U.S. GOVERNMENT PRINTING OFFICE

28–488 WASHINGTON : 

" ! SENATE 

109TH CONGRESS

2d Session 

REPORT

2006

109–325 

‘‘GIMME FIVE’’—INVESTIGATION OF TRIBAL 

LOBBYING MATTERS 

FINAL REPORT 

BEFORE THE

COMMITTEE ON INDIAN AFFAIRS 

ONE HUNDRED NINTH CONGRESS

SECOND SESSION

SEPTEMBER 5, 2006 

SEPTEMBER 5, 2006.—Ordered to be printed 

4:23 Sep 06, 2006 Jkt 028488 PO 00000 Frm 00003 Fmt 4012 Sfmt 4012 E:\HR\OC\SR325.XXX SR325
(II) 

COMMITTEE ON INDIAN AFFAIRS 

JOHN MCCAIN, Arizona, Chairman 

BYRON L. DORGAN, North Dakota, Vice Chairman 

PETE V. DOMENICI, New Mexico 

CRAIG THOMAS, Wyoming 

GORDON SMITH, Oregon 

MICHAEL D. CRAPO, Idaho 

RICHARD BURR, North Carolina 

TOM COBURN, M.D., Oklahoma 

DANIEL K. INOUYE, Hawaii 

KENT CONRAD, North Dakota 

DANIEL K. AKAKA, Hawaii 

TIM JOHNSON, South Dakota 

MARIA CANTWELL, Washington 
(III) 

INVESTIGATION STAFF 

PABLO E. CARRILLO, Esq., Chief Investigative Counsel for the Majority 

BRYAN D. PARKER, Esq., Deputy Chief Investigative Counsel for the Majority 

JEANNE L. BUMPUS, Esq., Staff Director for the Majority 

BRANDON I. ASHLEY, Staff Assistant for the Majority 

KATHERINE B. ROSSI, Staff Assistant for the Majority 

SARA G. GARLAND, Staff Director for the Minority 

DAVID MONTES, Professional Staff for the Minority 

EAMON P. WALSH, Research Assistant for the Minority 

ALLISON C. BINNEY, Esq., General Counsel for the Minority 

EMMETT M. O’KEEFE, Esq., Counsel for the Vice Chairman 

A special thanks to the efforts and support of the entire staff of the Senate Committee 

on Indian Affairs through the course of this investigation. 

(V) 

C O N T E N T S 

Page 

Investigation Staff ................................................................................................... iii 

Table of Names ........................................................................................................ ix 

Table of Entities ...................................................................................................... xiii 

Investigation Hearings ............................................................................................ xvii 

Introduction .............................................................................................................. 1 

Executive Summary and Findings ......................................................................... 7 

PART ONE—FACT SUMMARY BY TRIBE 

I. Mississippi Band of Choctaw Indians ................................................................ 13 

A. Introduction .................................................................................................. 13 

B. Background on the Tribe ............................................................................. 14 

C. Background on Abramoff and the Tribe’s Relationship—Building Trust 

and Confidence .............................................................................................. 15 

D. Substantial Fees and Conduits—Setting the Stage for Scanlon ............. 18 

E. Abramoff Brings Scanlon to the Choctaw .................................................. 24 

F. Abramoff Has the Choctaw Fund His Pet Projects ................................... 27 

1. 2000 Scotland Golf Trip ........................................................................ 27 

2. Sports Suites ......................................................................................... 27 

3. Liberty Consulting Services, LLC ........................................................ 28 

G. Conclusion .................................................................................................... 28 

II. Coushatta Tribe of Louisiana ............................................................................ 31 

A. Introduction .................................................................................................. 31 

B. Background on the Tribe ............................................................................. 33 

C. Abramoff and Scanlon Get the Louisiana Coushatta’s Business ............. 34 

D. Scanlon’s Grassroots Projects for the Tribe ............................................... 39 

E. Conclusion .................................................................................................... 43 

III. Saginaw Chippewa Tribe of Michigan ............................................................. 45 

A. Introduction .................................................................................................. 45 

B. Background on the Tribe ............................................................................. 46 

C. Christopher Petras—Abramoff and Scanlon’s Access to the Tribe .......... 47 

D. The ‘‘Slate of Eight’’—Abramoff and Scanlon’s Trojan Horse .................. 48 

E. The Tribe Hires Abramoff and Scanlon ..................................................... 54 

F. Abramoff on Tribal Client Management—‘‘keeping our people in 

power’’ ............................................................................................................ 58 

G. Christopher Petras’ Hearing Testimony Is Not Credible ......................... 63 

1. Petras’ Relationship With Abramoff and Scanlon .............................. 63 

2. Problems With Petras’ Testimony ....................................................... 65 

H. Abramoff and Scanlon Privately Express Contempt for the Tribe .......... 68 

I. Conclusion ..................................................................................................... 70 

IV. Agua Caliente Band of Cahuilla Indians ......................................................... 73 

A. Introduction .................................................................................................. 73 

B. Background on the Tribe ............................................................................. 74 

C. Abramoff and Scanlon Offer the Promised Land ...................................... 75 

D. Scanlon Works on C. Patencio and Siva’s Election Campaigns ............... 79 
Page

VI 

IV. Agua Caliente Band of Cahuilla Indians—Continued 

D. Scanlon Works on C. Patencio and Siva’s Election Campaigns—Continued 

1. Mail ........................................................................................................ 81 

2. Door-to-Door .......................................................................................... 82 

3. Telephone ............................................................................................... 82 

4. Candidates’ Meeting ............................................................................. 82 

E. C. Patencio and M. Patencio Pave the Way for Abramoff and Scanlon .. 83 

F. Abramoff and Scanlon Seek Additional Money From the Tribe .............. 90 

G. Abramoff and Scanlon’s Work for the Tribe .............................................. 91 

H. 2003 Tribal Elections .................................................................................. 93 

I. Chapman and Sierra Dominion Consulting ................................................ 94 

1. Payments to Chapman .......................................................................... 94 

2. Payments to Sierra Dominion .............................................................. 98 

J. Conclusion ..................................................................................................... 99 

V. Ysleta del Sur Pueblo (Tigua) ............................................................................ 101 

A. Introduction .................................................................................................. 101 

B. Background on the Tribe ............................................................................. 102 

C. Abramoff, Scanlon, and Reed Work Against the Tigua ............................ 103 

D. Abramoff and Scanlon Seek the Tribe’s Money ........................................ 106 

E. Secrecy and Contributions .......................................................................... 114 

F. Abramoff and His Colleagues Set the Plan in Motion in the House ....... 115 

G. Scanlon Purportedly Sets the Plan in Motion in the Senate ................... 117 

H. Things Begin To Unravel ............................................................................ 120 

I. Abramoff Asks the Tigua To Finance a Golfing Junket to Scotland ........ 121 

J. The Tribe Meets With Congressman Ney .................................................. 123 

K. Election Reform Passes Without the Tigua Provision .............................. 125 

L. The Elder Legacy Project ............................................................................ 127 

M. Abramoff and Scanlon Attempt To Obstruct the Investigation .............. 127 

N. Conclusion .................................................................................................... 128 

VI. Pueblo of Sandia of New Mexico ...................................................................... 129 

A. Introduction .................................................................................................. 129 

B. Background on the Tribe ............................................................................. 129 

C. The Search for a New Lobbyist .................................................................. 130 

D. Implementing the Plan ............................................................................... 132 

E. The Database ............................................................................................... 134 

F. A Happy Ending, in Spite of ... ................................................................... 136 

PART TWO—‘‘GIMME FIVE’’—ANALYSIS BY ENTITY 

Introduction .............................................................................................................. 137 

I. Capitol Campaign Strategies .............................................................................. 141 

A. Background .................................................................................................. 142 

B. Abramoff Conceals His Financial Relationship With Scanlon ................. 143 

C. Abramoff Induces the Tribes Into Hiring and Paying Scanlon ................ 145 

D. What Happened to the Money That the Tribes Paid Scanlon? ............... 149 

1. Snapshots of CCS’ Representation of the Tribes ................................ 149 

a. Transaction #1 (Miscellaneous)—Huge Profit Margins ............. 150 

b. Transaction #2 (August 2002)—Louisiana Coushatta and 

Agua Caliente Pay CCS a Total of $5,000,000 ............................. 152 

c. Transaction #3 (October 2001–January 2002)—Louisiana 

Coushatta Pays CCS $2,170,000 ................................................... 153 

d. Transaction #4 (January–April 2002)—Several Tribes Pay 

CCS Over $22,000,000 ................................................................... 157 

e. Transaction #5 (October 16, 2002)—Louisiana Coushatta Pays 

CCS $950,000 and the Agua Caliente Pays $1,745,000 to CCS . 161 
Page

VII 

I. Capitol Campaign Strategies—Continued 

D. What Happened to the Money That the Tribes Paid Scanlon?—Continued 

1. Snapshots of CCS’ Representation of the Tribes —Continued 

f. Transaction #6 (January–March 2003)—Louisiana Coushatta 

Pays CCS $5,000,000 ...................................................................... 163 

2. The ‘‘Database’’ ...................................................................................... 165 

a. The Pitch ........................................................................................ 165 

b. The Facts ........................................................................................ 171 

3. CCS’ Use of Fictitious Grassroots Organizations ............................... 174 

E. Conclusion .................................................................................................... 177 

II. American International Center ......................................................................... 179 

A. Introduction .................................................................................................. 179 

B. A Day at the Beach—How AIC Was Started ............................................ 180 

C. Making It Look Real—Abramoff Has AIC Post a Website ....................... 183 

D. How Abramoff and Scanlon Used Conduits To Represent the Tribes .... 187 

E. AIC as a ‘‘Gimme Five’’ Entity ................................................................... 191 

F. Conclusion .................................................................................................... 193 

III. Capital Athletic Foundation ............................................................................. 195 

A. Introduction .................................................................................................. 195 

B. General Background on CAF ...................................................................... 196 

C. Abramoff Attempts To Secure Federal Funding for CAF, and Fails ....... 197 

D. Abramoff and Scanlon Misappropriate Tribal Funds for CAF Seed 

Money in 2001 ............................................................................................... 198 

1. Abramoff and Scanlon Divert Louisiana Coushatta Money to CAF . 198 

2. Abramoff’s Misuse of CAF Funds in 2001 ........................................... 201 

E. In 2002, Abramoff and Scanlon Scam Other Tribes Into Paying Into 

CAF ................................................................................................................ 203 

1. Abramoff Deceives the Saginaw Chippewa Indian Tribe Into Partially Funding a Golfing Trip to Scotland—June Through November 2002 .................................................................................................. 203 

2. Abramoff and Scanlon Deceive the Mississippi Band of Choctaw 

Indians Into Sending $1 Million to CAF—January and August 

2002 ......................................................................................................... 206 

3. Abramoff and Scanlon Misappropriate Another $1 Million From 

the Choctaw—October 2002 .................................................................. 209 

4. Abramoff’s Misuse of CAF Funds in 2002 ........................................... 212 

F. In 2003, Abramoff Funnels Tribal Money Through Conduits to CAF ..... 219 

1. Kaygold Sends Tribal Funds to CAF ................................................... 219 

2. Abramoff and Scanlon Use ARA as a Conduit To Funnel Louisiana 

Coushatta Funds to CAF ...................................................................... 219 

3. Abramoff’s Use of CAF Funds in 2003 ................................................ 222 

G. Conclusion .................................................................................................... 223 

PART THREE—OTHER 

I. Council of Republicans for Environmental Advocacy ........................................ 225 

A. Background .................................................................................................. 225 

1. Abramoff Has His Tribal Clients Pay CREA ...................................... 226 

2. Federici Promises To Help Abramoff in Exchange for, or Because 

of, CREA Contributions ......................................................................... 229 

B. Abramoff and Federici Start Working Together ....................................... 230 

C. Contributions in Exchange for Access? ...................................................... 233 

D. What Did Federici Do for Abramoff at Interior? ....................................... 236 

E. What, if Anything, Griles Did for Abramoff’s Clients Is Unclear ............ 239 

F. Conclusion .................................................................................................... 244 
Page

VIII 

PART FOUR—RECOMMENDATIONS 

A. Introduction ......................................................................................................... 247 

B. Contracting for Legal, Lobbying and Other Professional Services ................. 247 

1. No New or Revised Federal Legislation Needed ........................................ 247 

2. Best Practices Recommendations ................................................................ 247 

a. Contracting for legal, lobbying and other services should follow 

a specific, open and competitive process .............................................. 248 

b. Contracting rules should be structured to prevent conflicts of interest ............................................................................................................ 248 

c. Contracting and conflict of interests rules should include appropriate sanctions ...................................................................................... 249 

d. Tribes should consider working with tribal organizations and educational institutions to develop model codes and education programs addressing contracting and conflicts of interests .................... 249 

C. Integrity of Tribal Elections ............................................................................... 249 

D. Tribal Political Contributions ............................................................................ 250 

E. Referrals to Other Committees .......................................................................... 251 

1. Possible Misuse of Tax Exempt Organizations .......................................... 251 

PART FIVE—VIEWS 

I. Additional Views of Senator Daniel K. Inouye .................................................. 253 

A. Introduction .................................................................................................. 253 

B. Discussion ..................................................................................................... 253 

PART SIX—EXHIBITS 

I. Appendix One (Dated Exhibits) .......................................................................... 255 

A. Pre-2001 Exhibits ........................................................................................ 255 

B. 2001 Exhibits ............................................................................................... 285 

C. 2002 Exhibits ............................................................................................... 423 

D. 2003 Exhibits ............................................................................................... 831 

E. 2004 Exhibits ............................................................................................... 1044 

II. Appendix Two (Undated Exhibits) .................................................................... 1107 

III. Appendix Three (Documents Transmitted to Senate Finance Committee) .. 1278 
(IX)

TABLE OF NAMES 

Abramoff, Jack: former lobbyist, Greenberg Traurig; Preston 

Gates Ellis & Rouvelas Meeds. 

Baggett, Fred: Chair, National Governmental Affairs Practice, 

Greenberg Traurig. 

Ben Zvi, Shmuel: former high-school friend of Abramoff. 

Benn, Charlie: Director of Administration, Office of the Chief, 

Mississippi Band of Choctaw Indians. 

Biederman, Amy: former associate, Capitol Campaign Strategies. 

Boulanger, Todd: former associate, Greenberg Traurig. 

Bozniak, Allison: former assistant to Abramoff, Greenberg 

Traurig. 

Cathcart, Christopher: former associate, Capitol Campaign 

Strategies. 

Chapman, Michael: former business associate of Abramoff and 

Scanlon. 

Doolittle, Julie: president, Sierra Dominion Financial Solutions. 

Federici, Italia: president, Council of Republicans for Environmental Advocacy. 

Griles, J. Steven: former Deputy Secretary, U.S. Department of 

the Interior. 

Grosh, David: former director, American International Center. 

Halpern, Gail: former tax advisor to Abramoff. 

Hisa, Carlos: Lieutenant Governor, Ysleta del Sur Pueblo of 

Texas. 

Kahgegab, Maynard: former Chief, Saginaw Chippewa Indian 

Tribe. 

Kilgore, Donald: Attorney General, Mississippi Band of Choctaw 

Indians. 
X

Kuhn, Jennifer: vice-president, Finance and Development, Americans for Tax Reform. 

Lane, Rodney: former assistant to Abramoff, Greenberg Traurig; 

former business associate of Abramoff. 

Lapin, Rabbi Daniel: president, Toward Tradition. 

Lippy, Laura: assistant to Abramoff. 

Mann, Brian: former director, American International Center. 

Martin, Phillip: Chief, Mississippi Band of Choctaw Indians. 

Martin, Terry: Governmental Affairs/Administrative Liaison, 

Chitimacha Tribe of Louisiana. 

McConnon, BR: president, Democracy Data & Communications. 

Mielke, David: outside counsel, Pueblo of Sandia. 

Milanovich, Richard: Chairman, Agua Caliente Band of Cahuilla 

Indians. 

Norquist, Grover: president, Americans for Tax Reform. 

Norton, Gale: former Secretary, U.S. Department of the Interior. 

Otto, David: former Sub-Chief, Saginaw Chippewa Indian Tribe. 

Paisano, Stuwart: former Governor, Pueblo of Sandia. 

Pego, Robert: former council member, Saginaw Chippewa Indian 

Tribe. 

Petras, Christopher: former legislative director, Saginaw Chippewa Indian Tribe. 

Patencio, Candace: former council member, Agua Caliente Band 

of Cahuilla Indians. 

Reed, Ralph: president, Century Strategies. 

Ridenour, Amy: president, National Center for Public Policy Research. 

Ring, Kevin: former associate, Greenberg Traurig. 

Rogers, Nell: planner, Mississippi Band of Choctaw Indians. 

Rossetti, Michael: former Counselor to the Secretary, U.S. Department of the Interior. 
XI

Scanlon, Michael: president, Capitol Campaign Strategies; Scanlon Public Affairs; Scanlon Gould Public Affairs; American International Center; Principal, Atlantic Research & Analysis. 

Schwartz, Marc: president, Partners Group Consultants; former 

spokesperson, Ysleta del Sur Pueblo of Texas. 

Short, Stephanie Leger: former associate, Greenberg Traurig. 

Sickey, David: Council member, Coushatta Tribe of Louisiana. 

Sickey, Kevin: Chairman, Coushatta Tribe of Louisiana. 

Siva, Virginia: Tribal Council member, Agua Caliente Band of 

Cahuilla Indians. 

Smith, Michael: former associate, Greenberg Traurig. 

Sprague, Bernie: Sub-Chief, Saginaw Chippewa Indian Tribe. 

Stetter, Aaron: former associate, Capitol Campaign Strategies. 

Van Hoof, Kathryn: former outside counsel, Coushatta Tribe of 

Louisiana. 

van Horne, Jon: former associate, Greenberg Traurig. 

Vasell, Shawn: former associate, Greenberg Traurig. 

Volz, Neil: former associate, Greenberg Traurig; former chief of 

staff, U.S. Congressman Robert W. Ney. 

Worfel, William: former Vice-Chairman, Coushatta Tribe of Louisiana. 

(XIII)

TABLE OF ENTITIES 

ENTITIES OWNED OR CONTROLLED BY ABRAMOFF

Aeneas Enterprises: a consulting firm that received payments from another Abramoff controlled entity called Grassroots Interactive, which did business with, among others, Tyco International 

and International Interactive Alliance. 

Archives: a company that owned Stacks, formerly a kosher deli lo- cated in Washington, DC. 

Beis Avrohom Chaim: a company used to acquire real estate. 

Capital Athletic Foundation (‘‘CAF’’): a charitable foundation 

used to fund Abramoff’s private Jewish boys’ school, called the 

Eshkol Academy, and other projects with which he was in some 

way associated. 

Eshkol Academy: See Capital Athletic Foundation, supra. 

Grassroots Interactive (‘‘GRI’’): See Aeneas Enterprises, supra. 

Kaygold: a company used to collect ‘‘consulting fees’’ from entities owned or controlled by Scanlon. 

Lexington Group: a company that performed lobbying-type services. 

Livsar Enterprises: a company that owned Signatures, formerly a restaurant-bar located in Washington, DC. 

Sports Suites: a company that leased, with money provided by 

some of Abramoff’s Tribal clients, sky boxes at sports and concert 

venues in Washington, DC and Baltimore, Maryland. 

ENTITIES OWNED OR CONTROLLED BY SCANLON

American International Center (‘‘AIC’’): a supposed think tank 

used to collect money for services performed by others and to secretly pay money to Abramoff. 

Atlantic Research and Analysis (‘‘ARA’’): a company used to secretly pay money to Abramoff. 

Capitol Campaign Strategies (‘‘CCS’’): a grassroots/political 

consulting firm that secretly paid money to Abramoff. 

Christian Action Network: a fictitious grassroots organization. 
XIV

Christian Research Network: a fictitious grassroots organization. 

Concerned Citizens Against Gaming Expansion (‘‘CCAGE’’): 

a fictitious grassroots organization. 

Global Christian Outreach Network (‘‘GCON’’): a fictitious 

grassroots organization. 

Scanlon Capital Management: a company used to invest money. 

Scanlon Gould Public Affairs: a grassroots/political consulting 

firm that secretly paid money to Abramoff. 

Scanlon Venture Capital: a company used to invest money. 

OTHER

Alexander Strategies Group (‘‘ASG’’): a consulting firm owned 

or controlled by former Congressman Tom DeLay’s former chief of 

staff Ed Buckham to or through which Abramoff or Scanlon directed their Tribal clients to pay money. 

Americans for Tax Reform (‘‘ATR’’): a non-profit anti-tax organization headed by conservative activist Grover Norquist to or 

through which Abramoff or Scanlon directed their Tribal clients to 

pay money. 

Capitol Media: a grassroots/political consulting firm owned or 

controlled by former Christian Coalition Executive Director Ralph 

Reed. 

Century Strategies: a grassroots/political consulting firm owned 

or controlled by former Christian Coalition Executive Director 

Ralph Reed. 

Council of Republicans for Environmental Advocacy 

(‘‘CREA’’): an environmental non-profit organization to or through 

which Abramoff or Scanlon directed their Tribal clients to pay 

money. 

Democracy Data and Communications (‘‘DDC’’): a firm that 

built, operated and maintained political databases for Scanlon and 

his Tribal clients. 

Greenberg Traurig (‘‘GT’’): a lobbying firm with which Abramoff 

was associated during the relevant period. 

Kollel Ohel Tiferet: an entity used to enable the CAF to distribute money to a sniper workshop in Israel. 

Liberty Consulting: a consulting firm owned or controlled by 

former Congressman Tom DeLay’s former deputy chief of staff 
XV

Tony Rudy to or through which Abramoff or Scanlon directed some 

of their Tribal clients to pay money. 

National Center for Public Policy Research (‘‘NCPPR’’): a 

non-profit educational foundation on whose board Abramoff sat, to 

or through which he or Scanlon directed some of their Tribal clients to pay money. 

(XVII)

INVESTIGATION HEARINGS 

FIRST HEARING

Oversight Hearing on In re Tribal Lobbying Matters, et al., 

Wednesday, September 29, 2004, 9:30 am, Room 216 of the Hart 

Senate Office Building. 

Panel One—Mr. Jack Abramoff, former lobbyist, Greenberg 

Traurig, and Mr. Michael Scanlon, president, Capitol Campaign 

Strategies. Mr. Scanlon was invited, but did not appear before the 

Committee on this date. 

Panel Two—The Honorable Richard Milanovich, Chairman, Agua 

Caliente Band of Cahuilla Indians and The Honorable Bernie 

Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe of Michigan. 

Panel Three—Dr. Christopher Petras, former legislative director, 

Saginaw Chippewa Indian Tribe of Michigan. 

SECOND HEARING

Oversight Hearing on In re Tribal Lobbying Matters, et al., 

Wednesday, November 17, 2004, 3:00 pm, Room 216 of the Hart 

Senate Office Building. 

Panel One—Mr. Marc Schwartz, president, Marc Schwartz Partners and The Honorable Carlos Hisa, Lieutenant Governor, Ysleta 

del Sur Pueblo. 

Panel Two—Mr. Michael Scanlon, president, Capitol Campaign 

Strategies. 

THIRD HEARING

Oversight Hearing on In re Tribal Lobbying Matters, et al., 

Wednesday, June 22, 2005, 9:30 am, Room 216 of the Hart Senate 

Office Building. 

Panel One—Mr. Charlie Benn, Director of Administration, Office 

of the Chief, Mississippi Band of Choctaw Indians; Donald Kilgore, 

Esq., Attorney General, Mississippi Band of Choctaw Indians; and 

Ms. Nell Rogers, planner, Mississippi Band of Choctaw Indians. 

Panel Two—Mr. Kevin Ring, former Abramoff associate and Mr. 

Shawn Vassell, former Abramoff associate. 

Panel Three—Mrs. Amy Ridenour, president, National Center for 

Public Policy Research; Ms. Gail Halpern, Abramoff’s former tax 

advisor; Mr. Brian Mann, former director, American International 

Center; Mr. David Grosh, former director, American International 

Center; and Mr. Aaron Stetter, former Scanlon associate, Capitol 

Campaign Strategies. 
XVIII

FOURTH HEARING

Oversight Hearing on In re Tribal Lobbying Matters, et al., 

Wednesday, November 2, 2005, 9:00 am, Room 216 of the Hart 

Senate Office Building. 

Panel One—The Honorable Kevin Sickey, Chairman, Coushatta 

Tribe of Louisiana and Mr. David Sickey, Tribal Council Member, 

Coushatta Tribe of Louisiana. 

Panel Two—Mr William Worfel, former Tribal Council member, 

Coushatta Tribe of Louisiana; Mrs. Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana; and Mr. Fred Baggett, 

managing shareholder; Chair, National Governmental Affairs Practice, Greenberg Traurig. 

Panel Three—Mr. B.R. McConnon, president, Democracy Data & 

Communications; Mr. Christopher Cathcart, former associate, Capitol Campaign Strategies; and Ms. Gail Halpern, Abramoff’s former 

tax advisor. 

Panel Four—Mr. J. Steven Griles, former Deputy Secretary, U.S. 

Department of the Interior; Mr. Michael Rossetti, Esq., former 

counsel to the Secretary of the Interior, U.S. Department of the Interior; and Ms. Italia Federici, president, Council of Republicans for 

Environmental Advocacy. Ms. Federici was invited, but did not appear before the Committee on this date. 

FIFTH HEARING

Oversight Hearing on In Re Tribal Lobbying Matters, et al., 

Wednesday, November 17, 2005, 10:00 am, Room 216 of the Hart 

Senate Office Building. 

Panel One—Ms. Italia Federici, president, Council of Republicans 

for Environmental Advocacy. 
(1) 

1 Email between Michael Scanlon, Capitol Campaign Strategies, and Jack Abramoff, Green- berg Traurig (GTG–E000011945) (June 18, 2001). 

INTRODUCTION 

Etched in the history of our great nation is a long and 

lamentable chapter about the exploitation of Native Americans. It began with the sale of Manhattan, and has continued ever since. Every kind of charlatan and every type of 

crook has deceived and exploited America’s native sons 

and daughters. While these accounts of unscrupulous men 

are sadly familiar, the tale we hear today is not. What sets 

this tale apart, what makes it truly extraordinary, is the 

extent and degree of the apparent exploitation and deceit. 

Opening Statement of then-Committee Ranking Majority Member John McCain, 

during the Committee’s September 29, 2004, hearing on allegations made by Tribes 

against Jack Abramoff and Michael Scanlon 

[J]ust speaking as an enrolled member of an Indian tribe, 

not the chairman of this committee, I have to tell you that 

for 400 years people have been cheating Indians in this 

country, so you’re not the first one, Mr. Scanlon. It’s just 

a shame that in this enlightened day that you have added 

a new dimension to a shameful legacy of what’s happened 

to American Indians. You’re the problem, buddy, of what’s 

happened to American Indians. 

Closing remarks of then-Chairman Ben Nighthorse Campbell, during the Committee’s November 17, 2004, hearing on allegations made by Tribes against Jack 

Abramoff and Michael Scanlon 

[It] [n]eeds to have a bit more about how the tribes in the 

past were left helpless at the whims and good will of nontribal members. Some reference to the past and how they 

were always given the [short] end of the stick would be 

pretty important, I think. 

Email from Jack Abramoff to associate Todd Boulanger, February 26, 2004 

(critiquing draft letter intended for The Washington Post and Senate Indian Affairs 

Committee regarding Committee investigation) 

Yes, I did wrong, but I did a hell of a lot right too. Basically, I was the best thing they had going. I knew it, they 

knew it. My mistake was not informing them (about Scanlon). 

Jack Abramoff to contributing editor David Margolick, Vanity Fair, ‘‘Washington’s 

Invisible Man,’’ April 2006 

FACTUAL BACKGROUND

On the afternoon of June 18, 2001, in Washington, D.C., 

racquetball was the order of the day.1 Having brought former congressional communications director Michael Scanlon with him to 
2 

2 Id. 

3 Id. 

4 Id. 

5 Id. 

6 Email from Jack Abramoff, Greenberg Traurig, to Rodney Lane (GTG–E000011577) (March 15, 2002). 7 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg Traurig (GTG–E000012012) (March 25, 2003). Scanlon might have been referring to his resale 

of an expensive five-bedroom canal-front home near Rehoboth, Delaware, he had bought in November 2001, apparently with Tribal proceeds, in one of that area’s most prestigious neighborhoods—reportedly for $1,200,000 more that he paid. See Cris Barrish, Abramoff cohort spent 

millions on Sussex homes—As a Rehoboth lifeguard last year, he made $11.35 an hour, The 

News Journal, May 14, 2006. Early in 2003, Scanlon also reportedly paid $1,600,000 in cash 

for a home on Baltimore Avenue (across the street from where he ran his supposed international 

think tank, the American International Center) where he later opened offices. Id. 8 Email between Michael Scanlon, Capitol Campaign Strategies, and Jack Abramoff, Greenberg Traurig (GTG–000012012) (March 25, 2003). 

the lobbying shop at Greenberg Traurig for what ended up as a 

brief stint, Jack Abramoff wanted to get together with Scanlon for 

a round. 

But, Scanlon, who was now out on his own, wanted to talk shop: 

‘‘A few weeks ago you mentioned something to me—I took the concept and have put together a plan that will make serious money. 

We also talked briefly about it in the beginning of the year but I 

think we can really move it now.’’ 2

Scanlon went on to describe ‘‘the broad strokes’’: ‘‘I have been 

making contacts with some larger Public Affairs companies in town 

for a few months. I have two solid relationships that will seriously 

consider acquiring Capitol Campaign Strategies. The problem is 

that there is not much in CCS right now.’’ 3

‘‘However,’’ he continued, ‘‘if we build up Capitol Campaign 

Strategies enough I can get it acquired by a large firm by the end 

of next year at 3x [sic] the firm revenue. Bottom line: If you help 

me get CCS a client base of $3 million a year, I will get the clients 

served, and the firm acquired at $9 million. We can then split the 

[sic] up the profits. What do you think?’’ 4

Abramoff’s response was brief: ‘‘Sounds like a plan, but let’s discuss when we are together.’’ 5

This appears to be the genesis of a partnership the two would 

later infamously label as ‘‘gimme five’’—their secret plan ‘‘to put in 

$5[million] revenue/yr [in fees from tribes, into] CCS.’’ 6 Later, the 

term ‘‘gimme five’’ came to mean kickbacks to Abramoff from payments made by any of Scanlon’s Tribal clients to Scanlon. 

By Spring 2003, Abramoff and Scanlon’s secret financial arrangement was apparently straining. The two had failed to get a Tribal 

client’s casino reopened. And Scanlon, apparently awash in cash, 

seemed to have outgrown the partnership and appeared more interested in putting his ill-gotten gains to work. 

He offered Abramoff, ‘‘I have a few real estate developments in 

the pipeline—One really big one—and a couple of small ones that 

I may need to raise outside capital for. I can guarantee the returns 

on rate and time, and if you wanted to do more down the road taking a run at the upside potential you could get into some of the 

longer term stuff ... (I’m turning a 100% return on a one year 

project next month).’’ 7

Abramoff responded, ‘‘OK, let’s chat when we are next together. 

Meanwhile, let’s get some more fucking money!’’ 8
3 

9 John Bresnahan, Jack Doubles Down, Washington Business Forward, November/December 

2002 (citing estimates provided by Abramoff). 10 Id. 11 Id. 12 ‘‘K Street’’ is a commonly used term for the numerous think tanks, lobbying firms, law firms 

and associations located on and around this major thoroughfare in Washington, D.C. 13See Email from Linsey Crisler, Greenberg Traurig, to Jack Abramoff, Greenberg Traurig (GTG–E000010599–614) (February 3, 2004) (embedding transcript of Abramoff interview with 

Schmidt). 14 Id. 15 Id. 16 Id. 17 Id. 

Making money was certainly nothing new to Abramoff. When he left the premier Washington, D.C. offices of the lobbying firm Preston Gates Ellis & Rouvelas Meeds in December 2000 for a relatively new Washington lobbying group at Greenberg Traurig, 

Abramoff brought with him a book of business worth more than $6 

million annually, according to Abramoff’s own estimates.9 This 

helped Greenberg Traurig generate a 500 percent increase in lobbying fees over the previous year.10 With that increase, Greenberg Traurig reportedly vaulted into the top ten Washington lobbying 

firms—jumping from sixteenth place to fourth.11 While Abramoff’s 

impact on ‘‘K Street’’ 12 during this period is generally well-known, the precise nature of his relationship with Scanlon has been, until 

recently, a closely-held secret—concealed, most importantly from 

Abramoff and Scanlon’s Tribal clients. 

By February 5, 2004, time was running out for Abramoff and Scanlon’s secret business arrangement. In a conference room at 

Greenberg Traurig, Washington Post reporter Susan Schmidt interviewed Abramoff on allegations that he and Scanlon may have 

bilked several Tribes out of millions of dollars in fees.13 With 

Abramoff were Greenberg Traurig spokesperson Jill Perry and associates Todd Boulanger, Kevin Ring, Allen Foster, and Jon van 

Horne.14 Things apparently heated-up quickly. Schmidt began, ‘‘As I’m sure you know I’m working on a story about your work with some of these gaming tribes and your relationship with Mike Scanlon and his company and the work that the 

two of you have done in tandem for some of the tribes and so that’s 

what I want to talk to you about ... So, I want to ask you, basically 

what your relationship is with his firm, well he’s got several firms. 

As I understand it from the tribes that I’ve talked to, you guys 

work together and you recommend that they hire him.’’ 15

Abramoff deftly answered—truthfully but non-responsively: ‘‘In terms of Mike or any other third party, you know the firm does not 

have any formal relationship, to my knowledge, with any third 

party vendor used by any of the tribes for some of their activities 

and so probably best to have you go ahead and check directly with 

him and if you have specific questions again, we’ll take them and 

we’ll look at them, but in general I think we feel at liberty to discuss in general our practice, which we’re delighted to do, with the 

tribes.’’ 16

Schmidt pushed: ‘‘Okay, but you basically recommend to these 

tribes that they hire him?’’ 17

Once again, Abramoff strained to avoid answering the question, 

but was quickly running out of wiggle room: ‘‘We have recommended that different tribes hire different vendors for different 
4 

18 Id. 19 Id. 20 Id. 21 Id. 22 Id. 23 Email from Jack Abramoff, Greenberg Traurig, to Candace Patencio, Agua Caliente of 

Cauhilla Band (GTG–E000057926) (February 3, 2004). 24 Id. 25 Email between Todd Boulanger, Greenberg Traurig, and Jack Abramoff, Greenberg Traurig, 

and Kevin Ring, Greenberg Traurig (GTG–E000028537) (February 5, 2004). 26 Id. (ellipses in original). 27 Id. 28 Id. 29 Id. 

needs that they might have. Again, I’m going to defer in terms of 

any discussion of Scanlon or his company or any specific third 

party vendor.’’ 18

Schmidt pushed more: ‘‘Well, do you recommend his company and do you know what they are doing for the tribes and do you endorse what he’s doing?’’ 19

Abramoff offered, ‘‘Well, again I think that some of this gets into the area of our confidential dealings with our clients so I’m happy, 

we’ll go back and look at that question.’’ 20

Schmidt finally cut to the chase: ‘‘Do you have an ownership stake in Capitol Campaign Strategies or Scanlon Gould or any of 

Mike Scanlon’s other ventures?’’ 21

Even a pregnant pause here might be looked on with some sus- picion. So, Abramoff had no choice: ‘‘No. No, I don’t. ...’’ 22

As future events would soon reveal, this of course was a lie. 

Perhaps mindful of his actual financial arrangement with Scan- lon, which he withheld from Schmidt, Abramoff was very concerned 

about how the interview went. Among others, he wrote to Candace 

Patencio, an ally at the Agua Caliente Band of Cahuilla Indians.23

The next race for Chairman was the topic of conversation. 

Abramoff wrote, ‘‘I think you are right that we really need Richard 

[Milanovich] to beat [his opponent]. [His opponent] is poison. She 

has been feeding The Washington Post a hit piece about Scanlon 

and me. It’s going to be horrible. It is so obvious it’s her doing this 

too. Can’t wait to see you on the 23rd.’’ 24

A couple of days later, on February 5, 2004, Abramoff’s most sen- ior associate, Todd Boulanger reached out to Abramoff and colleague Kevin Ring: ‘‘Someone on the [Saginaw Chippewa Tribal] 

council trashed us, our work, and [S]canlon ... We are going to get 

smoked here.’’ 25 He added, ‘‘[Abramoff] should [file suit for slander] 

... after what happe[n]ed a couple of months ago. We are dead.’’ 26

Likely appreciating that the thrust of the pending Post story was true, Abramoff could only offer, ‘‘Where are you now?’’ 27

Boulanger answered, ‘‘Going to bed. I’m really [sic] in a terrible mood.’’ 28

Abramoff could only reply, ‘‘Me too.’’ 29

THE CONDUCT OF THE INVESTIGATION AND THE REPORT

On February 22, 2004, The Washington Post published Schmidt’s 

article, entitled ‘‘A Jackpot From Indian Gaming Tribes; Lobbying, 

PR Firms Paid $45 Million Over 3 Years.’’ Based on the allegations 

of misconduct made by several Tribes documented in the Post article, then-Chairman Ben Nighthorse Campbell of the Senate Com-
5 

30Where witnesses whom the Committee interviewed were not put under oath, they were reminded of the applicability of the False Statements Act, 18 U.S.C. sec. 1001, and the federal 

criminal statute prohibiting the obstruction of congressional investigations, under 18 U.S.C. sec. 

1505. Because all witness interviews and depositions were conducted in executive session, the 

Committee will not release summaries or transcripts of those proceedings in toto unless said 

release is duly authorized. 

In the course of the Committee’s investigation, several witnesses declined to provide the Committee with important information under oath, citing their right against self-incrimination 

under the Fifth Amendment of the U.S. Constitution, or indicated that they intended to assert 

their Fifth Amendment right if called to testify. These witnesses include not only Abramoff and 

Scanlon but also former Abramoff associates Todd Boulanger, Kevin Ring, Shawn Vassell, and 

Neil Volz as well as former Scanlon associate Christopher Cathcart. Cathcart did, however, submit to several informal interviews with staff. 

mittee on Indian Affairs, authorized then-Ranking Majority Member John McCain to conduct an investigation of these matters. Following Senator Campbell’s retirement at the end of the 108th Congress, Senator McCain continued the investigation during the 

109th Congress, as Chairman of the Committee. Ultimately, the 

Committee examined Abramoff and Scanlon’s dealings with six 

tribes: the Mississippi Band of Choctaw Indians, the Coushatta 

Tribe of Louisiana, the Saginaw Chippewa Indian Tribe, the Agua 

Caliente Band of Cahuilla Indians, the Ysleta del Sur Pueblo of 

Texas and the Pueblo of Sandia of New Mexico. 

While a Department of Justice task force reportedly began a par- allel inquiry into related matters, the Committee sought to answer 

several questions, including but not limited to the following: (1) are 

the Tribes’ allegations of misconduct regarding Abramoff and Scanlon true; (2) if so, how much did those Tribes pay Abramoff and 

Scanlon’s partnership, as well as third-parties at their direction, as 

a result of that misconduct; and (3) did those Tribes receive the intended benefit of the tens of millions of dollars that they paid Scanlon and Abramoff. With this Report, the Committee attempts to set 

forth definitive conclusions and the bases for those conclusions regarding each of those areas, and others. After an intensive two-year investigation—consisting of five hear- ings, 70 formal requests for documents, including subpoenas, resulting in the production of about 750,000 pages; and about 60 

depositions and witness interviews, 30 the Committee found that, as 

Scanlon’s secret partner, Abramoff received about half of the profit 

that Scanlon collected from the $66 million in fees he obtained 

from six of his Tribal clients from 2001 through 2003. Principally, this Report focuses on allegations of misconduct made by the covered Tribes. Generally, those allegations relate to 

the activities of entities owned or controlled by Abramoff and/or 

Scanlon, including Capitol Campaign Strategies, the American 

International Center and the Capital Athletic Foundation. This Report also addresses payments that those Tribes made at Abramoff 

or Scanlon’s direction to particular third parties—payments that 

were apparently used by third parties, like the Council of Republicans for Environmental Advocacy, for purposes unintended by the 

Tribes. While some of the Tribes have expressed concern about discreet billing anomalies, those Tribes have generally not alleged 

wrongdoing arising from the federal lobbying activities of Greenberg Traurig, the firm with which Abramoff was associated. Therefore, this Report does not address those activities. 

Also beyond the scope of this Report is an in depth discussion of 

the internal political or organizational conditions within each of the 
6 

Tribes that may have rendered them susceptible to exploitation by 

Abramoff and Scanlon. Those are internal Tribal matters. 

Part I of this Report, presented in chapters relating to each 

Tribe, provides the factual background as to how each Tribe came 

to hire Abramoff and Scanlon and discusses how Abramoff and 

Scanlon’s representation of those Tribes caused unique harm to 

each of them. After these chapters, the Report explicates Abramoff 

and Scanlon’s ‘‘gimme five’’ arrangement and how it injured the 

Tribes generally. Each chapter in Part II addresses these issues by 

focusing on the relevant ‘‘gimme five’’ entity. Part III of this Report 

discusses ancillary issues that have arisen during the course of the 

investigation, namely, the Tribes’ payment of money to a non-profit 

called the Council of Republicans for Environmental Advocacy 

(‘‘CREA’’). Finally, Part IV of the Report contains the Committee’s 

recommendations flowing from its investigation. 

COMMITTEE ACTION

On June 12, 2006, the Committee invited Members and any duly 

designated staff to review a completed draft of the Report in anticipation of a business meeting to be convened for the purpose of voting the Report out of Committee and filing it with the Senate. It 

also gave Members the opportunity to accept a confidential copy of 

the draft in their offices on June 20, 2006. On June 22, 2006, the 

Committee held a business meeting, at which time it voted 13 to 

0 to approve this Report and file it with the Senate. Voting with 

the majority were Senators McCain, Dorgan, Domenici, Thomas, 

Smith, Murkowski, Crapo, Burr, Coburn, Conrad, Akaka, Johnson, 

Cantwell. No Members voted in the negative. Senator Inouye submitted additional views. 
(7) 

EXECUTIVE SUMMARY AND FINDINGS 

After (or at the same time when) several Tribes hired Abramoff 

as their federal lobbyist, Abramoff urged some of them to hire 

Scanlon to provide grassroots support. Abramoff, however, failed to 

disclose that he and Scanlon were partners. Evidence obtained over 

the course of a two-year investigation indicates that Abramoff and 

Scanlon had agreed to secretly split, between themselves, fees that 

the Tribes paid Scanlon from 2001 through 2003. Abramoff and 

Scanlon referred to this arrangement as ‘‘gimme five.’’ 

As a general proposition, the scheme involved the following: getting each of the Tribes to hire Scanlon as their grassroots specialist; dramatically overcharging them for grassroots and related 

activities; setting aside for themselves an unconscionable percentage of what the Tribes paid at a grossly inflated rate—a rate wholly unrelated to the actual cost of services provided; and using the 

remaining fraction to reimburse scores of vendors that could help 

them maintain vis-a-vis the Tribes a continuing appearance of competence. One example of this fee-splitting arrangement arises from 

a payment of $1,900,000 from the Saginaw Chippewa Tribe of 

Michigan. On or about July 9, 2002, Scanlon assured Abramoff, 

‘‘800 for you[,] 800 for me[,] 250 for the effort the other 50 went 

to the plane and misc expenses. We both have an additional 500 

coming when they pay the next phasem [sic].’’ Indeed, on July 12, 

2002, after that payment arrived, Scanlon made three payments to 

Abramoff, including a payment of $800,000. 

In some cases, Abramoff and Scanlon obtained lobbying and 

grassroots contracts by insinuating themselves into Tribal Council 

elections and assisting with the campaigns of candidates who were 

calculated to support their proposals. In other cases, Abramoff and 

Scanlon were even more aggressive, for example, helping to shut 

down the casino of one Tribe, only to pitch their services—for millions of dollars—to help that same, now desperate Tribe reopen its 

casino. 

Typically, the most expensive element of Scanlon’s proposals to 

the Tribes related to a purportedly elaborate political database. 

But, in all cases, it appears that the degree to which Scanlon 

marked-up his actual costs was unconscionable. For example, while 

Scanlon told the Coushatta Tribe of Louisiana that their ‘‘political’’ 

database would cost $1,345,000, he ended up paying the vendor 

that actually developed, operated and maintained that database 

about $104,560. The dramatic mark-ups were intended to accommodate Scanlon’s secret 50/50 split with Abramoff. 

In total, six tribes paid Scanlon’s companies, in particular a company called Capitol Campaign Strategies (‘‘CCS’’) (which also did 

business as Scanlon Gould Public Affairs and Scanlon Public Affairs), at least $66,000,000 over the three-year period. By the Committee’s reckoning, each Tribe paid CCS as follows: the Mississippi 
8 

31 According to records in the Committee’s possession, two of Abramoff’s Tribal clients made 

payments to the AIC: the Choctaw, $2,655,654 and the Coushatta, $3,653,200. So, the total that 

all of Abramoff’s Tribal clients paid the AIC was $6,308,854. During the relevant period, Scanlon paid Abramoff through the AIC a total of $991,000 and an additional $950,000 through another entity that he controlled, called Atlantic Research & Analysis. 

Band of Choctaw Indians (‘‘Choctaw’’), $14,745,650; the Coushatta 

Tribe of Louisiana (‘‘Louisiana Coushatta’’), $26,695,500; the Saginaw Chippewa Tribe of Michigan (‘‘Saginaw Chippewa’’), 

$10,007,000; the Agua Caliente Band of Cahuilla Indians (‘‘Agua 

Caliente’’), $7,200,000; the Ysleta del Sur Pueblo of Texas 

(‘‘Tigua’’), $4,200,000; and the Pueblo of Sandia of New Mexico 

(‘‘Pueblo of Sandia’’), $2,750,000. Of that $66,000,000, Abramoff secretly collected from Scanlon, through (among other entities) an entity called Kaygold, about $24,000,000. This constituted about onehalf of Scanlon’s total profit from the Tribes. 

The $66,000,000 figure includes only those payments made by 

the Tribes to Scanlon for grassroots activities. The total cost of 

doing business with Abramoff and Scanlon was actually much higher. To determine that cost, one must add to the $66,000,000 figure, 

payments made by the Tribes to the lobbying firms with which 

Abramoff was associated and payments made by the Tribes directly 

to other entities owned or controlled by Abramoff, such as the Capital Athletic Foundation (‘‘CAF’’), or by Scanlon, such as the American International Center (‘‘AIC’’).31

Most of the money that the Tribes paid Scanlon appears to have 

been used by Scanlon and Abramoff for purely personal purposes— 

purposes unintended by the Tribes. Generally, Abramoff seems to 

have used his share of the proceeds he received from Scanlon to 

float his restaurant ventures and, through CAF, operate his Jewish 

boys’ school in Maryland. Likewise, Scanlon seems to have used his 

share to purchase real estate and other investments. The Committee, therefore, finds that most of the Tribes received little of the 

intended benefit for the significant sums they paid to Scanlon and 

that most of the money paid by the Tribes was used for purposes 

unintended by the Tribes. Against that backdrop, understanding 

under what circumstances the Tribes paid Scanlon becomes important. 

Probably Abramoff’s most valued Tribal client was the Choctaw. 

Since 1995, when the Choctaw first hired Abramoff, a history of 

dramatic victories emerged, with Abramoff successfully advocating 

the Tribe’s sovereignty and anti-tax interests before Congress. In 

many instances, Abramoff had the Tribe use conduits to conceal its 

grassroots activities from the world—activities often conducted by 

former Christian Coalition Executive Director Ralph Reed. After 

this history of success, in early 2001, things changed. Following 

Abramoff’s guidance, the Tribe hired Scanlon. And, to implement 

its grassroots strategies, the Tribe, at Abramoff and Scanlon’s direction, paid to or through conduits owned or controlled by 

Abramoff and Scanlon. As an example of how much Scanlon sought 

from the Choctaw, he had the Tribe pay him $4,500,000 for efforts 

related to a single program—a grandiose idea Scanlon called ‘‘Operation Orange.’’ During the relevant period, Abramoff manipulated 

the Tribe into funding, among other things, a much reported golfing trip to Scotland. The Tribe thought that its money, which it 
9 

paid to a non-profit on whose board Abramoff sat, would be used 

for anti-tax and other policy work. At the end of the day, having 

collected about $15,000,000 from the Choctaw during the relevant 

period, Scanlon secretly kicked back to Abramoff about 

$6,364,000—about 50 percent of his total profit from the Tribe. 

Specifically citing the work he had done for the Choctaw, 

Abramoff subsequently secured contracts for himself and Scanlon 

from the Louisiana Coushatta. Regrettably, of all the Tribes that 

hired Scanlon, the Louisiana Coushatta ended up paying Scanlon 

the most. Initially, the Tribe hired Scanlon to help with its compact 

renegotiations with the State of Louisiana. But, after having successfully done so, Scanlon dramatically expanded his scope of work, 

which ranged from squelching supposedly ubiquitous threats to the 

Tribal casino’s customer market share to supposedly getting the 

‘‘right’’ candidates elected to the Louisiana State Legislature. To its 

detriment, the Tribe trusted Abramoff and Scanlon’s expertise in 

Indian gaming and were captured by their lure of making the 

Coushatta ‘‘the Choctaw of Louisiana.’’ Accordingly, it deferred to 

Abramoff and Scanlon’s judgment when they recommended that it 

fund very expensive grassroots campaigns. Ultimately, having collected about $30,000,000 from the Louisiana Coushatta during the 

relevant period, Scanlon secretly kicked back to Abramoff about 

$11,450,000—about 50 percent of his total profit from the Tribe. 

This includes a payment of $1,000,000 that Abramoff and Scanlon 

manipulated the Tribe into paying to Abramoff’s private charity, 

the Capital Athletic Foundation (‘‘CAF’’). 

Abramoff and Scanlon’s efforts to sign on the Saginaw Chippewa 

and the Agua Caliente as clients are notable. With both Tribes, 

Abramoff and Scanlon insinuated themselves into Tribal Council 

elections to maximize their chance of getting hired afterwards. In 

particular, they provided, among other things, strategic advice and 

material support to some of the candidates. Those who ran in the 

Saginaw Chippewa election called themselves the ‘‘Slate of 8.’’ The 

weight of evidence obtained by the Committee indicates that, in 

both the Saginaw Chippewa and Agua Caliente cases, those candidates who were elected to the Council with Abramoff and Scanlon’s assistance ultimately supported Abramoff and Scanlon’s contract proposals because of, or in exchange for, the assistance that 

Abramoff and Scanlon provided them. 

Key to Abramoff and Scanlon’s success in getting contracts with 

the Saginaw Chippewa and the Agua Caliente was the assistance 

of non-Tribal Members Christopher Petras and Michael Chapman, 

respectively. In the course of the Tribe’s dealings with Abramoff 

and Scanlon, Abramoff and Scanlon apparently provided each 

things of value. Evidence indicates that, over the course of 

Abramoff and Scanlon’s representation of the Saginaw Chippewa, 

Abramoff and Scanlon provided Petras with a great deal of attention during his frequent trips to Washington, D.C. (which, with private cars, tickets to sporting events and concerts, meals at posh 

restaurants, and meetings with prominent personalities, one 

former Abramoff associate described as a ‘‘dog and pony show’’) and 

some favors. Likewise, for the services that Chapman provided 

Abramoff and Scanlon over the course of the Agua Caliente retainer, Chapman received about $271,482. 
10 

From June 2002 through October 2003, the Saginaw Chippewa 

paid Scanlon about $3,500,000 for among other things ‘‘a strategy 

for making [the Tribe] the most dominant political entity in Michigan’’ that Scanlon called ‘‘Operation Redwing.’’ Of those proceeds, 

Scanlon secretly kicked back to Abramoff about $540,000—about 50 

percent of his total profit from the Tribe during this period. Similarly, from the Agua Caliente, Scanlon collected about $7,200,000 

from the Agua Caliente during the relevant period and appears to 

have secretly split about 50 percent of his total profit from that 

Tribe with Abramoff. 

How Abramoff and Scanlon had the Tigua hire them was particularly aggressive. In late 2001 through early 2002, (largely with the 

assistance of Ralph Reed) Abramoff and Scanlon successfully 

helped Texas authorities shut the Tigua’s casino down, as violating 

federal law. Despite the fact that the Louisiana Coushatta’s casino 

was in southwest Louisiana and the Tigua’s was in El Paso, Texas, 

Abramoff and Scanlon succeeded in persuading the Louisiana 

Coushatta that the Tigua posed a threat to its customer market 

share. So, the Louisiana Coushatta largely funded the grassroots 

effort to help close their casino. 

Having succeeded in helping shut down the Tribe’s casino, 

Abramoff and Scanlon then pitched their services to help reopen it. 

In pitching their services, Abramoff offered to represent the Tribe 

on a pro bono basis if it hired Scanlon for millions of dollars to provide grassroots support for his federal lobbying effort. He did so 

without telling the Tribe of his financial arrangement with Scanlon. 

After they signed the Tigua on as a client, Abramoff and Scanlon 

promised to, among other things, insert language allowing the 

Tribe to re-open its casino. Cumulatively, Scanlon called this plan 

‘‘Operation Open Doors.’’ Abramoff and Scanlon were ultimately 

unsuccessful, despite that they collected (and split between themselves) millions of dollars from the Tribe. Having collected about 

$4,200,000 from the Tigua during the relevant period, Scanlon secretly kicked back to Abramoff about $1,850,000—about 50 percent 

of his total profit from the Tribe. 

The Pueblo of Sandia hired Abramoff and Scanlon to help them 

with the lobbying aspects of a legal dispute related to Sandia 

Mountain, revered by the Tribe as sacred. Abramoff pitched his 

and Scanlon’s services as a ‘‘package deal,’’ actually insisting that 

the Tribe hire Scanlon as its public relations specialist. He even offered to reduce Greenberg Traurig’s retainer in contemplation of 

the Tribe’s hiring Scanlon, but insisted that Scanlon’s asking price 

could not be reduced further because his ‘‘10 percent profit margin’’ 

was ‘‘locked in.’’ After having paid Scanlon about $2,750,000 for 

grassroots work intended to support Abramoff’s federal lobbying effort, the Tribe became dissatisfied with the quality of Scanlon’s effort and ceased the representation. From those proceeds that Scanlon collected from the Pueblo Sandia during the relevant period, on 

information and belief, Scanlon secretly split about 50 percent of 

his total profit from the Tribe, with Abramoff. 

A couple of ‘‘gimme five’’ entities—entities owned or controlled by 

Abramoff or Scanlon that they used in their kickback scheme—are 

especially worth noting. One is an ‘‘international think tank’’ called 
11 

the American International Center (‘‘AIC’’). With two of Scanlon’s 

beach buddies sitting on its board, AIC’s purpose was actually to 

collect fees associated with activities conducted by others and, in 

some cases, divert those fees to entities owned or controlled by 

Scanlon or Abramoff. In other words, AIC was a sham. From 2001 

through 2003, the Choctaw and the Coushatta paid AIC about 

$6,308,854. While much of this money went to vendors such as 

Reed as intended (to conduct grassroots activities supportive of several Tribes’ gaming interests), millions did not. 

CAF, Abramoff’s private charity, is a particularly interesting 

‘‘gimme five’’ entity. In total, four of the Tribes paid CAF about 

$2,075,000. The totals for each Tribe is as follows: the Louisiana 

Coushatta, $1,000,000; the Choctaw, $1,000,000; the Saginaw Chippewa, $25,000; and the Alabama Coushatta, $50,000, which was 

not even a client. Evidence obtained by the Committee indicates 

that Abramoff treated CAF as his own personal slush fund, using 

CAF for a number of activities wholly unrelated to its charitable 

mission and tax-exempt status. Such activities included, for example, evading taxes, financing lobbying activities and purchasing 

military-related equipment. 

In 2001, the single largest contributor to CAF was the Louisiana 

Coushatta, supposedly giving CAF $1,000,000. However, the Tribe 

never intended to make a charitable contribution to CAF. While it 

thought that its money was going to fund its grassroots activities, 

the money simply padded the coffers of CAF for Abramoff’s discretionary use. 

In 2002, Abramoff and Scanlon manipulated the Choctaw into 

sending directly and indirectly $2,000,000 to CAF, making the 

Choctaw CAF’s largest donor that year. However, the Choctaw 

never intended to contribute to CAF. The Tribe thought that its 

payments to CAF were going to pass through to grassroots organizations working to oppose the expansion of gaming in the Tribe’s 

customer market. The Tribe’s money was not used for its intended 

purpose. 

As described above, Abramoff also deceived the Saginaw Chippewa into paying $25,000 to CAF that year. While the Tribe was 

led to believe that CAF ‘‘create[d] programs that teach leadership 

skills to disadvantaged youth in the D.C.-area in an effort to keep 

them off the streets and enhance their educational opportunities’’ 

and was a charity important to an important Member of Congress, 

the Tribe’s ‘‘donation’’ was used to partially fund a widely publicized golf trip to Scotland for Congressman Bob Ney and others. 

For 2003, CAF’s tax records do not list any Tribe as a donor. 

However, substantial evidence indicates that a $47,891 contribution to CAF listed as having been made by Abramoff’s corporate 

alter ego, Kaygold, and a $950,000 contribution from a Scanloncontrolled entity called Atlantic Research & Analysis (‘‘ARA’’) were 

actually funds from some of the Tribes, paid as a result of 

Abramoff and Scanlon’s manipulation. 

Among the third parties that Abramoff had some of his Tribal 

clients pay money was an environmental organization called the 

Council of Republicans for Environmental Advocacy (‘‘CREA’’). 

From 2001 through 2003, Abramoff managed to have these Tribes 

‘‘contribute’’ at least $250,000 to CREA, sometimes under false pre-
12 

tenses. The Coushatta, for example, paid CREA $25,000 to help the 

Department of the Interior with a ‘‘national park study,’’ which was 

apparently never conducted. Likewise, the Saginaw Chippewa 

made a $25,000 donation, having been told that former Interior 

Secretary Gale Norton was ‘‘involved’’ with and supported CREA 

and that supporting such ‘‘a project’’ that the Secretary was involved with would ‘‘look good’’ for the Tribe. In both cases, the 

Tribes were deceived. 

In any event, with the possible exception of the Choctaw, the 

Committee has found no evidence that those Tribes that gave to 

CREA did so because of any interest in CREA’s mission. In fact, 

Abramoff apparently had his clients contribute to CREA, described 

by CREA president Italia Federici as a ‘‘mom and pop’’ operation, 

because he believed that Federici would help him possibly influence 

tribal issues pending at the Department of the Interior. Ample evidence indicates that she repeatedly told Abramoff that she would 

talk with a particular senior Interior official to help ensure that the 

concerns of Abramoff’s clients were addressed. However, what she, 

or her working contact at Interior, former Deputy Secretary J. Steven Griles, actually did at Interior for the benefit of Abramoff’s 

Tribal clients, remains unclear. 
(13) 

1Letter from Chief Phillip Martin, Mississippi Band of Choctaw Indians, to Chairman Ben 

Nighthorse Campbell, and Ranking Majority Member John McCain, Committee on Indian Affairs (no Bates number) (August 9, 2004). 

PART ONE—FACT SUMMARY BY TRIBE 

CHAPTER I 

MISSISSIPPI BAND OF CHOCTAW INDIANS 

Lets [sic] do this, lets [sic] plan a swing to the big three 

[Choctaw, Coushatta, and Saginaw] as soon as is convenient to go over existing operations and hit them for new 

ones—Ill [sic] start working gup [sic] the reports (choctas 

[sic] is almost done) and the new proposals. We will take 

two maybe three days and take no prisoners—we are coming home with a bag of cash. 

Email from Michael Scanlon to Jack Abramoff, May 31, 2002. 

You know, it’s the lack of care for people and just the personal greed. And who knows? I don’t understand that point 

of view. 

Nell Rogers on Jack Abramoff and Michael Scanlon, April 29, 2005. 

A. INTRODUCTION

When the Committee first began this investigation in February 

2004, many of Jack Abramoff’s and Michael Scanlon’s long-time 

friends and clients came to their defense. Among them were Chief 

Phillip Martin and the Mississippi Band of Choctaw Indians 

(‘‘Choctaw’’). Six months into the Committee’s investigation, however, Chief Martin wrote to Senators John McCain and Ben 

Nighthorse Campbell, who were leading the investigation: 

In light of information we have recently obtained from various sources, it now appears that our Tribe may in fact 

have been the victim of serious wrongdoing by Abramoff 

and Scanlon. Thus, despite my prior concerns, I appreciate 

your Committee’s work on this matter.1

Indeed, of all the Tribes that Abramoff and Scanlon betrayed, 

their misdeeds were perhaps most painful for the Choctaw, which 

Abramoff had represented for nearly a decade. Nell Rogers, the 

Tribal planner who had dealt most closely with Abramoff and Scanlon, gave an impassioned, tearful account during her interview 

with Committee staff: 

STAFF: If Jack Abramoff and Michael Scanlon were sitting 

in this room today and you had a chance to look them in 

the eye, what would you tell them? 
14 

2 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mississippi (April 27–29, 2005). During his interview, Chief Phillip Martin expressed similar feelings of betrayal caused by Abramoff and Scanlon. Interview of Phillip Martin, Chief, Mississippi 

Band of Choctaw Indians, in Washington, D.C. (May 17, 2005). 3 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. at 

52 (June 22, 2005) (prepared statement of Phillip Martin, Chief, Mississippi Band of Choctaw 

Indians). 4 Id. 

5 Id. 

6 Id. 

7 Id. 

8 Id. 

9 Id. 

ROGERS: I would tell them that—there are a lot of things 

that I could say about being angry or bitter. But I think 

the worst is that they betrayed the tribe. They betrayed 

the Chief who had a great deal of confidence in them. They 

betrayed me ... But I think at the end of the day, it’s the 

betrayal that’s worse. And I think of the people whose 

lives they’ve destroyed. I think of all those young kids who 

worked at Greenberg and Preston Gates with them, who, 

fairly or unfairly, are going to have to bear that burden. 

And I think about the other tribes. I mean, you know, let’s 

face it. The tribes they dealt with were not the poorest of 

the poor tribes. Of all those tribes, Choctaw, though, probably has the greatest needs, the biggest tribe, was the 

poorest tribe. And they used the success they had with 

Choctaw to gain entree with the other tribes. 

You know, not only did they betray Choctaw but they betrayed the tribe’s good name and Chief’s reputation. And, 

you know, Phillip Martin has spent his life working for not 

only this tribe but for Indian people. And for him to have 

to be smeared like this is intolerable. I’ve spent my whole 

life working. You know, it’s the lack—it’s the lack of care 

for people and just the personal greed. And who knows? I 

don’t understand that point of view.2

B. BACKGROUND ON THE TRIBE

The Mississippi Band of Choctaw Indians is a federally recognized Indian tribe of nearly 10,000 members, most of whom reside 

on eight reservation communities located on trust lands scattered 

over a five-county area in East-Central Mississippi.3 The Tribal 

capital is in Choctaw, Mississippi.4 The majority of Tribal members 

are full-blood, Choctaw language speaking.5

The Choctaw Indians are the descendants of those Choctaw people who resisted efforts by the Federal Government around 1830– 

1840 to remove them to Oklahoma, then known as Indian Territory.6 Although the Choctaw chose to stay in Mississippi, they did 

not receive their initial reservation lands until 1944 and it was not 

until the following year that they were federally recognized.7

The Tribe has developed a stable governmental structure providing a full panoply of governmental services.8 These include a 

school system, police and fire protection services, courts, hospitals, 

clinics, and housing.9
15 

10 Choctaw Chronology (visited March 21, 2006) <http://www.choctaw.org/history/chronology.htm> (providing a detailed chronology of Choctaw history). 11 Id. 12 Id. 13 Id. 14 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. 

at 52 (June 22, 2005) (prepared statement of Phillip Martin, Chief, Mississippi Band of Choctaw 

Indians); Economic Development History How We Got Here (visited March 21, 2006) <http:// 

www.choctaw.org/economics/triballbusinessloverview.htm> (providing an overview of the 

Choctaw’s economic development). 15 Economic Development History How We Got Here (visited March 21, 2006) <http:// 

www.choctaw.org/economics/triballbusinessloverview.htm> (providing an overview of the 

Choctaw’s economic development). 16 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mississippi (April 27–29, 2005). 17 Interview of Phillip Martin, Chief, Mississippi Band of Choctaw Indians, in Washington, 

D.C. (May 17, 2005); Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, 

in Choctaw, Mississippi (April 27–29, 2005). 18 Id. 19 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. 

at 12 (June 22, 2005) (testimony of Nell Rogers, planner, Mississippi Band of Choctaw Indians). 20 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mississippi (April 27–29, 2005). 21 Id. 

For many years the Choctaw struggled to survive. By 1964, ninety percent of the Tribe’s population lived in poverty.10 The Choctaw’s situation improved when Chief Phillip Martin began a campaign to bring economic development to the reservation.11 The 

Choctaw are unusual in their development because they first 

gained economic success through their non-gaming business ventures, before opening the Silver Star Hotel and Casino in 1994.12

In 2000, the Tribe announced an expansion to include another casino, the Golden Moon, and a shopping complex.13

The Tribe now is the third largest employer in Mississippi, employing nearly 9,200 people in 25 different enterprises including 

greeting card manufacturing, wiring harness production for the 

automotive industry, a nursing home, and a world renowned golf 

course, the Dancing Rabbit.14 The annual Tribal payroll is over 

$1,237,000 and covers many non-member employees.15

C. BACKGROUND ON ABRAMOFF AND THE TRIBE’S RELATIONSHIP— 

BUILDING TRUST AND CONFIDENCE

The Choctaw have long enjoyed a government-to-government relationship with the Federal Government, particularly with the 

United States Congress.16 In the beginning, Chief Martin of the 

Choctaw preferred to lobby Congress himself.17

That changed in 1994. Either through retirement or defeat, many 

of the Members of Congress who provided the institutional memory 

on American Indian issues were gone.18 At the same time, the 

opening of the Choctaw’s Silver Star Hotel and Casino in 1994 gave 

rise to an array of new issues and concerns that required the Tribe 

to track and address them at the federal level.19

Moreover, tribes apparently began to see a slew of proposed legislation they believed were inimical to their interests.20 One of the 

first major initiatives came from the U.S. House of Representatives, in a bill seeking to apply the unrelated business income tax 

(‘‘UBIT’’) to tribal enterprises.21 Confronted with this legislation 
16 

22 Id. 23 Id. Rogers’ friend had actually attended a fundraiser that Abramoff’s father had thrown in 

support of Abramoff’s bid for the Chair of the College Republican National Committee. Id. 24 Id. 25 Id. 26 Id. 27 Id. 28 Id. 29 Id. 30 Id. 31 Id. 32 Id. 33 Id. 34See Jim Vandehei, Rain Dance, Mississippi’s Choctaw Find an Unlikely Ally In a GOP Stal- wart, The Wall Street Journal, July 3, 2000. 35 ATR opposes all tax increases as a matter of principle. (visited May 21, 2006) <http:// 

www.atr.org/home/about/index.html>. 

and a sea of unknown faces in Congress, the Choctaw decided to 

hire outside lobbyists.22

Coincidentally, around the same time, Nell Rogers, the Tribe’s planner responsible for legislative affairs, was speaking with a 

friend in California who knew Abramoff’s father.23 Aware that 

Abramoff had once been a Republican activist, Rogers’ friend suggested she speak with Abramoff.24

Through further due diligence, Chief Martin and Rogers learned that Abramoff worked for Preston Gates Ellis & Rouvelas Meeds 

(‘‘Preston Gates’’), and that Meeds was former Congressman Lloyd 

Meeds from Washington State.25 The Choctaw had known and respected Meeds during his tenure in Congress, as a member of at 

least one House committee that had jurisdiction over Indian 

issues.26 The Tribe decided to contact Preston Gates.27

After a brief telephone call, Meeds and Abramoff traveled to the 

Choctaw reservation.28 There they made a presentation about their 

firm’s capabilities and connections, and discussed the Tribe’s legislative concerns.29 Rogers was extremely fascinated by how 

Abramoff proposed mobilizing other groups to assist the Choctaw 

in its legislative battle: ‘‘I came away thinking this is really different and unusual. It was. It was an unusual approach that you 

would engage other groups to help you in a campaign to say ‘these 

are good guys.’ ’’ 30

After the meeting, Chief Martin and Rogers concluded that the 

Choctaw needed to educate the new members of Congress about Indian Country and the issues it faced.31 They therefore hired Preston Gates.32 The issues on which Preston Gates would lobby were 

not limited to the UBIT. At the time, Rogers recalled, there seemed 

to be daily issues emerging that adversely affected tribes, a ‘‘sea 

change of proposals’’ that were ‘‘hostile to the tribes.’’ 33

To help the Choctaw in its campaign to educate the new Members of Congress, Abramoff mobilized his friends and colleagues at 

various think tanks and grassroots organizations. The Preston 

Gates team recast the issue from an Indian issue into a tax issue.34

Abramoff then enlisted the aid of his long term friend and anti-tax 

activist Grover Norquist and his organization Americans for Tax 

Reform (‘‘ATR’’), which, according to its website, ‘‘opposes all tax increases as a matter of principle’’ and serves as ‘‘a national clearinghouse for the grassroots taxpayers movement.’’ 35

According to one document in the Committee’s possession, 

Abramoff described ATR as ‘‘an effective conduit of support for 
17 

36February 22, 1996, List of Suggested Contributions, Republicans and Conservative Organizations (GTG–E000106655–57) 37 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mississippi (April 27–29, 2005). 38 Id. This apparently was not the only time that Abramoff and his clients had sought to hire 

Norquist and ATR. During the UBIT battle for the Choctaw, Abramoff discussed with a colleague the possibility of Brown Forman, a company in the wine and spirits business, retaining 

Norquist as a lobbyist: 

I spoke this evening with Grover. He said that, if they want the taxpayer movement, including him, involved on this issue and anything else which will come up over the course of the 

year or so, they need to become a major player with ATR. He recommended that they make 

a $50,000 contribution to ATR. It seems that, on another ‘‘sin tax’’ matter, he is getting a similarly large contribution to get involved. ... He would prefer donations to ATR. 

Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to Mark Ruge, Preston 

Gates Ellis & Rouvelas Meeds (GTG–E000106493) (October 22, 1995). Abramoff said that keeping the arrangement with Norquist and ATR secret was important. After all, Abramoff wrote, 

‘‘[w]e do not want opponents to think that we are trying to buy the tax payer [sic] movement.’’ 

Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to Pamela Garvie, Preston 

Gates Ellis & Rouvelas Meeds (Greenberg Traurig production) (GTG–E000106492) (October 24, 

1995). 39 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mississippi (April 27–29, 2005). 40 Id. 41 Id. 42 Id. 43 Id. 44 Id. 45 Id. 

other groups which have provided assistance to Indian gaming’s efforts to fight the tax proposal.’’ 36 There were a number of anti-tax 

grassroots groups in various states, and ‘‘it was ATR’s job to make 

contacts with those groups, to assist them in making contacts with 

members of the Ways and Means Committee or other committee 

members.’’ 37 The Choctaw apparently paid ATR a total of $60,000 

in 1996 to oppose the UBIT tax.38

Abramoff and his colleagues at Preston Gates eventually succeeded in their efforts, and the UBIT tax failed in the Senate.39

Three years later, however, the Choctaw were still battling congressional attempts to tax its Tribal revenue. In so doing, in September 1999, the Choctaw paid ATR another $25,000.40 Rogers believed that the payment was in furtherance of ATR’s opposition to 

a sales tax issue at the time.41 According to Rogers: ‘‘Well, we did 

not support the general work of ATR unless we had a tax issue. 

That’s what I mean by saying general work. We would have expected them to take a position opposing—we did expect them to 

take a position opposing the sales tax.’’ 42

On this issue, Abramoff enlisted other allies. The Choctaw paid 

Americans for Economic Growth (‘‘AEG’’) $45,000 in 1999 for its 

work opposing the sales tax.43 The payments were intended for 

grassroots work and the anti-tax program in 1999.44 Rogers understood that AEG would be ‘‘contacting their supporters, contacting 

members of Congress’’ and ‘‘staffers that they might have known 

to talk to them about the tribe—this was after they had been to 

visit [the Choctaw reservation]—to let them know what the tribe 

was about. That was our understanding of what they would do.’’ 45

The outside groups were not limited to grassroots organizations. 

Abramoff put together visits to the Choctaw reservation for reporters and public policy groups, with the goal of demonstrating the 

Tribe’s success in an environment unfettered by unnecessary gov-
18 

46 Id. 47 Id. 48 Id. 49 Id. According to one news article, Bandow resigned from the Cato Institute, after admitting 

he received money from Abramoff to write between 12 and 24 articles in the mid ’90s addressing 

topics important to Abramoff’s clients. Eamon Javers, Op-Eds for Sale, BusinessWeek Online, 

December 16, 2005. 50 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mississippi (April 27–29, 2005). 51 Id. 52 Id. 53 Id. 54 Id. 55 Id. 56 Email from Ralph Reed, Century Strategies, to Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds (GTG–E000079102) (November 12, 1998). 

ernment regulation.46 One group that visited the reservation was 

the National Center for Public Policy Research (‘‘NCPPR’’), which 

was headed by long-time Abramoff friend Amy Ridenour. Ridenour 

visited the Tribe, ‘‘wrote some articles about the tribe, the tribe’s 

economic development, cultural preservation of the tribal community. And we had made a contribution—had said that we would 

make a contribution to the National Center.’’ 47 The Tribe paid 

NCPPR $5,000 in 1999.48 Others who attended were representatives from think tanks including Doug Bandow from the Cato Institute.49

The Choctaw’s campaign against the sales tax was ultimately 

successful. 

The UBIT and sales tax issues were only two among the many 

issues on which Abramoff and his team lobbied for the Choctaw. As 

time passed, and Abramoff and his team repeatedly succeeded in 

their lobbying efforts for the Choctaw, the Tribe developed a great 

deal of trust and confidence in Abramoff and his capabilities.50 Another Abramoff trait that engendered trust with the Choctaw was 

that he ‘‘always presented himself as a deeply religious person ... 

his conversations were spiked with references to a good cause or 

working for a good cause. And he talked quite a bit about his religious beliefs and what he could and what he couldn’t do.’’ 51

It was during the UBIT battle that Abramoff assumed primary 

responsibility for the Choctaw account.52 In fact, he remained ultimately responsible for the account throughout his tenure at Preston Gates and, later, at Greenberg Traurig.53

D. SUBSTANTIAL FEES AND CONDUITS—SETTING THE STAGE FOR

SCANLON

As the Tribe’s trust and confidence in Abramoff grew, Rogers 

would often discuss with Abramoff issues affecting the Tribe, both 

at a local and national level.54 In 1999, Rogers and Abramoff discussed various legislative proposals in Mississippi and elsewhere 

that threatened the market share of the Choctaw’s casino operations, and which the Tribe wanted to somehow counter.55 It just 

so happened that a few months earlier, Ralph Reed, the former executive director of the Christian Coalition and one of Abramoff’s 

long-time friends, had reached out to Abramoff: ‘‘Hey, now that I’m 

done with electoral politics, I need to start humping in corporate 

accounts! I’m counting on you to help me with some contacts.’’ 56

Abramoff saw an opportunity: he suggested a grassroots effort and 
19 

57 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mississippi (April 27–29, 2005). 58The Committee has seen no evidence that the Choctaw undertook or authorized any work 

by Abramoff or Scanlon, or anyone else, to oppose gaming in other Southern states, such as Louisiana and Texas. 59 Id. 60 Id. 61 Email from Ralph Reed, Century Strategies, to Shawn Vasell, Preston Gates Ellis & 

Rouvelas Meeds (GTG–E000111956) (March 26, 1999). 62 Ralph Reed document production (Bates number 5908–09) (March 26, 1999) (letter from 

Ralph Reed to Jack Abramoff). 63 Id. 64 Id. 65 Id. 66 Id. 67 Id. 

recommended the Choctaw hire Reed to orchestrate an anti-gaming 

effort.57

The Tribe agreed to hire Reed to mobilize grassroots opposition 

to various legislative proposals throughout the Gulf Coast 58 that 

would have increased gaming, thereby diminishing the Choctaw casino’s market share.59 No one from the Choctaw had any direct 

contact with Reed; rather, Abramoff served as the liaison with 

Reed and his firm, which eventually became a subcontractor to 

Preston Gates.60

In March 1999, Abramoff and his associate, Shawn Vasell, spoke 

with Reed about the Choctaw’s grassroots needs.61 According to a 

draft engagement letter from Reed to Abramoff, Reed was hired to 

defeat a bill that had passed the Alabama House of Representatives ‘‘authorizing dog tracks in the state to install video poker and 

other casino-style games on their sites.’’ 62 Reed promised to ‘‘build 

a strong grassroots network across the state against the extension 

of video poker and [REDACTION].’’ 63 He claimed that no firm had 

better relationships than his with the grassroots conservatives in 

Alabama, including the Alabama Christian Coalition, the Alabama 

Family Alliance, the Alabama Eagle Forum, the Christian Family 

Association, and ‘‘leading evangelical pastors such as Frank Barker 

of Briarwood Presbyterian Church in Birmingham.’’ 64 Reed boasted 

that ‘‘Century Strategies has on file over 3,000 pastors and 90,000 

religious conservative households in Alabama that can be accessed 

in this effort.’’ 65

Reed promised to leverage his contacts for the Tribe: 

Working closely with your existing team at Preston Gates, 

we can play on [sic] operational role in building a strong 

anti-video poker grassroots structure that will leverage the 

considerable contacts and reputation of our principals 

within Alabama, the conservative faith community, and 

state elected officials.66

Reed proposed a $20,000 monthly retainer for his services, and 

ended his letter by writing, ‘‘We look forward to bringing about the 

desired results for you.’’ 67

After receiving Reed’s proposed engagement agreement, 

Abramoff responded, ‘‘Ralph, I spoke with Nell this evening. She 

wants much more specifics. They are not scared of the number, but 
20 

68 Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to Ralph Reed, Century Strategies (GTG–E000111956) (March 29, 1999). 69 Email between Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, and Ralph Reed, 

Century Strategies (GTG–E000111992) (April 4, 1999). 70 Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to Ralph Reed, Century Strategies (Bates number 7029) (April 6, 1999) (Ralph Reed document production). 71 Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to Ralph Reed, Century Strategies (GTG–E000111977) (April 9, 1999). 72 Id. 73 Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to Ralph Reed, Century Strategies (GTG–E000111974) (April 12, 1999). 74 Email from Ralph Reed, Century Strategies, to Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds (GTG–E000112006) (April 21, 1999). 75 Id. 76 Id. 77 Email from Ralph Reed, Century Strategies, to Jack Abramoff, Preston Gates Ellis & 

Rouvelas Meeds (GTG–E000112006) (April 22, 1999). 

want to know precisely what you are planning to do for this 

amount.’’ 68

When Reed told Abramoff he was devoting half his staff to the 

project for two weeks, but needed the green light to begin, 

Abramoff directed: 

Please page me with a page of no more than 90 words ... 

informing me of your completion of the budget and giving 

me a total budget figure with category breakdowns. Once 

I get this, I will call Nell at Choctaw and get it approved.69

On April 6, 1999, Abramoff informed Reed that he ‘‘spoke with 

our managing partner [at Preston Gates] and he has approved the 

subcontractor arrangement’’ and instructed Reed to ‘‘get me invoices as soon as possible so I can get Choctaw to get us checks 

asap.’’ 70

When Abramoff believed he could not get money quickly enough 

to Reed, Abramoff suggested that the Choctaw pay Reed directly: 

‘‘Ralph, I am not sure that I can get this wire moving fast enough 

today. Give me your wire info and I’ll do what I can.’’ 71 Abramoff 

then asked, ‘‘Any chance that a wire from Choctaw directly would 

be OK?’’ 72 Reed’s response is unknown; however, the Committee 

has seen no evidence that the Choctaw paid Reed or his firms directly. 

By mid-April, things were moving. In an e-mail entitled ‘‘Disbursement on behalf of Choctaw Indians,’’ Abramoff assured Reed 

that the money was on its way.73 Using the Choctaw’s money, Reed 

paid for grassroots activities including, telemarketing (patchthrough, tape-recorded messages and call-to-action phone calls), 

targeted mail, legislative counsel and local management, rallies, 

petitions, ‘‘voter contact, television and radio production, the remainder of phones, the statewide fly-around, the pastor’s and activist rally, the church bulletin inserts, and other items.’’ 74

Reed also claimed that he was leveraging his contacts within the 

Christian community for the Choctaw’s benefit. Reed reported to 

Abramoff that there would be ‘‘a saturation statewide radio buy 

with a new ad by Jim Dobson that he will record tomorrow.’’ 75

Reed assured Abramoff, ‘‘We are opening the bomb bay doors and 

holding nothing back. If victory is possible, we will achieve it,’’ 76

and, one day later, again promised, ‘‘All systems are go on our end 

and nothing is being held back.’’ 77
21 

78 Email from [REDACTED] to Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds (GTG– 

E00018933) (May 10, 1999). 79 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mis- sissippi (April 27–29, 2005). 80See Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to himself (GTG– 

E000079255) (September 24, 1999). 81 Email from Grover Norquist, Americans for Tax Reform, to Jack Abramoff, Preston Gates 

Ellis & Rouvelas Meeds (GTG–E000114915) (May 20, 1999). 82 Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to himself (GTG– 

E000079255) (September 24, 1999). 83 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mis- sissippi (April 27–29, 2005). 84 Id. 85Michael Kranish, Antitax Activist Says He got $1.5M from Tribes, The Boston Globe, May 

13, 2005. 86 Id. 87 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mis- sissippi (April 27–29, 2005). 88See Email from Ralph Reed, Century Strategies, to Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds (GTG–E000020203) (January 27, 2000) (listing the names of the heads of the 

groups they contemplated using as conduits). 89 Abramoff’s designation of groups as a c4 or c3 group apparently refers to their tax exempt 

status under either subsection (c)(3) or (c)(4) of section 501 of the Internal Revenue Code. 

By May 10, 1999, the Choctaw had paid Reed $1,300,000 through 

Preston Gates, with another $50,000 outstanding.78 For reasons 

unclear to the Committee, in late 1999 the Tribe discontinued paying Reed through Preston Gates. Rogers recalled that there came 

a time when either Reed or Preston Gates (or both) became uneasy 

about money being passed through Preston Gates to Reed.79

Abramoff thus searched for another conduit. 

Abramoff turned to his long-time friend Norquist to have his 

group ATR serve as a conduit for the Choctaw money.80 Earlier, on 

May 20, 1999, Norquist had asked Abramoff, ‘‘What is the status 

of the Choctaw stuff. I have a $75K hole in my budget from last 

year. ouch [sic].’’ 81 Thus, in the fall of 1999, Abramoff reminded 

himself to ‘‘call Ralph re Grover doing pass through.’’ 82 When 

Abramoff suggested the Choctaw start using ATR as a conduit, the 

Tribe agreed.83

In late 1999, the Choctaw paid ATR $325,000.84 In a 2005 interview with The Boston Globe, Norquist said that ATR had sent 

$300,000 of that $325,000 to Citizens Against Legalized Lottery 

(‘‘CALL’’).85 Norquist explained that he sent the money to CALL 

because the Tribe wanted to block gambling competition in Alabama.86

Out of the Choctaw’s $325,000, ATR apparently kept $25,000 for 

its services. According to Rogers, Norquist demanded that he receive a management fee for letting ATR be used as a conduit: 

But I remember when we discussed needing a vehicle for 

doing the pass-through to Century Strategies that Jack 

had told me that Grover would want a management fee. 

And we agreed to that, frankly didn’t know any other way 

to do it at that time.87

On a similar project in early 2000, Reed and Abramoff discussed 

using four groups instead of one as conduits to pay Reed: NCPPR, 

ATR, Toward Tradition and one unidentified group.88 Abramoff 

later advised Reed that ‘‘Rabbi Lapin [head of Toward Tradition] 

does not have a c4’’ 89 and asked Reed for ‘‘the name of the c4 you 

want to use (include address) and we’ll divide it among the three 
22 

90 Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to Ralph Reed, Century Strategies (GTG–E000020287) (January 28, 2000). 91 Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to Ralph Reed, Century Strategies (Bates number 7096) (February 2, 2000) (Ralph Reed document production). 92 Id. 93 Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to Ralph Reed, Century Strategies (GTG–E000020517) (February 3, 2000). 94See Email from Ralph Reed, Century Strategies, to Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds (GTG–E000020467) (February 17, 2000); see also Michael Kranish, Antitax Activist Says He got $1.5M from Tribes, The Boston Globe, May 13, 2005. 95 Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to Ralph Reed, Century Strategies (GTG–E000020508) (February 7, 2000). 96See Email between Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, and Ralph Reed, 

Century Strategies (Bates number 7096) (February 2, 2000) (Ralph Reed document production). 97 Id. 98 Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to Ralph Reed, Century Strategies (GTG–E000020467) (February 17, 2000). 99 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mis- sissippi (April 27–29, 2005). 100 Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to himself (GTG– 

E000078903) (February 22, 2000). 101 Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to Nell Rogers, Mis- sissippi Band of Choctaw Indians (GTG–E000110996) (March 2, 2000). 102 Email between Susan Ralston, Preston Gates Ellis & Rouvelas Meeds, and Jack Abramoff, 

Preston Gates Ellis & Rouvelas Meeds (GTG–E000110996) (March 3, 2000). 103 Id. 104 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mississippi (April 27–29, 2005). 

groups.’’ 90 Within days, Abramoff advised Reed that Amy 

Ridenour, president of NCPPR, ‘‘does not have a c4, only a c3, so 

we are back to ATR only.’’ 91 Abramoff asked Reed, ‘‘Let me know 

if it will work just to do this through ATR until we can find another group.’’ 92

Though Reed did not respond, on February 2, 2000, Abramoff informed Reed, ‘‘We’ll have $300K for Monday and more shortly 

thereafter.’’ 93 This project apparently was centered on opposing a 

video poker initiative.94 The Choctaw made the first of three 

$300,000 payments to ATR on February 7, 2000. Abramoff warned 

Reed, however, that ‘‘I need to give Grover something for helping, 

so the first transfer will be a bit lighter.’’ 95

During this time, Abramoff advised Reed that the Choctaw might 

be limited in the amount of money it could devote to his activities.96 In response, Reed assured Abramoff that he was also seeking money from ‘‘national anti-gambling groups, Christian CEOs, 

and national pro-family groups.’’ 97

The Tribe was nevertheless able to continue funding Reed’s efforts. On February 17, 2000, Abramoff advised Reed that ‘‘ATR will 

be sending a second $300K today.’’ 98 This money, too, came from 

the Choctaw.99 Norquist kept another $25,000 from the second 

transfer, which apparently surprised Abramoff.100

On March 2, 2000, Abramoff told Rogers he needed ‘‘more money 

asap’’ for Reed, and requested ‘‘a check for $300K for Americans for 

Tax Reform asap.’’ 101

Abramoff’s executive assistant Susan Ralston asked him, ‘‘Once 

ATR gets their check, should the entire $300K be sent to the Alabama Christian Coalition again?’’ 102

Abramoff replied, ‘‘Yes, but last time they sent $275K, so I want 

to make sure that before we send it to ATR I speak with Grover 

to confirm.’’ 103

Rogers did not speak with anyone at ATR about using ATR as 

a conduit.104 As far as Rogers knew, ATR was not involved and 
23 

105 Id. 106 Id. Interview of Phillip Martin, Chief, Mississippi Band of Choctaw Indians, in Washington, D.C. (May 17, 2005). 107 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Washington, D.C. (June 16, 2005). Interview of Phillip Martin, Chief, Mississippi Band of Choctaw Indians, 

in Washington, D.C. (May 17, 2005). 108 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mis- sissippi (April 27–29, 2005). 109 Id. 110 Id. 111 Id. 112 Id. 113 Id. 114 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Washington, D.C. (June 16, 2005). 115 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mis- sissippi (April 27–29, 2005). 116 Id. 117 Id. 

was not considering getting involved in any of the efforts the Choctaw ultimately paid Reed and others to oppose.105 Based on everything Rogers knew, ATR simply served as a conduit to disguise the 

source of the Choctaw money ultimately paid to grassroots groups 

and Reed.106 Rogers told Committee staff that she understood from 

Abramoff that ATR was willing to serve as a conduit, provided it 

received a fee.107

The Choctaw’s intent and understanding was that the money 

would pass through ATR and ultimately reach either Reed or a 

grassroots organization engaging in anti-gaming activities.108 It 

was never intended as a contribution to support ATR’s general 

anti-tax work.109 As far as Rogers was concerned, ATR was serving 

as a conduit on a project that had nothing to do with taxes and 

that was designed to oppose gaming.110

At some point, Rogers recalled that Norquist apparently began 

getting nervous about his role as a pass-through.111 Rogers thought 

that part of Norquist’s discomfort derived from press accounts reporting that ATR was one of the largest contributors to an organization that was fighting against the expansion of gaming.112

The question arises why the Choctaw paid money to Reed 

through various conduits, such as Preston Gates and ATR, rather 

than directly. Rogers told Committee staff, ‘‘I always assumed it’s 

because Ralph was more comfortable with that.’’ 113 Rogers understood from Abramoff that ‘‘Ralph Reed did not want to be paid directly by a tribe with gaming interests. It was our understanding 

that the structure was recommended by Jack Abramoff to accommodate Mr. Reed’s political concerns.’’ 114 Nevertheless, the work 

Reed and his company Century Strategies performed and for which 

they were paid through Preston Gates and ATR was on the Tribe’s 

behalf and for its benefit.115 The Tribe has no complaints about the 

quality of work Reed undertook on its behalf.116

Once ATR ceased serving as a conduit, Abramoff and Reed 

looked for other conduits for the Tribe to route money to Reed’s 

Century Strategies. After he left Preston Gates for Greenberg 

Traurig in 2001, Abramoff suggested the Tribe pay into entities 

owned or controlled by Michael Scanlon. In 2001, the Choctaw paid 

money into American International Center (‘‘AIC’’), which Abramoff 

described as vehicle for passing money through to Reed.117 By the 
24 

118 Id. 119 Id. 120 Id. 121 Id. 122 Id. 123 Id. 124 Id. Interview of Phillip Martin, Chief, Mississippi Band of Choctaw Indians, in Washington, D.C. (May 17, 2005). 125 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mis- sissippi (April 27–29, 2005). 126 Id. 127 Interview of Phillip Martin, Chief, Mississippi Band of Choctaw Indians, in Washington, D.C. (May 17, 2005). 128 Id. Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mississippi (April 27–29, 2005). 129 Id. 130 Id. 131 Interview of Phillip Martin, Chief, Mississippi Band of Choctaw Indians, in Washington, D.C. (May 17, 2005). 132 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mis- sissippi (April 27–29, 2005). 133 Id. 134 Id. 

Committee’s accounting, the Tribe paid AIC $1,485,656 in 2001, 

and $1,170,000 in 2002.118

E. ABRAMOFF BRINGS SCANLON TO THE CHOCTAW

In late 2001, the Choctaw were again looking for a grassroots 

specialist to help with certain state issues.119 Because of the 

Tribe’s and Rogers’ relationship with and trust in Abramoff, they 

asked him to recommend a grassroots specialist.120 This time, 

Abramoff did not turn to Reed; he instead introduced the Tribe to 

Scanlon.121

Abramoff and Scanlon traveled together to Mississippi to meet 

with the Choctaw.122 Abramoff introduced Scanlon as an independent consultant and an expert in grassroots operations.123

Abramoff claimed that Scanlon worked with the Christian community in grassroots campaigns, get out the vote campaigns and public relations campaigns.124 He also said Scanlon was Congressman 

Tom DeLay’s former staffer and later described him as ‘‘DeLay’s 

dirty tricks guy.’’ 125

Abramoff recommended that the Tribe hire Scanlon.126 Abramoff 

did not recommend anyone else.127 Trusting in and relying on 

Abramoff, the Tribe did so.128 From the outset, the Tribe understood that Scanlon would hire vendors to perform much of the 

work, and that Scanlon and his company Capitol Campaign Strategies would provide the strategy, hire and coordinate the vendors, 

and make the contacts.129 Although the Tribe expected Scanlon 

would take a reasonable fee for his work, it intended that most of 

its payments to Scanlon would be used for grassroots activities 

such as polling, surveying, media, and analysis.130 The Choctaw 

never intended that any of the money it paid Scanlon would go to 

Abramoff.131

The Tribe, and in particular Chief Martin, were always concerned about how high Scanlon’s fees were.132 Rogers sometimes 

asked Scanlon for a reduced budget.133 To justify Scanlon’s 

charges, both Abramoff and Scanlon explained that the cost of 

Scanlon’s work was consistent with the cost of the work Reed had 

done for the Choctaw.134 They also explained that it was ‘‘the cost 
25 

135 Id. 136 Id. 137 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign Strategies (Bates number 1131592) (October 16, 2001). 138 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mississippi (April 27–29, 2005). 139 Id. 140 Id. 141 Id. 142 Id. 143See Id. Unknown to the Choctaw was that these organizations were bogus. A full explanation about how Scanlon apparently used such bogus organizations as a part of his and 

Abramoff’s ‘‘gimme five’’ scheme is set forth below in Part 2, Chapter 1, ‘‘Capitol Campaign 

Strategies’’ section, Page 3, ‘‘CCS’ Use of Fictitious Grassroots Organizations.’’ 144 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mis- sissippi (April 27–29, 2005). 

of operating under the radar.’’ 135 In some instances, Scanlon did 

reduce his original, proposed budget, but not often.136

In addition to combating market threats, Scanlon promised to 

turn the Choctaw into a political powerhouse at the state level. 

And so, on October 16, 2001, Abramoff asked Scanlon, ‘‘By the way, 

even with this [project] done, don’t we have a large longer term 

project to do for them there? Remember we promised when we had 

dinner with the Chief that we would make them the most powerful 

folks in the state.’’ 137

Scanlon was referring to a grandiose plan he called Operation 

Orange. The Tribe did not agree to Operation Orange in its entirety, but instead directed Scanlon to pursue discreet parts of it 

aimed at threats to its casino’s market share.138 Contemporaneously, the Tribe saw evidence that Scanlon was carrying out 

parts of Operation Orange it had commissioned.139 The Tribe paid 

roughly $4,500,000 over two years for Scanlon’s efforts related to 

Operation Orange.140

Over the same two years, the Tribe also paid Scanlon another 

$1,000,000 for a separate project.141 Rogers understood that Scanlon and his companies were conducting polls, performing research, 

including opposition research, directly lobbying opinion makers, 

using third parties, and engaging in letter campaigns.142 Scanlon 

told the Choctaw he was mobilizing Christian grassroots groups, 

such as Global Christian Outreach Network and Concerned Citizens Against Gaming Expansion.143

In earlier grassroots efforts to protect its market share, the Tribe 

had grown accustomed to sending payments through conduits at 

Abramoff’s direction. Abramoff and Scanlon continued the practice 

of directing the Tribe to route money through conduits. Abramoff 

and Scanlon identified the following as pass-through vehicles for 

the Choctaw: American International Center, Capital Athletic 

Foundation, Scanlon-Gould Public Affairs, and, National Center for 

Public Policy Research.144 Common among all of them was that 

they were all entities over which Abramoff or Scanlon exercised 

considerable control. 

Ultimately, the Choctaw paid approximately $17,500,000 to companies owned or controlled by Scanlon. Unknown to the Choctaw, 

Scanlon secretly kicked back to Abramoff about $6,364,000—about 

50% of his total profit from the Tribe. Additionally, at Abramoff 

and Scanlon’s direction, the Tribe paid another $2,000,000 to non- 
26 

145Discussion and analysis of how Abramoff and Scanlon successfully perpetrated their 

‘‘gimme five’’ scheme on the Tribe, on an entity-by-entity basis, is contained in Part 2 of the 

this Report. 

profit organizations where Abramoff was a director.145 The pay- ments from the Tribe to Abramoff and Scanlon-related entities is 

as follows: 

PAYMENTS BY CHOCTAW TO ABRAMOFF/SCANLON ENTITIES

Payments by Tribe to Capitol Campaign Strategies (CCS) 

06/29/01 ................................................................................................... $200,000 

07/18/01 ................................................................................................... $43,650 

07/31/01 ................................................................................................... $50,000 

08/29/01 ................................................................................................... $1,500,000 

09/27/01 ................................................................................................... $1,000,000 

10/18/01 ................................................................................................... $207,000 

11/02/01 ................................................................................................... $1,670,000 

11/13/01 ................................................................................................... $2,350,000 

12/31/01 ................................................................................................... $250,000 

02/22/02 ................................................................................................... $1,600,000 

10/15/02 ................................................................................................... $800,000 

12/11/02 ................................................................................................... $330,000 

12/11/02 ................................................................................................... $600,000 

09/03/03 ................................................................................................... $48,333 

09/03/03 ................................................................................................... $48,334 

09/03/03 ................................................................................................... $48,333 

09/11/03 ................................................................................................... $500,000 

10/16/03 ................................................................................................... $450,000 

10/16/03 ................................................................................................... $300,000 

11/18/03 ................................................................................................... $300,000 

11/18/03 ................................................................................................... $150,000 

12/10/03 ................................................................................................... $300,000 

Total ................................................................................................. $12,745,650 

Payments by Tribe to Scanlon Gould Public Affairs (SGPA) 

04/29/02 ................................................................................................... $1,000,000 

10/15/02 ................................................................................................... $1,000,000 

Total ................................................................................................. $2,000,000 

Payments by Tribe to American International Center (AIC) 

02/27/01 ................................................................................................... $200,000 

04/09/01 ................................................................................................... $150,000 

05/02/01 ................................................................................................... $175,000 

05/11/01 ................................................................................................... $960,654 

02/22/02 ................................................................................................... $1,000,000 

12/11/02 ................................................................................................... $170,000 

Total ................................................................................................. $2,655,654 

Payments by Tribe to Capital Athletic Foundation (CAF) 

01/03/02 ................................................................................................... $500,000 

08/05/02 ................................................................................................... $500,000 

Total ................................................................................................. $1,000,000 

Payments by Tribe to National Center for Public Policy Research (NCPPR) 

10/15/02 ................................................................................................... $1,000,000 

Total ................................................................................................. $1,000,000 

Grand Total .............................................................................. $19,401,304 
27 

146 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mis- sissippi (April 27–29, 2005). 147 Id. 148 Id. Interview of Phillip Martin, Chief, Mississippi Band of Choctaw Indians, in Washington, D.C. (May 17, 2005). 149 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mississippi (April 27–29, 2005). 150 Id. 151 Id. 152 Id. 153 Id. 154The Choctaw Revolution: Lessons for Federal Indian Policy was a book written about the 

success of the Choctaw in 1998 by Peter Ferrara and published by ATR. The Choctaw reportedly 

paid Ferrara for his work on the book. Eamon Javers, ‘‘Op-Eds for Sale,’’ BusinessWeek Online 

(December 16, 2005). 

The Tribe would not discover, until after this Committee started its 

investigation, the scam that Abramoff and Scanlon were running 

on it. 

F. ABRAMOFF HAS THE CHOCTAW FUND HIS PET PROJECTS

1. 2000 Scotland Golf Trip 

In 2000, Abramoff had the Choctaw pay twice to the NCPPR: 

$25,000 on May 19 and $40,000 on June 27.146 It has been widely 

reported that the NCPPR used those funds to finance partially a 

golf trip to Scotland for Abramoff, Congressman DeLay and his 

staff, and others.147 The Tribe never intended for those funds to be 

used to finance a trip for any member of Congress; rather, it was 

intended as a donation for some anti-tax and anti-NACS [National 

Association of Convenience Stores] work.148 Any use of the funds 

to finance that Scotland trip was done without the Choctaw’s 

knowledge or authorization.149

2. Sports Suites 

For three years, the Choctaw paid into what Abramoff labeled 

the ‘‘Sports Suites’’ program: $170,374 in 1999, $233,679 in 2000, 

and $223,679 in 2001.150 Rogers understood that ‘‘Sports Suites 

company to be a company basically that was a Jack Abramoff company but that several tribes paid shares into so that the suites 

could be used for fundraisers or similar kinds of events.’’ 151

Abramoff told Rogers that he would represent the tribal participants as the owners of the Sports Suites.152 Rogers said she would 

find it objectionable if Abramoff used the Sports Suites boxes for 

the benefit of other clients or his family, unless they paid for their 

use of the Sports Suites.153

Rogers believed that Choctaw derived benefit from participating 

in the Sports Suites program: 

In some regards I do [believe the Tribe derived a benefit] 

because the box had copies of the Choctaw Revolution.154

It had the tribal profile. It had information about manufacturing opportunities or economic development opportunities on the reservation. And we actually had calls or ran 

into people who had picked up information about the tribe 

and who had contacted the tribe because of that. And 

there were fundraisers held for members of Congress 

there, including some in our delegation as well as other 

members who had interest in Indian issues or who had re-
28 

155 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mis- sissippi (April 27–29, 2005). 156See Email from Jack Abramoff, Greenberg Traurig, to Illisa Gertner, Greenberg Traurig 

(GTG–E000107717–18) (January 30, 2002) (attaching Liberty Consulting Services invoice). 157 Id. 158 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mississippi (April 27–29, 2005). 159 Id. 160Plea Agreement, Factual Basis for the Plea at para. 7, U.S. v. Tony C. Rudy (Dist. D.C., 

March 31, 2006) (CR–06–082). 161 Id. 162 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mis- sissippi (April 27–29, 2005). 163 Id. 

sponsibility for Indian issues. So in that regard, I think 

that the tribe did have some benefit.155

3. Liberty Consulting Services, LLC 

On January 30, 2002, Abramoff instructed his assistant Illisa 

Gertner to send an invoice for Liberty Consulting Services (‘‘Liberty’’) in the amount of $5,000 for ‘‘Consulting Services.’’ 156

Abramoff instructed Gertner to include a cover sheet saying, ‘‘Per 

my email about Alexander Strategy Group, attached please find the 

invoice for Liberty.’’ 157 Abramoff told the Tribe that Liberty ‘‘was 

another lobbying group that was going to oppose NACS [National 

Association of Convenience Stores]. ...’’ 158 The Choctaw paid Liberty Consulting a total of $25,000 in 2002.159

Unknown to the Choctaw, Liberty was actually a company set up 

by Tony Rudy, while he was serving on Congressman DeLay’s staff, 

as his Deputy Chief of Staff.160 When Rudy pled guilty to committing conspiracy on March 31, 2006, he admitted, among other 

things, that Liberty performed no services to justify receipt of the 

payments from the Choctaw: 

From February 2002 through July 2002, Abramoff, with 

Rudy’s knowledge and consent, arranged for payments totaling $25,000 to be made to Liberty Consulting by one of 

Firm B’s [Greenberg Traurig] clients, a Native American 

Tribe in Mississippi [Choctaw]. The payments were made 

in five monthly installments, which were usually sent by 

mail. Rudy knew that no additional services were being 

provided to the client for payments.161

G. CONCLUSION

All the money that Scanlon and Abramoff bilked from the Choctaw had very significant consequences for the Tribe. During her 

interview, Rogers identified numerous unmet needs of the Tribe, 

where the lost money would have been critical: ‘‘[s]cholarships; 

health care, in particular; education; courts; police.’’ 162

Nonetheless, after the first few The Washington Post articles ran, 

Abramoff attempted to have the Choctaw dissuade the Committee 

from investigating. Rogers said Abramoff ‘‘asked me if I would ask 

the Chief to approach Senator McCain and suggest that each of the 

tribes, since they had their own police departments and courts, conduct their own internal investigations.’’ 163

Even as details of his and Scanlon’s ‘‘gimme five’’ scheme began 

to emerge, Abramoff attempted to conceal his and Scanlon’s wrong-
29 

164 Id. 

doing from the Tribe. In a telephone conversation with Rogers, 

Abramoff claimed that he used his school as a conduit to pass 

Choctaw money to grassroots organizations. According to Rogers: 

He [Jack] said that he—he said, ‘‘Well, Nell, I have to tell 

you, I took some of the money Mike had’’—yeah. He said, 

‘‘I took some of the money that Mike had and I gave it to 

the school and they passed the money through. And the 

people they passed it to will never tell.’’ 164

(31) 

1 Email between Kevin Ring, Greenberg Traurig, and Matt DeMazza (GTG–E000257509) (Feb- ruary 22, 2004). 2 Id. 

3 Id. 

CHAPTER II 

COUSHATTA TRIBE OF LOUISIANA 

ABRAMOFF: Can you let me know how much more (than 

the current +/¥ 660K) we would each score should 

Coushatta come through for this phase, and Choctaw continue to make the transfers. I need to assess where I am 

at for the school’s sake. 

SCANLON: Coushatta is an absolute cake walk. Your cut on 

the project as proposed is at least 800k ... Total [:] 1.5. mil 

on top of the 660. For a toal [sic] of 2.1. Not bad :) :) [sic] 

ABRAMOFF: How can I say this strongly enough: YOU IZ 

DA MAN. 

SCANLON: Ill [sic] take the man title for now—but not tomorrow, you return to being the man at midnight! Let’s 

grow that 2.1 to 5!!! We need the true give me five! 

ABRAMOFF: Amen!! 

Email between Jack Abramoff and Michael Scanlon, September 10, 2001 

ABRAMOFF: I’m actually in a bad cash position ... I need 

[the expected payment from the Agua Caliente] badly. 

Other than [that Tribe], what next on the money train? 

[The Choctaw] coming through soon? 

SCANLON: The next big money we have coming our way is 

Coushatta, and that will be in early January—the exact 

amounts I’m still hammering out. 

Email between Jack Abramoff and Michael Scanlon, December 17, 2002 

A. INTRODUCTION

By February 22, 2004, when The Washington Post published its 

article entitled, ‘‘A Jackpot From Indian Gaming Tribes; Lobbying, 

PR Firms Paid $45 Million Over 3 Years,’’ Abramoff and Scanlon’s 

scheme to defraud several Native American tribes out of tens of 

millions of dollars was beginning to unravel. 

Soon after the article’s publication, former Abramoff associate 

Kevin Ring emailed a colleague, ‘‘I know more than [the] article 

and the truth is worse.’’ 1

Ring continued, ‘‘Now what do you think of my partner Jack? Not 

too shady, eh?’’ 2

Referring to how much the Tribes covered in the article reportedly paid Abramoff and Scanlon, Ring’s colleague could only reply, 

‘‘that’s a lot of cake.’’ 3
32 

4 Email from Jack Abramoff, Greenberg Traurig, to Gail Halpern, May & Barnhard (GTG– 

E000012336) (December 23, 2001). 5See Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in 

Washington, D.C. (September 13–14, 2005). 6See Id. 

7See Id. 

8See Id. 

9See Id. 

10See Id. 11 A fuller discussion of this transaction is contained in Part III, Chapter 1, Section A, entitled, ‘‘Council of Republicans for Environmental Advocacy: Background.’’ 

Among all of Abramoff’s Tribal clients, the Coushatta Tribe of 

Louisiana (‘‘Louisiana Coushatta’’) paid Scanlon the most. Between 

2001 and 2003, Abramoff and Scanlon successfully had the Tribe 

pay them (or entities owned or controlled by them) about 

$32,000,000: about $27,000,000 to Capitol Campaign Strategies 

(‘‘CCS’’); another $3,600,000 to the American International Center 

(‘‘AIC’’); $1,000,000 to the Capital Athletic Foundation (‘‘CAF’’) 

through the firm of Greenberg Traurig; and another $950,000 

through a Scanlon-controlled entity called Atlantic Research & 

Analysis (‘‘ARA’’). Of the $27,000,000 the Tribe paid to CCS, Scanlon appears to have kicked back roughly a third to Abramoff in ‘‘referral fees.’’ This constituted about one-half of Scanlon’s net profit. 

In addition, of the $3,600,000 the Tribe paid to AIC, Scanlon diverted almost $1,000,000 to an entity called Kaygold, which 

Abramoff privately described to his tax advisor as ‘‘really me.’’ 4

In the course of their three-year business relationship with the 

Tribe, Abramoff and Scanlon were indifferent to the trust that the 

Louisiana Coushatta put in them as its paid representatives and 

advocates. At no time did they ever tell the Tribe that Abramoff 

had a financial interest in CCS or that Abramoff received a hefty 

percentage of the millions of dollars that the Tribe paid CCS or 

AIC.5 Similarly, the Tribe never knew that the cost of services 

charged by Scanlon was dramatically inflated so that Abramoff 

could get a big piece of a big pie.6 The Tribe likewise never knew 

most of the money it paid Scanlon actually went to finance Scanlon’s private investments and to float Abramoff’s business ventures.7

In addition, at no time was the Tribe ever told that any of the 

money it paid Scanlon would be diverted to Abramoff’s private 

charity—for distribution mostly to Abramoff’s Jewish boys’ school.8

The Tribe was also never told that any of its payments to Scanlon 

would actually be used to conduct public relations activities for 

other Tribes, on matters wholly unrelated to the Louisiana 

Coushatta.9 Abramoff and Scanlon also concealed from the Tribe 

their representation of the Ysleta del Sur Pueblo of Texas 

(‘‘Tigua’’), whose interests the Louisiana Coushatta hired Abramoff 

and Scanlon to oppose.10 Abramoff or Scanlon also deceived the 

Tribe into making a sizeable ‘‘contribution’’ to an obscure environmental advocacy group.11 Regrettably, there was much the Tribe 

did not know about the activities of Abramoff and Scanlon—its 

‘‘trusted’’ advisors. 

This Chapter will, drawing from evidence that the Committee 

has already released to date and new information that the Committee is now releasing in conjunction with this Report, attempt to 

explicate the foregoing activities. 
33 

12 Early Records Show Coushatta Living in Northern Alabama, (visited March 20, 2006) <http://www.carencrohighschool.org/LAlStudies/indian/coushatta/alabama.htm> (discussing the early history of the Coushatta); A History of the Sovereign Nation of the Coushatta Tribe 

of Louisiana, (visited March 19, 2006), http://www.coushattatribe.org/history.html>. 13 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. at 11 (November 2, 2005) (testimony of Kevin Sickey, Chairman, Coushatta Tribe of Louisiana). 14 Id. at 10. 15The Culture of the Coushatta Tribe of Louisiana, (visited March 20, 2006) <http:// 

www.coushattatribela.org/culture1.html> (describing the culture and social organization of the Louisiana Coushatta). 16 Id. 17 Id. 18 Id. 19 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. at 10 (November 2, 2005) (testimony of Kevin Sickey, Chairman, Coushatta Tribe of Louisiana). 20 Id. at 10–11. 21 Id. at 11. 22The Sovereign Nation of the Coushatta Tribe of Louisiana, (visited March 20, 2006) <http:// 

www.coushattatribela.org/historylchrono.html> (providing a chronology of Louisiana Coushatta history). 23The Government of the Sovereign Nation of the Coushatta Tribe of Louisiana, (visited 

March. 20, 2006) <http://www.coushattatribela.org/government.html> (describing the governing structure of the Louisiana Coushatta). 24The Sovereign Nation of the Coushatta Tribe of Louisiana, (visited March 20, 2006) <http:// 

www.coushattatribela.org/historylchrono.html> (providing a chronology of Louisiana Coushatta history). 25 Id. 26 Id. 

B. BACKGROUND ON THE TRIBE

The Louisiana Coushatta’s traditional homelands are in Alabama; however, in the late 18th Century a group of approximately 

100 Coushatta led by a tribal leader named Red Shoes moved to 

Louisiana around the Red River.12 Since then, its population has 

grown to over 850 enrolled members.13 Traditionally, the Louisiana 

Coushatta belonged to the southern section of the Creek Confederacy, a loose association of Muskogee family tribes occupying and 

controlling a vast area across the South.14 The Tribe is composed 

of seven large clans and several more smaller clans, which form the 

foundation of its society.15 As members of the Creek Confederacy, 

the Coushatta lived in an agriculturally based economy.16 It grew 

corn, peas, beans, squash, potatoes, and rice.17 Sophisticated trade 

networks were developed covering thousands of miles.18

In 1898, the Federal Government took land into trust for the 

Tribe.19 In 1953, during the Termination Era, during which the 

government terminated its trust relationship with certain tribes, 

the Bureau of Indian Affairs (‘‘BIA’’) ended its trusteeship with, 

and discontinued its services to, the Louisiana Coushatta.20 However, after twenty years of struggle, the Louisiana Coushatta’s federal recognition as a tribe was restored in 1973 and it held its first 

elections in 1985.21 In 1980, the current reservation near Elton, 

Louisiana was formally established.22

Over the past twenty years, the Tribe has increased its reservation land base from the original 35 acres of land to 154 acres.23

This land is used for Tribal housing, economic development projects 

such as crawfish farming and cattle-raising, and to house its numerous governmental programs and services.24 The Louisiana 

Coushatta have established a Tribal police department; community, 

health and learning centers; and other social programs.25 The Tribe 

has enjoyed economic prosperity largely due to the success of its 

Grand Casino in Kinder, Louisiana, which opened in 1995.26 The 
34 

27 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. 

at 10–11 (November 2, 2005) (testimony of Kevin Sickey, Chairman, Coushatta Tribe of Louisiana). 28 Id. at 10–11. 29 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in 

Lecompte, Louisiana (September 21, 2005). See also ‘‘Tribal Lobbying Matters,’’ Hearings before 

the Committee on Indian Affairs, 109th Cong. at 17 (November 2, 2005) (testimony of William 

Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana). 30 Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 31 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in 

Lecompte, Louisiana (September 21, 2005). 32 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. 

at 17 (November 2, 2005) (testimony of William Worfel, former Vice-Chairman, Coushatta Tribe 

of Louisiana). 33 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in 

Lecompte, Louisiana (September 21, 2005). 34 Id. 35 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in 

Lecompte, Louisiana (September 21, 2005). 36 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in 

Lecompte, Louisiana (September 21, 2005); Interview of William Worfel, former Vice-Chairman, 

Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). Worfel understood 

that Martin and Abramoff were ‘‘tight.’’ Id. He recalls that ‘‘[Abramoff and Scanlon] would talk 

about Terry [Martin] a lot to me’’ and Martin ‘‘promoted [Abramoff and Scanlon] a lot.’’ Id. See 

also ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. 

at 17 (November 2, 2005) (testimony of William Worfel, former Vice-Chairman). 

Louisiana Coushatta currently employs 2,800 people, with a total 

annual payroll in the range of $80 million.27 In addition, they contribute approximately $7 million per year to state and local governments.28

C. ABRAMOFF AND SCANLON GET THE LOUISIANA COUSHATTA’S

BUSINESS

By the Spring of 2001, the Louisiana Coushatta was set to renegotiate its gaming compact with the State of Louisiana, which it 

needed to continue operating its casino in the State legally.29 Its 

compact was due to expire later that summer and the Tribe wanted 

to get a 25-year compact with the State as the Cherokees had obtained in North Carolina, to avoid having to renegotiate with the 

Governor’s office every seven years.30 But, with 2001 being a gubernatorial election year, the Tribe was concerned about its prospects for success with then-Governor Mike Foster.31 The Tribe was 

expecting a ‘‘very vigorous fight’’ 32 and had doubts about whether 

its lobbyists at the time were aggressive enough to get the best 

deal.33

Sometime during this same period, two members of the Louisiana Coushatta’s Tribal Council, William Worfel and Bertney 

Langley, called Kathryn Van Hoof, the Louisiana Coushatta’s outside counsel, from a meeting of the United South and Eastern 

Tribes (‘‘USET’’).34 They told her that they had just spoken with 

Terry Martin, a representative of the Chitimacha Tribe of Louisiana (‘‘Chitimacha’’).35 Martin recommended to Worfel and Langley that they contact a prominent Washington, D.C. lobbyist and a 

public relations consultant his Tribe had used and with whom they 

were very satisfied.36 Their names: Jack Abramoff and Michael 
35 

37 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in 

Lecompte, Louisiana (September 21, 2005); Interview of William Worfel, former Vice-Chairman, 

Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 38 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in 

Lecompte, Louisiana (September 21, 2005); Interview of William Worfel, former Vice-Chairman, 

Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 39 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in Lecompte, Louisiana (September 21, 2005). See also ‘‘Tribal Lobbying Matters,’’ Hearings before 

the Committee on Indian Affairs, 109th Cong. at 17 (November 2, 2005) (testimony of William Worfel, former Vice-Chairman). 40 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in Lecompte, Louisiana (September 21, 2005). 41 Id. 42 Id. 43 Id. 44 Id. 45 Id. 46 Id. 47 Id. 48 Id. 49 Id. 50 Id.; Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in 

Washington, D.C. (September 13–14, 2005). 51 Id.; Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in Lecompte, Louisiana (September 21, 2005) (recalling only Abramoff’s attendance). Also 

present was administrative assistant, Michelle ‘‘Missy’’ Litteral; Interview of William Worfel, 

former Vice-Chairman, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 

Continued 

Scanlon.37 Martin suggested that they might be able to help with 

the Tribe’s compact.38

So, Worfel and Langley asked Van Hoof to meet with Martin in 

Marksville, Louisiana that day.39 At that meeting, Martin told Van 

Hoof about Abramoff’s history with his Tribe.40 He also discussed 

Abramoff’s successful representation of the Mississippi Band of 

Choctaw Indians (‘‘Choctaw’’) on several funding issues and noted 

how happy that Tribe was with Abramoff’s representation.41 He 

told Van Hoof that Abramoff was well-connected and a friend of 

former Congressman Tom DeLay.42 Martin discussed the possibility that Abramoff could help the Louisiana Coushatta with its 

compact renegotiations.43

Van Hoof returned to the Louisiana Coushatta Tribal Council, 

which was then comprised of not only Worfel and Langley but also 

Chairman Lovelin Poncho and councilmen Leonard Battise and 

Harold John, and conducted some basic due diligence on 

Abramoff.44 She then delivered an oral report to the Tribal Council 

on her meeting with Martin about Abramoff.45 Van Hoof described 

how hiring Abramoff could help the Tribe implement a strategy to 

convey, in particular to the Governor and the State legislature, 

that it had political ‘‘stroke’’ in Washington.46 After Van Hoof’s 

presentation, the Tribal Council asked Van Hoof to invite Abramoff 

to meet with the council about possibly representing the Louisiana 

Coushatta as its lobbyist in Washington, D.C.47 Van Hoof complied.48

In anticipation of his meeting with the Tribal Council, Abramoff 

spoke with Van Hoof more fully about the Louisiana Coushatta’s 

lobbying interests.49 He was preparing a formal plan and budget 

proposal for the Tribal Council.50

About a week or two after Van Hoof’s presentation to the Tribal 

Council, probably in March 2001, Abramoff and Scanlon went to 

Louisiana to meet with the Tribal Council at the Tribe’s administration building.51 During the meeting, Abramoff described his 
36 

2005). At this meeting, it was suggested that Abramoff and Scanlon would talk more openly if 

the council turned off its recorder. See id. 52 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in Lecompte, Louisiana (September 21, 2005); Interview of William Worfel, former Vice-Chairman, 

Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 53 Id. 54 Id. Worfel testified that ‘‘[he] heard [reference to earmarks] so much.’’ Id. 55 Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 56 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in Lecompte, Louisiana (September 21, 2005). 57 Id.; see also Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005) (Worfel describing how Scanlon said he 

could do ‘‘media blitzes,’’ ‘‘phone calls,’’ ‘‘phone banks,’’ ‘‘advertising on television,’’ etc.); ‘‘Tribal 

Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. at 17 (Novem- ber 2, 2005) (testimony of William Worfel, former Vice-Chairman). 58 Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 59 Id. Months later, Abramoff and Scanlon would cite their association with the Choctaw in 

furtherance of their scheme to defraud the Tribe: When Abramoff pitched Scanlon in connection 

with a plan to elect Louisiana officials calculated to be supportive of the Tribe’s gaming interests, called the ‘‘Louisiana Political Program,’’ Abramoff told Worfel that Chief Phillip Martin 

had spent $13 million ‘‘to get the governor of Alabama elected to keep gaming out of Alabama 

so it wouldn’t hurt ... his market in Mississippi.’’ Id. 60 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in Lecompte, Louisiana (September 21, 2005). 61 Id. 62 Id.; Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in 

Washington, D.C. (September 13–14, 2005). 63Plea Agreement, Factual Basis for the Plea at para. 2, U.S. v. Michael P.S. Scanlon (Dist. 

D.C., November 17, 2005) (CR–05–411). 

background, political connections, and capabilities.52 In particular, 

he mentioned that he ‘‘knew federal Indian law,’’ ‘‘federal legislation,’’ and ‘‘how to get things passed through the legislature.’’ 53 Referring to appropriations earmarks, Abramoff said that his team 

could get ‘‘line items’ for the Tribe.54

He also mentioned that he ‘‘worked with people’’ in the Department of Interior and with Members of Congress.55 Abramoff specifically mentioned his relationship with Congressman DeLay and 

former DeLay associate Scanlon.56 Abramoff described how Scanlon’s background as a media consultant and in public relations 

could help make it appear that the Louisiana Coushatta had connections in Washington.57

Abramoff also cited his success with the Choctaw.58 That impressed Worfel and the Tribal Council; the Tribe had been trying 

to model itself and its casino operations on the economic development strategy that Chief Phillip Martin used to make the Choctaw 

among the most respected tribes in Indian Country.59

Abramoff proposed a plan for establishing relationships with 

Members of Congress and participating in various campaign-related activities and events to help the Tribe convey to others that 

it had influence in Washington, D.C.60 For example, Abramoff provided the Tribe with information about a DeLay golf tournament, 

saying that participating would convey the impression that it had 

some real ‘‘stroke’’ in Washington and would also build some good 

will with DeLay.61 Participation in events such as these and payments on ‘‘lists of suggested contributions’’ would, Abramoff suggested, provide name recognition and access.62

In pitching himself to the Tribal Council, Scanlon represented 

that CCS could organize direct mail and telephone campaigns that 

would urge public officials to support issues important to CCS’s clients.63 At the council meeting, Scanlon described himself as a 
37 

64 Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 65Plea Agreement, Factual Basis for the Plea at para. 2, U.S. v. Michael P.S. Scanlon (Dist. 

D.C., November 17, 2005) (CR–05–411). 66 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in 

Lecompte, Louisiana (September 21, 2005). 67Plea Agreement, Factual Basis for the Plea at para. 2, U.S. v. Michael P.S. Scanlon (Dist. 

D.C., November 17, 2005) (CR–05–411). 68 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in 

Lecompte, Louisiana (September 21, 2005). 69 Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 70 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in 

Lecompte, Louisiana (September 21, 2005). 71 Id. There were at least two other meetings between the Tribal Council and Abramoff and 

Scanlon—another one in the Spring of 2001 (about two or three weeks after the first) and one 

in February 2004. Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005) (during which compact renegotiation, 

Texas threats, Delta Downs and Pinnacle were discussed). Worfel and Poncho met with 

Abramoff at least one other time early in 2004 at Abramoff’s office in Greenberg Traurig. Id. 72 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in 

Lecompte, Louisiana (September 21, 2005). 73 Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 74 Id. 75 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in 

Lecompte, Louisiana (September 21, 2005). 

‘‘bulldog’’—‘‘the one who puts fires out’’ and ‘‘[who] did the groundwork, like on the ads, the radio blitz, the phone banks, and all 

that.’’ 64 Scanlon represented that CCS ‘‘could provide effective advice about strategies focusing on specific public officials in order to 

obtain official support for, or neutralize opposition to, the interests 

of CCS’ clients.’’ 65

The main operational feature of Scanlon’s proposal was an elaborate political database.66 To support that database, Scanlon said 

that he would provide a range of ‘‘electronic-related services.’’ 67

Polling would identify the likes and dislikes of those who may be 

inclined to support the Louisiana Coushatta’s casino.68 He would 

also ‘‘need to [get] a list of [the Tribe’s] vendors and ... associates, 

... tribal members, everybody that does business with the casino 

and the tribe, and try to get them to start making phone calls, letter-writing campaigns....’’ 69 Having identified the universe of individuals whose preferences were consistent with the interests of the 

Tribe, Scanlon promised to use this ‘‘customized’’ database to mobilize them.70 Scanlon said that this would, for example, ‘‘have them 

flood the offices of policy makers with calls.’’ 71

Based on representations Abramoff and Scanlon made to the 

Tribal Council at this meeting, Van Hoof understood that Scanlon 

had ‘‘vast experience’’ in public relations and that Scanlon was 

‘‘part of the package’’ with Abramoff’s representation of the Louisiana Coushatta.72 Worfel came to believe that Scanlon’s company 

was a branch of Greenberg Traurig.73 When Abramoff first met 

with the Tribal Council, Abramoff said that Scanlon worked for 

him, and Van Hoof always referred to ‘‘Jack and his guys.’’ 74 But, 

Van Hoof and Worfel agree, Abramoff never told the Council that 

he would personally collect a share of those proceeds that the Tribe 

paid Scanlon.75
38 

76 Id.; Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in 

Washington, D.C. (September 13–14, 2005). 77 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in Lecompte, Louisiana (September 21, 2005); Interview of William Worfel, former Vice-Chairman, 

Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 78Letter from Jack Abramoff, Greenberg Traurig, to Kathryn Van Hoof, Coushatta Tribe of Louisiana (COUSH–MiscKVH–0001189–91) (March 16, 2001). 79 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in Lecompte, Louisiana (September 21, 2005). 80 Id. 81 Id. Despite a provision in its agreement with Greenberg Traurig to the contrary, the firm’s expenses (which were not itemized in its bills to the Tribe) were deducted from the retainer. 

Id. Van Hoof could not explain why the Tribe agreed to this arrangement. While Van Hoof 

served as outside counsel to the Louisiana Coushatta, she was never advised of what expenses 

Abramoff and his team at the firm incurred. Id. Typically, those expenses amounted to about 

$15,000 to $18,000 per month. Interview of Stephanie Leger Short, former associate, Greenberg 

Traurig, in Washington, D.C. (August 18, 2005). Occasionally, Leger questioned some of those 

expenses, including an anomalous charge for the charter of a helicopter. See id. But, inevitably 

the response would be ‘‘That’s the way Jack wants it to be.’’ Id. Also, according to Short, two 

of Abramoff’s associates, Shana Tesler and Samuel Hook, did not work all those hours for which 

Greenberg Traurig billed its clients. See id. She recalled, ‘‘[T]owards the end, [Tesler] and Sam 

[Hook] were not at Greenberg, physically, often at all.’’ Id. ‘‘It was common knowledge within 

our group that they weren’t there, but hours were on our bills.’’ Id. However, where the Louisiana Coushatta and other Tribes who were so charged for these hours paid a retainer, i.e., were not billed hourly, they were not injured by those billings. 82 Email from Jack Abramoff, Greenberg Traurig, to Kathryn Van Hoof, Coushatta Tribe of Louisiana (COUSH–MiscKVH–0001632–33) (April 12, 2001). 83 Id. Email from Jack Abramoff, Greenberg Traurig, to Kathryn Van Hoof, Coushatta Tribe of Louisiana (COUSH–MiscKVH–0001632–33) (April 12, 2001). 84 Id. 85 Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 86 Id. 

Impressed with their proposals, the Tribal Council hired 

Abramoff and Scanlon as their federal lobbyist and grassroots political/media consultant, respectively.76

Their tasks were to ‘‘assist [the Tribe] with the renewal of its 

compact with the State of Louisiana, regional gaming issues, and 

obtaining its public policy goals in Washington, D.C.’’ 77 Under an 

agreement executed on March 20, 2001, the Tribe was to pay 

Greenberg Traurig, the firm with which Abramoff was associated, 

$125,000 per month plus reasonable expenses.78 The Tribe was 

willing to pay this high retainer because it reflected, according to 

Van Hoof, ‘‘a concentrated effort within a short period of time’’ or 

‘‘a short-term blitz’’ while the Tribe was renegotiating its compact.79 Van Hoof assumed that the retainer amount would decrease 

after the compact period.80 In fact, she was surprised to learn, after 

she was no longer with the Tribe, that the Tribe had continued to 

pay Greenberg Traurig a retainer at the original amount.81

Separately, the Tribe was to pay CCS, Scanlon’s company, for grassroots activities related to the compact renegotiations—‘‘the 

ground effort.’’ 82 Referring to this ground effort, on April 12, 2001, Abramoff told Van Hoof that ‘‘Mike [Scanlon] believes we can’t wait 

any longer for [it].’’ 83 The asking price, $534,500.84

With those agreements, the Tribe placed their trust in Abramoff and Scanlon. As Worfel testified, ‘‘You trust them because they 

worked for Greenberg. It’s supposed to be one of the most prestigious law firms in D.C. and America, and these people worked for 

these guys.’’ 85 Worfel trusted Abramoff, in particular, because it 

had been reported that he was one of the best lobbyists in Washington, D.C.; the Tribe was paying him a lot of money to represent 

its interests in D.C. and in the states; and (as described below) he 

and Scanlon originally ‘‘got good results.’’ 86
39 

87 Interview of Stephanie Leger Short, former associate, Greenberg Traurig, in Washington, 

D.C. (August 18, 2005). 88 Id. 89 Id. 90 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in 

Lecompte, Louisiana (September 21, 2005). 91 Id. 92 Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 93 Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 94Memorandum from Michael Scanlon, Capitol Campaign Strategies, to Kathryn Van Hoof, 

Coushatta Tribe of Louisiana, ‘‘Louisiana Political Budget Outline’’ (October 23, 2001) (‘‘we need 

to modify your political database into a statewide format’’). 95Louisiana Coushatta document production (no Bates number) (June 26, 2001) (‘‘ ‘The 

Coushatta Political Program,’ by Michael Scanlon’’). 96See Email from Jack Abramoff, Greenberg Traurig, to Kathryn Van Hoof, Coushatta Tribe 

of Louisiana (COUSH–MiscKVH–0001632–33) (April 12, 2001) (‘‘I still do not have the budget 

for the complete effort, but Mike believes we cannot wait any longer for the on ground effort, 

so I need to get this to you for approval. ... Please let me know if I can give Mike the go 

ahead.’’); Email from Michael Scanlon, Capitol Campaign Strategies, to Kathryn Van Hoof, 

Coushatta Tribe of Louisiana, ‘‘Re: Political Program funding’’ (COUSH–MiscFin–0000368) 

(April 18, 2001) (‘‘The total for the program is $539,000. In order to get started the tribe will 

need to pay $200k up front to cover the organizational program. ... If there [sic] is any way to 

get the initial money out today it would be great!’’). 

In her interview, Short recalled that Worfel told her that the 

Tribe wanted to be the ‘‘Choctaw of Louisiana.’’ 87 According to 

Short, the Louisiana Coushatta were ‘‘in awe of the Mississippi 

Choctaw ... because Chief Martin has done an amazing job with his 

tribe. ...’’ 88 ‘‘And so I think,’’ Leger continued, ‘‘Chief Martin trusted Jack, and had Jack doing all these things for them. I think that 

gave him automatic credibility with William [Worfel]. And then 

meeting with him, I think, just sealed the deal.’’ 89

After the Tribe hired Abramoff and Scanlon, the Tribal Council 

asked Van Hoof to liaise between the Tribe, on the one hand, and 

Abramoff and Scanlon, on the other.90 From the Spring through 

the Fall of 2001, she did so.91 During the Fall of 2001 onward, 

Worfel replaced Van Hoof as the Tribe’s point of contact with 

Abramoff and Scanlon.92

D. SCANLON’S GRASSROOTS PROJECTS FOR THE TRIBE

As described above, initially Scanlon was hired to help the Tribe 

on its renegotiations with the State of Louisiana regarding its gaming compact. Scanlon promised to develop and implement a media 

blitz, a letter writing campaign to the governor and local officials, 

phone banks, and opposition research.93 That would be accomplished by Scanlon’s ‘‘political database.’’ 94

A draft of a program budget outlines what Scanlon proposed to 

do for the Tribe regarding the compact renegotiations. Using language very similar to what he used with other Tribes, Scanlon proposed a five-point plan focused around the development and use of 

an elaborate political database.95

Apparently, Abramoff and Scanlon split the fees that the Louisiana Coushatta paid for CCS’ work on the compact renegotiations: 

on April 12, 2001, and April 18, 2001, Abramoff and Scanlon each 

urged Van Hoof that the Tribe come up with $200,000 for an ‘‘organizational phase’’ of this political program.96 On or about April 26, 

2001, the Tribe paid CCS $200,000, as requested. Soon thereafter, 
40 

97Diehl & Company document production (D00411–512) (undated) (General Ledger, Capitol Campaign Strategies). 98 Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 99 Id. 100 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in Lecompte, Louisiana (September 21, 2005). 101 Id. 102 Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in 

Washington, D.C. (September 13–14, 2005). 103See Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in Lecompte, Louisiana (September 21, 2005). See also ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. at 17 (November 2, 2005) (testimony of Wil- liam Worfel, former Vice-Chairman). 104 Id. 105 Id. 106 Id. 

on or about April 30, 2001, CCS paid Abramoff $75,000—itemized 

in CCS’ accounting ledger as a ‘‘referral expense.’’ 97

Worfel did see evidence that Scanlon’s strategy was implemented.98 In July 2001, Governor Foster signed the compact.99

Most of the Tribal Council, and Van Hoof, were satisfied with the 

work that Scanlon conducted on the compact renegotiations.100

But, afterwards, the scope of work dramatically increased.101 Soon 

after his first meeting with the Tribal Council, Abramoff raised 

with the Tribe the idea of fighting the expansion of gaming in 

Texas and dockside gaming projects elsewhere in Louisiana.102

Indeed, Abramoff and Scanlon, on whom the Tribe relied as experts, persuaded the Tribal Council that threats to the Tribe’s gaming interests were everywhere—state-sponsored gambling, slot machines at horse tracks, the possibility of Texas legalizing gaming, 

and competing casinos possibly being built by other tribes.103 According to Worfel, ‘‘It was always one crisis after another. There 

were real threats and some not so real, looking back with hindsight.’’ 104

Worfel continued: 

Texas gaming was one of those oversold threats. In 2001, 

we were told by Abramoff that Texas was one vote away 

from allowing casino gambling. I have since learned that 

legalized casino gambling was far from being approved by 

the Texas Legislature. In addition, we have learned that 

Jack and Mike were working for other tribes in Texas that 

were trying to get gaming, when they were supposed to be 

watching out for us.105

Worfel asked rhetorically: 

What should you spend to save a $300-million a year business when the lawyers who work for you tell you that it 

could all be gone if we do not act now? Our tribe has one 

and only one business. We made tough decisions and we 

acted always in the best interests of our tribe.106

Thus, the Tribe hired Scanlon to implement a number of grassroots activities on behalf of the Louisiana Coushatta to battle the 

numerous threats—both real and imagined—that the Tribe faced. 

Over the following three years, separate from its payments to 

Greenberg Traurig, the Louisiana Coushatta paid entities owned or 
41 

107 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000252622) (June 2, 2002). 

controlled by Abramoff or Scanlon about $32,000,000. Those payments are set forth below. 

PAYMENTS BY LOUISIANA COUSHATTA TO ABRAMOFF/SCANLON

ENTITIES

Payments by Tribe to Capitol Campaign Strategies (CCS) 

4/26/01 ............................................................................................. $200,000 

5/30/01 ............................................................................................. 283,500 

6/29/01 ............................................................................................. 850,000 

7/13/01 ............................................................................................. 200,000 

7/26/01 ............................................................................................. 102,000 

7/26/01 ............................................................................................. 292,500 

7/26/01 ............................................................................................. 97,500 

10/5/01 ............................................................................................. 940,000 

10/31/01 ........................................................................................... 700,000 

10/31/01 ........................................................................................... 2,170,000 

1/18/02 ............................................................................................. 1,000,000 

1/18/02 ............................................................................................. 1,500,000 

1/18/02 ............................................................................................. 1,505,000 

1/24/02 ............................................................................................. 800,000 

2/6/02 ............................................................................................... 1,200,000 

3/15/02 ............................................................................................. 3,405,000 

4/3/02 ............................................................................................... 2,100,000 

8/2/02 ............................................................................................... 2,100,000 

10/16/02 ........................................................................................... 950,000 

2/14/03 ............................................................................................. 5,000,000 

4/22/03—Coushatta/AIC ................................................................. 1,300,000 

Total ......................................................................................... 26,695,500 

Payments by Tribe to American International Center (AIC) 

3/16/01—Southern Underwriters ................................................... 400,000 

3/21/01 ............................................................................................. 258,000 

3/30/01 ............................................................................................. 298,000 

4/27/01 ............................................................................................. 397,200 

4/9/03 ............................................................................................... 2,300,000 

Total ......................................................................................... 3,653,200 

Payments by Tribe to Capital Athletic Foundation (CAF) 

11/13/01—Greenberg Traurig ........................................................ 1,000,000 

5/8/03—Atlantic Research & Analysis .......................................... 950,000 

Total ......................................................................................... 1,950,000 

Grand Total .......................................................................... 32,298,700 

As the foregoing indicates, during the first quarter of 2002 alone, 

the Tribe made continuous payments to Abramoff and Scanlon, totaling over $9,000,000. But, on June 2, 2002, Abramoff wrote Scanlon, ‘‘[The Louisiana Coushatta] are ripe for more pickings. We 

have to figure out how.’’ 107

In furtherance of the grassroots strategy devised for the Tribe, 

Abramoff and Scanlon persuaded the Tribal Council to financially 

support other groups opposed to gaming expansion, namely Christian evangelical conservatives, to help the Tribe protect its share 
42 

108 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in Lecompte, Louisiana (September 21, 2005). 109 Id. 110 Id. 111 Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in 

Washington, D.C. (September 13–14, 2005). From 2001 through 2004, most, if not all, of the 

Louisiana Coushatta’s revenue came from its casino profits. Id. See also id. ( ‘‘[Reed’s name 

could not be mentioned,] I guess because he would be judged as a hypocrite.’’). 112 Id. 113 Id. 114 Id. 115 Id. 116 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in Lecompte, Louisiana (September 21, 2005). 117 Id. 118 Id. 119 Id. 120 Id. 121 Id.; Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in 

Washington, D.C. (September 13–14, 2005). 122 Interview of Kathryn Van Hoof, former outside counsel, Coushatta Tribe of Louisiana, in Lecompte, Louisiana (September 21, 2005). 

of the regional gaming market.108 Abramoff specifically proposed that the Tribe work with former Christian Coalition Executive Director Ralph Reed.109 According to Van Hoof, Abramoff understood that gaming opponents, like Christian conservatives, would of 

course eschew direct contributions from the Tribe.110 Worfel recalled that Van Hoof ‘‘came back and told us that [sic] a guy named 

Ralph Reed. She was real careful about a Ralph Reed person. It 

can’t get out. He’s Christian Coalition. It wouldn’t look good if 

they’re receiving money from a casino-operating tribe to oppose 

gaming. It would be kind of like hypocritical.’’ 111

Worfel testified that, on the Tribe’s behalf, Abramoff hired Reed 

to help prevent the expansion of gaming in Louisiana.112 In that 

capacity, Worfel understood, Reed was supposed to mobilize ‘‘the 

Christian Coalition’’ to engage on several legislative initiatives relating to gaming, including, opposing bills providing for dockside 

gaming and supporting an amendment that raised taxes on the 

river boats.113 Furthermore, Worfel recalled, Van Hoof told him 

that Reed would ‘‘supposedly get a lot of pastors or preachers or 

ministers ... together.’’ 114 But, once again, Worfel recalled Van Hoof cautioning him that Reed ‘‘did not want his name being revealed.’’ 115

Against that backdrop, Abramoff asked whether the Tribe had any business through which payments to Reed could be made.116

In a meeting that included Louisiana businessman Aubrey Temple, 

Temple volunteered the use of one of his businesses as a conduit.117 It was an apparently moribund insurance company called Southern Underwriters.118 So, on or about March 16, 2001, the 

Tribe paid $400,000 to AIC, a Scanlon-controlled entity, through 

Southern Underwriters.119 From Abramoff, Van Hoof understood 

that AIC was an entity that supported anti-gaming efforts, which 

the Tribe could support.120 She also understood that the Tribe’s 

money that went through AIC was to go to Reed, for coalitionbuilding against gaming initiatives that would have competed with 

the Tribe.121 She also understood that, by paying Reed through AIC, the Tribe’s identity as the original source of those funds would 

be disguised.122 When the Tribe paid AIC in March 2001, it did not 

know that Abramoff and Scanlon would later extract secretly millions in ‘‘gimme five’’ proceeds from Tribal payments routed 
43 

through that entity. How Abramoff and Scanlon did so is fully explained in Part 2, Chapter 2, Section E, of this Report, entitled, 

‘‘American International Center: AIC as a ‘‘Gimme Five Entity.’’ 

E. CONCLUSION

Specifically citing the work he had done for the Choctaw, 

Abramoff subsequently secured contracts for himself and Scanlon 

from the Louisiana Coushatta. Of all the Tribes that hired Scanlon, 

the Louisiana Coushatta ended up paying Scanlon the most. Initially, the Tribe hired Scanlon to help with its compact renegotiations with the State of Louisiana. But, after having successfully 

assisted the Tribe, Scanlon dramatically expanded his scope of 

work, which ranged from squelching supposedly ubiquitous threats 

to the Tribal casino’s customer market share, to supposedly getting 

the ‘‘right’’ candidates elected to the Louisiana State Legislature. 

To its detriment, the Tribe trusted Abramoff and Scanlon’s expertise in Indian gaming and were captured by their lure of making the Louisiana Coushatta ‘‘the Choctaw of Louisiana.’’ Accordingly, it deferred to Abramoff and Scanlon’s judgment when they 

recommended that it fund very expensive grassroots campaigns. 

Ultimately, having collected about $30,000,000 from the Louisiana Coushatta during the relevant period, Scanlon secretly 

kicked back to Abramoff about $11,450,000—about 50 percent of 

his total profit from the Tribe. This includes a payment of 

$1,000,000 that Abramoff and Scanlon manipulated the Tribe into 

paying to CAF, Abramoff’s private charity. 

Discussion and analysis of how Abramoff and Scanlon successfully perpetrated their ‘‘gimme five’’ scheme on the Tribe, on an entity-by-entity basis, is contained below in Part 2 of this Report. 

(45) 

1 Email from Jack Abramoff, Greenberg Traurig, to Shana Tesler, Greenberg Traurig (GTG– E000028361) (February 9, 2004). 2See, e.g., ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th 

Cong. at 23 (September 29, 2004) (testimony of Tribal Sub-Chief Bernie Sprague). 3 A full discussion as to how Abramoff and Scanlon did so with regard to the Agua Caliente 

is contained infra in Part 1, Chapter 4, ‘‘Agua Caliente Band of Cahuilla Indians.’’ 4See e.g., Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol 

Campaign Strategies (no Bates number) (April 17, 2001) (produced by Capitol Campaign Strategies). Here, Abramoff advises Scanlon, ‘‘It is critical that you run the [Louisiana Coushatta] 

chairman’s campaign, and that he wins! We’re charging these guys up the wazoo, so this will 

be the key deliverable. Make sure you bill your hours like a demon. Almost no one else is billing 

this client yet, so there is plenty of room. You should be able to qualify for a hefty bonus just 

on this one ...’’ Id. And, Scanlon replies, ‘‘I will bill away! I need that bonus to by [sic] me a 

brand new cadillac!’’ Id. 

CHAPTER III 

SAGINAW CHIPPEWA TRIBE OF MICHIGAN 

Don’t forget to get to [Saginaw Chippewa Sub-Chief David] 

Otto and set up a meeting asap. We need that moolah. We 

have to hit $50M this year (our cut!). 

Email from Jack Abramoff to Michael Scanlon, January 16, 2002 

Understanding tribal politics, and keeping our people in 

power, is the priority of client management. 

Email from Jack Abramoff to associate Todd Boulanger, May 30, 2002 

We do a recall, election and take over. Let’s discuss. 

Email from Jack Abramoff to associate Jon van Horne, February 14, 2002 

A. INTRODUCTION

Among the documents obtained by the Committee is an email, 

dated February 9, 2004, in which Abramoff authorized his associate, Shana Tesler, to pay the legislative director of the Saginaw 

Chippewa Indian Tribe (‘‘Saginaw Chippewa’’), Christopher Petras, 

$2500 of Abramoff’s own money to help the former Chief of that 

Tribe with a recall effort there.1 This exchange reflects the end of 

Abramoff and Scanlon’s aggressive campaign to keep the Saginaw 

Chippewa as a client. 

Their approach was to insinuate themselves into internal tribal 

matters by influencing tribal elections to secure lucrative contracts 

from the Tribe—a strategy that most observers who have discussed 

the matter with the Committee agree is egregious.2

Abramoff and Scanlon successfully secured tribal business in this 

way from not only the Saginaw Chippewa but also the Agua 

Caliente Band of Cahuilla Indians (‘‘Agua Caliente’’).3 There are 

also fragments of information that suggest that they might have 

done so with the Coushatta Tribe of Louisiana (‘‘Louisiana 

Coushatta’’).4 But Abramoff and Scanlon’s representation of the 

Saginaw Chippewa presents what may be the most compelling case 

of how they did so to further their ‘‘gimme five’’ scheme. 
46 

5Ojibwe History (visited March 20, 2006) <http://www.tolatsga.org/ojib.html> (detailing the history of the Ojibwe peoples). 6The Saginaw Chippewa Tribe of Michigan (visited March 16, 2006) <http://www.itcmi.org/ 

thehistorytribal6.html> (discussing the history of the Saginaw Chippewa). 7 Brief History of the Saginaw Chippewa Indian Tribal Culture (visited March 20, 2006) <http://www.sagchip.org/culture/index.htm> (providing the history of the Saginaw Chippewa); 

The Saginaw Chippewa Tribe of Michigan (visited March 16, 2006) <http://www.itcmi.org/ 

thehistorytribal6.html> (discussing the history of the Saginaw Chippewa). 8 U.S. Census Bureau Profile of General Demographic Characteristic of the Saginaw Chippewa (visited March 20, 2006) <http://factfinder.census.gov/servlet/QTTable?lbm=y&- 

reg=DECl2000lSFAIANlDP1:04S|53S &-qrlname=DECl2000lSFAIANlDP1&-dsl name=DECl2000lSFAIAN&-geolid=01000US&;llang=en&-format=&-CONTEXT=qt> (list- ing the population of people claiming Saginaw Chippewa heritage). 9 Id. 

10 Id. 11Ojibwe History (visited March 20, 2006) <http://www.tolatsga.org/ojib.html> (detailing the history of the Ojibwe peoples). 12 Brief History of the Saginaw Chippewa Indian Tribal Culture (visited March 20, 2006) <http://www.sagchip.org/culture/index.htm> (providing the history of the Saginaw Chippewa); 

Where You Live: Saginaw Chippewa Indian Tribe (visited March 21, 2006) <http:// 

www.epa.gov/region5/tribes/tribepages/saginaw.htm> (providing a brief history of the Saginaw Chippewa). 13The Saginaw Chippewa Tribe of Michigan (visited March 16, 2006) <http://www.itcmi.org/ 

thehistorytribal6.html> (discussing the history of the Saginaw Chippewa). 14 Id. 15Soaring Eagle Casino Has Soared Over $3 Billion Since Opening in 1998 (visited March 

20, 2006) <http://www . mybaycity . com/scripts/ArticlelViewB . cfm?ArticleID=499& 

NewspaperID=0> (discussing the success of the Soaring Eagle Casino). 16 Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (September 13, 2004). See also Michigan’s Tribal Gaming Industry Continues to Grow (visited March 20, 2006) <http://www.casinocitytimes.com/article.cfm? 

ContentAndContributorID=17588> (discussing the growth of the Soaring Eagle Casino); Tribal 

quality of life boosted by casino revenues (visited March 20, 2006) <http:// 

www.indiancountry.com/content.cfm?id=1096412563> (discussing the expansion of the Soaring Eagle Casino). 

B. BACKGROUND ON THE TRIBE

The Saginaw Chippewa’s traditional homelands comprise all of 

Michigan and parts of Canada.5 Their current reservation, Isabella 

Reservation, was established under the Treaty of October 18, 1864, 

and is adjacent to the city of Mt. Pleasant, Michigan.6 The Saginaw 

Chippewa Indian Tribe traces its roots to three bands of Ojibwa 

Anishnabek known as the Saginaw, Swan Creek, and Black River 

Bands of Chippewa Indians.7 According to the 2000 census, the 

tribal population is 3,102.8

The Chippewa are a classical Woodlands culture and their language stems from the Algonquian family; therefore, they were 

hunter-gathers and practiced horticulture. Traditionally, they grew 

rice and made sugar, hunted and fished, and later became adept 

fur traders.9 There are approximately fifteen to twenty clans traced 

through paternal lineage that make up the tribal social network.10

Although the Saginaw Chippewa share a common dialect, culture, 

tradition, and spiritual practices with other Michigan Chippewa, 

they are a distinct social group.11

In 1937, the Tribe, reorganized under the Indian Reorganization 

Act, created the current Tribal government.12 The Tribal Council 

consists of twelve members elected from three electoral districts 

and includes the chief, sub-chief, treasurer, and secretary.13 In 

1993, the Tribe signed a gaming compact with the State of Michigan.14 Soon thereafter, it opened the Soaring Eagle Resort and Casino.15 The Tribe added and opened its 512 room hotel and entertainment complex in 1997.16 The Soaring Eagle Resort and Casino 

is one of the biggest Indian casinos in the nation with estimated 
47 

17 Casino rivals step up efforts to lure gamblers (visited March 20, 2006) <http:// 

gamblingmagazine.com/articles/27/27–126.htm> (estimating Soaring Eagle Casino’s revenue); 

Tribe, region benefit from casino revenues (visited March 20, 2006) <http://www.sagchip.org/ 

tribalobserver/article.asp?article=1204> (providing an estimate of Soaring Eagle Casino’s rev- enue). 18Soaring Eagle Casino Has Soared Over $3 Billion Since Opening in 1998 (visited March 

20, 2006) <http://www . mybaycity . com/scripts/ArticlelViewB . cfm? 

ArticleID=499&NewspaperID=0> (discussing the success of the Soaring Eagle Casino). 19 ‘‘Tribal Lobbying Matters’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 39 (September 29, 2004) (testimony of Christopher Petras, former legislative director, Saginaw 

Chippewa Indian Tribe). 20 Id. 21 Id. at 38. 22 Id. at 47. 23See id. at 39. 24See id. 25 Id. 26 Id. 27 Id. 28 Email from Steven Braga, Esq., Baker Botts, to Saginaw Chippewa Indian Tribe (no Bates number) (March 30, 2006) (conveying responses from Scanlon to questions posed by Tribe). 29 Interview of David Otto, former Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (August 27, 2004). 30 ‘‘Tribal Lobbying Matters’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 39 (September 29, 2004) (testimony of Christopher Petras, former legislative director, Saginaw 

Chippewa Indian Tribe). 

revenue of approximately $400 million per year.17 The Tribe currently employs over 4,000 people.18

C. CHRISTOPHER PETRAS—ABRAMOFF AND SCANLON’S ACCESS TO THE

TRIBE

Sometime during 1998, Christopher Petras was approached at a 

concert at the Soaring Eagle Resort about submitting an application to the Tribe’s newly created Legislative Affairs Department.19

At the time, Petras, who is not a tribal member, ‘‘had been teaching political science and was familiar with Government processes 

to some extent.’’ 20 In December 1999, Petras was hired by the 

Tribe as a policy research analyst for five years and later served 

as the Tribe’s director of legislative affairs.21 According to Petras, 

his responsibilities were ‘‘[t]o basically work with the Tribal Council on policy issues [and] conduct research.’’ 22 Whereas Tribal legislative assistant Kim Sawmick covered state issues for the Tribe, 

Petras focused on federal legislative matters. 

According to Petras, in 2000, Sawmick told him that the Tribal 

Council was interested in looking for representation in Washington, 

D.C. to work with its other lobbyist Larry Rosenthal, who was then 

one of Abramoff’s keenest competitors.23 In 1999, the Tribe had 

hired Rosenthal to serve as its Democratic lobbyist; the Tribe was 

now looking for a new Republican counterpart.24

Petras went on the Internet and typed in ‘‘cue words, basically 

‘tribes’ and ‘lobbyist.’ ’’ 25 Of the names that came up, he contacted 

three firms and traveled with Sawmick to D.C. to meet with 

them.26 Around May 2000, they met Abramoff, who was then at 

Preston Gates Ellis & Rouvelas Meeds.27 During that meeting, 

Abramoff brought in Scanlon.28 In his interview with staff, thenSub-Chief David Otto recalled that Abramoff gave an ‘‘impressive’’ 

presentation to the Tribal Council.29 According to Petras, after that 

meeting, Sawmick recommended that the Tribe bring Abramoff in 

for an interview, which led to a decision by the Tribal Council to 

hire Abramoff.30
48 

31 Interview of David Otto, former Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, 

D.C. (August 27, 2004). 32 Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, 

D.C. (September 13, 2004). Sprague also recalled that sometime after June 2002 Petras told him 

that Abramoff ‘‘was working with [then-House Whip] Tom DeLay’’; ‘‘was good friends with Tom 

DeLay’’; and ‘‘had good relations with Tom DeLay.’’ Id. 33 Email from Jack Abramoff, Greenberg Traurig, to Ronald Platt and Shawn Vasell, Greenberg Traurig (GTG–E000027597) (January 22, 2001). 34 Id. 35 Id. 36 Id. 37 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000028079) (October 4, 2001). 38See id. 

But, Otto and current Tribal Sub-Chief Bernie Sprague recalled 

differently. Otto remembered that Petras actually recommended 

Abramoff as his choice for the job.31 And, Sprague told staff, in his 

interview, that Petras ‘‘brought in’’ Abramoff.32

By January 2001, with the Tribe having already hired Abramoff, 

members of the Tribal Council discussed retaining Rosenthal as its 

Washington representative.33 Abramoff complained to his colleagues at Greenberg Traurig, ‘‘I had a discussion with [the Tribe’s 

legislative director] Christopher Petras today. [Competitor] Larry 

Rosenthal has been bad mouthing us non-stop and it is getting increasingly difficult for Chris to maintain our position. Larry is 

going to be hired and he offered me a chance for us to bid on getting them money for a school.’’ 34

Abramoff continued: ‘‘I told him we were not interested in this 

arrangement, that we have serious tribal clients who understand 

the value of our efforts and that if members of his council are insisting that they plight their trough [sic] with Larry, he should do 

so and I wish him luck.’’ 35

However, Abramoff predicted that the Tribe would be back: 

‘‘Frankly, given the animus of our Hill and new Administration 

friends ... we need not get anywhere near this problem. After the 

Saginaws are told by our friends how dead they are, and after their 

appropriations are zeroed out, they’ll be back.’’ 36

With that, the Tribe discontinued using Abramoff as its lobbyist. 

Likely having realized that the only way he could resume representing the Tribe (and getting the Tribe to hire Scanlon) was 

through a change in Tribal leadership, Abramoff came up with an 

idea. 

D. THE ‘‘SLATE OF EIGHT’’—ABRAMOFF AND SCANLON’S TROJAN HORSE

On or about October 4, 2001, Abramoff had a meeting with 

Petras, during which they discussed the Tribe’s upcoming election.37 Later that night, Abramoff brought Scanlon up-to-speed: ‘‘I 

had dinner tonight with Chris Petras of Sag Chip. He was salivating at the $4–5 million program I described to him (is that 

enough? Probably not).’’ 38

Abramoff laid out his plan: ‘‘They have their primary for tribal 

council on Tuesday, which should determine if they are going to 

take over (general elections in November). I told him that you are 

the greatest campaign expert since ... (actually, I told him that 

there was no one like you in history!). He is going to come in after 
49 

39 Id. 40 Id. (emphasis added). 41 Id. 42 Interview of David Otto, former Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (August 27, 2004). 43See Interview of David Otto, former Sub-Chief, Saginaw Chippewa Indian Tribe, in Wash- ington, D.C. (August 27, 2004); see also Capitol Campaign Strategies document production (no Bates number) (October 26, 2001) (Draft Flier, ‘‘Tribal Council Members Otto and Kahgegab Announce Formation of New Slate of Candidates to run [sic] in Saginaw Chippewa Tribal Elections—Slate of 8 Will Run on Platform of Reform’’); Capitol Campaign Strategies document production (no Bates number) (November 15, 2001) (another Draft Flier, entitled ‘‘Slate of 8’’); Capitol Campaign Strategies document production (no Bates number) (April 7, 2002) (Draft Press 

Release, entitled ‘‘Chief Maynard Kahgegab, Jr. and Saginaw Chippewa Tribal Council Host 

Second Community Meeting’’); Capitol Campaign Strategies document production (no Bates 

number) (April 7, 2002) (Draft Talking Points for Chief Maynard Kahgegab, Jr.); Capitol Campaign Strategies document production (no Bates number) (August 26, 2002) (Draft Community 

Meeting Agenda); Capitol Campaign Strategies document production (no Bates number) (October 30, 2002) (Draft Press Release, entitled ‘‘Zogby Poll says Michigan Voters Trust Tribes, Oppose More Gaming’’); Capitol Campaign Strategies document production (no Bates number) (undated) (Draft Flier, from ‘‘David Otto, Slate of 8 Member,’’ entitled ‘‘Slate of 8’’); Capitol Campaign Strategies document production (no Bates number) (undated) (another Draft Press Release, ‘‘Tribal Council Members Otto and Kahgegab Announce Formation of New Slate of Candidates to run [sic] in Saginaw Chippewa Tribal Elections—Slate of 8 Will Run on Platform of 

Reform’’); Capitol Campaign Strategies document production (no Bates number) (undated) (Draft 

Mailer from Chief Maynard Kahgegab to Mr. John Doe); Capitol Campaign Strategies document 

production (no Bates number) (undated) (Draft Mailer conveying ‘‘brief update’’ by Chief 

Kahgegab to Tribal Members). 44 Interview of David Otto, former Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (August 27, 2004). 45 Id. 46 Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (September 13, 2004). 47 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000028054) (October 11, 2001) (emphasis in original). 

the primary with the guy who will be chief if they win (a big fan 

of ours already) and we are going to help him win.’’ 39

Using a phrase the two coined to describe their financial relationship, Abramoff concluded, ‘‘If he wins, they take over in January, and we have millions. I told him that you are already in national demand and we need to secure you for them. He is very excited. GIMME FIVE lives.’’ 40

Scanlon replied enthusiastically, ‘‘THE PRICE HAS JUST GONE 

UP TO 10 MIL! Sounds good on the strategy—We should be 

wrapped up with the other camapigns [sic] soon, so I could run his 

general election to make sure we get or [sic] give me five!’’ 41

Apparently resolved to help Abramoff and Scanlon oust the incumbent Tribal Council, Petras recommended to a group (comprised of, among others, Maynard Kahgegab and Robert Pego) that 

they meet with Scanlon about their election campaign.42 That 

group became known as the ‘‘Slate of Eight.’’ 43 Otto believes that 

Petras came up with the ‘‘Slate of Eight’’ concept and remembers 

Petras telling him that this was how the Mississippi Band of Choctaw Indians ran its elections.44 In fact, Otto recalled, Petras said 

that Scanlon helped on that Tribe’s elections.45 Tribal Sub-Chief 

Bernie Sprague believes that Petras was only there to work for 

Kahgegab and, originally, Otto (who was running for the position 

of Sub-Chief).46

A few days after his meeting with Petras and a telephone call 

from Otto, Abramoff reached out to Scanlon: ‘‘MIKE, CALL ME AT 

HOME ASAP. THIS IS ON SAGINAW CHIPPEWA. TIME FOR 

BUCKS!!!’’ 47

Approximately three weeks before the general election for the 

Tribal Council, sometime in July or August 2001, Scanlon met with 
50 

48 Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (September 13, 2004). See also Interview of David Otto, former Sub-Chief, Saginaw Chip- pewa Indian Tribe, in Washington, D.C. (August 27, 2004). 49 Email from Steven Braga, Esq., Baker Botts, to Saginaw Chippewa Indian Tribe (no Bates number) (March 30, 2006) (conveying responses from Scanlon to questions posed by Tribe). 50 Id. 51 Id. 52 Interview of David Otto, former Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (August 27, 2004). 53 Id. 54 Id. 55 Id. 56 Id. 57 Id. 58 Id. 59 Id. 60 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘State of 8’’) (undated). 61 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Tribal 

Council Members Otto and Kahgegab Announce Formation of New Slate of Candidates to run 

in Saginaw Chippewa Tribal Elections’’) (October 26, 2001). 62 Id. 63 Id. 

Petras as well as Otto and some of the other candidates, in Michigan for a ‘‘strategy meeting.’’ 48 Petras, who set up the meeting, told Otto that Scanlon could help show them how to get elected.49

The purpose of the meeting, which was held at a Bob Evans restaurant, was to help them craft a campaign for that race.50 During that meeting, the idea of the Slate of Eight was hatched—Petras 

made up the slate concept and Scanlon made up the name.51

Petras, Scanlon and Otto discussed the upcoming elections, election 

strategy, how to get their names out, and issue mailers.52 Both 

Scanlon and Petras gave advice at that meeting.53 Afterwards, Otto 

reported to the other members of the Slate of Eight who were not 

in attendance, on his meeting with Petras and Scanlon.54 At that 

follow-up meeting, they discussed how Scanlon could help them get 

elected.55

Otto did not recall whether there was an express quid pro quo 

between Scanlon and the Slate of Eight during the strategy meeting.56 It was certainly generally understood that Scanlon would help Otto and the other members of the Slate of Eight in the election.57 In addition, he conceded, there was a ‘‘non-verbal understanding that Scanlon would like a chance to work for the Tribe.’’ 58

At least two batches of mailings were sent out on behalf of the Slate of Eight.59 Among the documents obtained by the Committee from Scanlon’s company, Capitol Campaign Strategies (CCS), is an 

undated draft mailer, apparently drafted for the Slate of Eight. It 

notes that ‘‘[t]he upcoming election may be the only chance for the 

disenfranchised, [sic] and beaten down members of this tribe to 

voice their disapproval with the way people on the council like 

XXXX [sic] Jackson have run our tribal government.’’ 60 Likewise, 

an October 26, 2001, press release, also apparently drafted by CCS, 

announced that the ‘‘Slate of 8 Will Run on Platform of Reform.’’ 61

According to that release, ‘‘The Slate of 8 represents honesty, integrity and vision—something that the Committee for Responsible 

Government unfortunately completely lacks.’’ 62 It also stated falsely that ‘‘[w]e organized the Slate of 8 ourselves and are asking the 

tribal members to vote for us so that we can put the scandal 

plagued [sic] politics of this tribe [sic] in the past.’’ 63 In laying the 

groundwork for the Tribe to ultimately hire Abramoff and Scanlon, 
51 

64 Id. 65Deposition of Brian Mann, former director, American International Center, in Washington, D.C. (March 31, 2005). 66 Id. 67 Id. 68 Id. 69 Id. 70 Id. 71 Id. 72 Interview of David Otto, former Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (August 27, 2004). 73 Id. 74See Interview of Christopher Cathcart, former associate, Capital Campaign Strategies, in Washington, D.C. (October 6, 2004); Email from Steven Braga, Esq., Baker Botts, to Saginaw 

Chippewa Indian Tribe (no Bates number) (March 30, 2006). 75 Interview of David Otto, former Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (August 27, 2004). 76 Email from Steven Braga, Esq., Baker Botts, to Saginaw Chippewa Indian Tribe (no Bates number) (March 30, 2006) (conveying responses from Scanlon to questions posed by Tribe). 

Interview of David Otto, former Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, 

D.C. (August 27, 2004). 77 Email from Steven Braga, Esq., Baker Botts, to Saginaw Chippewa Indian Tribe (no Bates number) (March 30, 2006). 78 Id. 

the release also described, as an issue on the Slate of Eight’s platform, ‘‘developing stronger ties in Washington D.C. [sic] and at the 

state and local level to advance tribal concerns.’’ 64

In connection with the Slate of Eight campaign, then-Scanlon associate, Brian Mann, served as a liaison between Petras and Scanlon.65 In his deposition, Mann recalled ‘‘being in contact with Chris 

Petras, creating fliers or letters that we would mail back to Chris 

on Maynard’s behalf.’’ 66 There can be no doubt that Petras was 

leading this effort. Mann ‘‘was employed ... [t]o catch up with 

Petras and help facilitate whatever it was that he wanted to be 

done.’’ 67 Apparently, Scanlon provided Mann with between three 

and five designs for mailers, which Mann faxed to Petras for his 

approval.68 Because Scanlon’s company did not have an in-house 

graphic design capability, those designs that had graphics were 

likely generated by an outside vendor.69 According to Mann, ‘‘[A] 

couple of times [Petras] didn’t like the wording for something. He 

wanted something darker or something bigger, just kind of, you 

know, trying to tweak whatever it was.’’ 70 There were about three 

to five such exchanges before Petras finally approved the designs.71

At some point, a box of mailers arrived at Kahgegab’s house—mailers for the election that the Slate of Eight never paid for.72 All Otto 

had to do was to put addressed stickers on the mailers.73

Not only did CCS draft mailers and fliers, it put together a call 

list; devised a campaign strategy, calendars, and time-lines; helped 

organize at least one event—a ‘‘candidates night’’; and apparently 

recorded a radio ad.74 Other than $200 that some members of the 

Slate of Eight paid for a ‘‘candidates night,’’ CCS paid for all outof-pocket expenses.75 While the value of those expenses is unclear, 

the Tribe has seen some estimates as high as $100,000.76 Responding to the Tribe for Scanlon, Scanlon’s lawyer, Stephen Braga, explained that ‘‘[t]his $100,000 number was a value reflected estimate that included the time value of individuals working on the 

campaign’’ and that ‘‘actual dollars would be less.’’ 77 He however 

agreed that, while ‘‘there is no way to tell exactly how much was 

spent,’’ CCS was never reimbursed for its costs.78
52 

79 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000012235) (October 30, 2001). 80 Id. 81 Id. 82 Id. 83 Interview of David Otto, former Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, 

D.C. (August 27, 2004). 84 Id. 85 Id. 86 Id. 87See Interview of Brian Mann, former director, American International Center, in Washington, D.C. (March 3, 2006); Interview of Christopher Cathcart, former associate, Capital Campaign Strategies, in Washington, D.C. (October 6, 2004). See Capitol Campaign Strategies document production (no Bates number) (undated) (Draft Power Point Slides, ‘‘Saginaw Chippewa 

Indian Tribe of Michigan, ‘‘Chief’s Report’’); Capitol Campaign Strategies document production 

(no Bates number) (Draft Speech, entitled ‘‘7:00 p.m.—Chief’s Report’’) (undated). 88 Capitol Campaign Strategies document production (no Bates number) (November 8, 2001) 

(entitled ‘‘Invoice from Weber Company, to Scanlon Gould Public Affairs for $3,278.65 of expenses’’). 89 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000012251) (November 2, 2001). 90 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (November 5, 2001) (GTG–E000012287). What the other election was, is unclear. 

As the election at the Saginaw Chippewa neared, Abramoff asked 

Scanlon for a status update: ‘‘When exactly is their election? Do 

you have a guy up there?’’ 79

Providing Abramoff with a document entitled ‘‘Slate of Eight Political Calendar,’’ Scanlon replied: ‘‘Election is next Tuesday—I 

have a guy on the ground, 2 more heading up for the final push 

on Friday, and 4 mail pieces including personalized letters from the 

candidates hitting between tomorrow and election day. Attached is 

our campaign calendar.’’ 80

Scanlon was optimistic about success: ‘‘If we don’t win after all 

this—we never had a chance!’’ 81

Seemingly pleased, Abramoff replied: ‘‘Looks like you have it well 

in hand. I smell victory! I smell gimme five!!!’’ 82

The ‘‘guy on the ground’’ that Scanlon referred to above was his 

top assistant, Christopher Cathcart. Scanlon apparently sent 

Cathcart to Michigan to do some ‘‘hand holding,’’ specifically, helping the Tribe with any needs and requests and to provide additional guidance.83 Otto understood that CCS was ‘‘handling the 

Slate of Eight’’ like a major election.84 On election night, Cathcart 

joined Otto and the Slate of Eight at a local Bennigans restaurant.85 According to Otto, Cathcart met and drove around with 

him and Kahgegab that evening.86

CCS associate Amy Biederman was assigned to write speeches 

for Slate of Eight member Maynard Kahgegab.87 Additionally, according to invoices from the Weber Company, an issues-management and grassroots lobbying firm that Scanlon sub-contracted, Joe 

Weber, from that firm was involved in the Saginaw Chippewa Tribal election and was actually there on October 25, 26, 30, and 31, 

2001.88 However, exactly what services the Weber Company provided Scanlon’s company in connection with the Slate of Eight’s 

campaign, is unclear. 

A few days later, Abramoff reminded Scanlon: ‘‘don’t forget!!! Ballot security at Saginaw!!!!’’ 89 Abramoff was concerned, because he 

could not ‘‘handle losing two elections in the space of 4 days!’’ 90
53 

91 Interview of David Otto, former Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, 

D.C. (August 27, 2004); Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian 

Tribe, in Washington, D.C. (September 13, 2004). 92 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Slate of 8’’) (November 15, 2001). 93 Email from Michael Scanlon, Capitol Campaign Strategies, to Robin Axline, Christopher Cathcart, Aaron Stetter and Patrick Gould, Capitol Campaign Strategies (GTG–E000002297) 

(November 7, 2001). 94 Id. 95 Id. (emphasis added). 96 Id. 97 Id. 98 Email from Jack Abramoff, Greenberg Traurig, to Fred Baggett, Todd Boulanger, Rodney 

Lane, Stephanie Leger, Ronald Platt, Kevin Ring, Tony Rudy, Alan Slomowitz, Shawn Vasell 

and Michael Williams, Greenberg Traurig (GTG–E000028114/GTG–E000028115) (November 6, 

2001). 99 Id. 100 Id. 

On November 6, 2001, all but one member of the Slate of Eight 

prevailed.91 A draft mailer, apparently prepared by CCS, dated November 15, 2001, announced the victory: ‘‘The election on November 6 was an historic event for the Saginaw Chippewa Tribe. It was 

the day the people of this tribe swept away the politics of the past, 

and started a new era of positive and responsible government.’’ 92

On the evening of the election, Scanlon emailed his employees, 

congratulating them for their participation in the campaign: ‘‘Well 

team ... Last night was amazing—The slate of 8 kicked ass, and I 

want to thank all of you for helping out—and watching the bottom 

line.’’ 93

He heaped more praise: ‘‘We had less than three weeks to take 

8 guys we never met before and get them [sic] elected. It was a 

great plan, and great execution by a great team. Just to recap, we 

elected 7 out of our slate of 8—and the last guy—Ray Davis missed 

it by ONE vote. We did get another one of our allies elected in District 2, and we now control 9 out of the 12 seats on the council.’’ 94

Alluding to his and Abramoff’s original plan, Scanlon concluded, 

‘‘Maynard [Kahgegab] will be elected Chief at the organizational 

meeting on December 4th, and hopefully we will be doing some 

more work for the tribe in the near future. THIS MAKES US 2– 

0 in tribal elections this year!’’ 95

He concluded, ‘‘Great work again—and by the way the last time 

I saw Chris he was doing Tequila shots with Dave Otto at the 

Bennigans in Mt. Pleasant, Michigan—If anyone hears from him— 

tell him to get back to the office—we have a referendum to win in 

Louisiana!’’ 96

Having been forwarded this email string from Scanlon, Abramoff 

enthusiastically replied, ‘‘I love it!’’ 97

On the day of the election, Abramoff reported to his colleagues 

at Greenberg Traurig: ‘‘I just got off the phone with Chris Petras, 

government affairs head for the Saginaw Chippewa. Today they 

had their election.’’ 98

He openly stated, ‘‘We had Scanlon up there running our 

slate.’’ 99

He concluded, ‘‘We won 7 of the 8 slate positions and now control 

the council! Our guys will be Chief and Sub-Chief. Chris will head 

the 1 month transition and we will be on board as soon as they are 

in. I figure the representation will be $100–$150k/month.’’ 100 During his interview with Committee staff, the head of Greenberg 
54 

101 Interview of Fred Baggett, Chair, National Government Affairs Practice, Greenberg Traurig, in Washington, D.C. (September 29, 2005). 102 Interview of David Otto, former Sub-Chief, Saginaw Chippewa Indian Tribe, in Wash- ington, D.C. (August 27, 2004). 103 ‘‘Tribal Lobbying Matter,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 53 (September 29, 2004) (prepared statement of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe). 104Saginaw Chippewa document production (no Bates number) (Engagement Letter from Jack 

Abramoff, Greenberg Traurig, to Chief Maynard Kahgegab, Saginaw Chippewa Indian Tribal 

Council) (December 6, 2001). 105Saginaw Chippewa document production (no Bates number) (Engagement Letter from Jack 

Abramoff, Greenberg Traurig, to Chief Maynard Kahgegab, Saginaw Chippewa Indian Tribal 

Council) (December 4, 2002); Interview of David Otto, former Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (August 27, 2004); Interview of Bernie Sprague, Sub-Chief, 

Saginaw Chippewa Indian Tribe, in Washington, D.C. (September 13, 2004). 106 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000024627) (January 14, 2002). 

Traurig’s national lobbying practice, who among others received 

that email, could not recall having read it.101

Regarding the ‘‘Slate of Eight,’’ the evidence described above supports the following conclusion: there was at least a mutual understanding, if not an agreement, that the Slate of Eight would hire 

Scanlon in exchange for, or because of, the work that CCS did on 

its election to the Tribal Council—possibly valued at as much as 

$100,000. This scenario has given rise to ethical concerns within 

the Tribe. In his interview with staff, Otto noted that Petras, who 

was not a member of the Tribe, was not part of its public relations 

department and, as an employee of the Tribe answerable to the 

Tribal Council, was not supposed to get involved in internal leadership disputes.102 The involvement of non-Indians in tribal elections 

is, as another Council Member said, ‘‘unheard of.’’ 103

E. THE TRIBE HIRES ABRAMOFF AND SCANLON

About two days after the seven successful members of the Slate 

of Eight were sworn in, on December 6, 2001, the Saginaw Chippewa hired Greenberg Traurig as its lobbyist in Washington for a 

monthly retainer of $150,000.104 Rosenthal was out. For reasons 

not clear to the Committee, about a year later, the Tribal Council 

voted to increase that retainer to $180,000 per month.105 But, 

there was a delay in the Tribe’s hiring Scanlon, who made a full 

presentation to the Tribal Council in late 2001. According to 

Abramoff, then-Sub-Chief Otto became concerned about how much 

the Tribe was spending on lobbying: 

Just spoke with Petras. He spoke with Otto (can’t believe 

this guy is getting off the rails). Otto is coming to DC on 

the 29th for two days with us (Petras will come too, but 

wants to stay in the background). Otto is bringing his father in law who is from [another tribe]. Otto is concerned 

about them being so far out on the line financially without 

anything to show first. He said that Otto wants to see 

some approps come through first. I told him—and he, 

Petras, agrees—that waiting is ridiculous because it will 

be 9 months before we know about approps, and in the 

meantime they would have blown an incredible opportunity. Anyway, we have to get Otto back on board when 

he is here. Can you do the Wizards game with us on the 

night of the 29th? 106
55 

107 Id. 108 Id. 109 Email between Todd Boulanger, Greenberg Traurig, and Jack Abramoff, Greenberg Traurig 

(GTG–E000024701) (January 18, 2002). 110 Id. 111 Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (September 13, 2004). 112 Id. 113 Interview of David Otto, former Sub-Chief, Saginaw Chippewa Indian Tribe, in Wash- ington, D.C. (August 27, 2004); Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (September 13, 2004). 114See, e.g., id. 

Scanlon expressed irritation about the Tribe’s failure to hire him 

immediately: ‘‘I can’t believe that I spilled blood getting those guys 

elected, and I got stiffed. How incredibly ungrateful. Can they at 

the very least sign me to some kind of deal? I can’t believe they 

laid a goose-egg.’’ 107

However, always optimistic about their partnership prospects, Abramoff offered encouragement: ‘‘We’ll get it!’’ 108

Shortly after the new Tribal Council was installed, it was ru- mored that the ousted Council intended to attempt a take-over: ‘‘[A 

Member’s] office just called Chris and told him that the group that 

got ousted is planning a take-over in the next couple of weeks and 

that the police may not get involved ... so they may need federal 

help. This is all rumor right now, but chris [sic] seemed concerned.’’ 109

Abramoff planned to use this rumor as an opportunity to have 

the Tribe hire Scanlon: ‘‘Tell Chris they have to get their political 

operations on the ground moving and fast. They need Scanlon in 

there to get them organized. We’ll handle the federal side.’’ 110

In the run-up to the Tribe’s hiring Scanlon, Sprague recalled in 

his interview with Committee staff, he specifically asked Abramoff 

about his relationship with Scanlon.111 In response, Sprague remembered, Abramoff only said he knew him and that Scanlon was 

a professional.112 Ultimately, the Tribe executed a contract with 

CCS in February 2002 for $4,000,000, primarily for the development of a political ‘‘database’’ and, according to Otto, another $3.9 

million to use it.113 Over the next two years, the Tribe would pay 

CCS about $10,000,000. The Tribe’s payments to CCS are set forth 

below: 

2/19/02 ............................................................................................. $1,857,000 

4/1/02 ............................................................................................... 1,200,000 

4/17/02 ............................................................................................. 1,050,000 

6/27/02 ............................................................................................. 1,900,000 

8/14/02 ............................................................................................. 500,000 

6/19/03 ............................................................................................. 500,000 

7/18/03 ............................................................................................. 500,000 

8/12/03 ............................................................................................. 500,000 

10/03 ................................................................................................ 2,000,000 

Total ......................................................................................... 10,007,000 

Throughout the relevant period, Abramoff and Scanlon represented that these payments were supposed to fund programs designed to protect the Tribe’s share of Michigan’s gaming market 

and protect its sovereignty from external threats.114

As with all the Tribes, CCS’ grassroots and public relations strategy centered on the development and use of a political database. 

In the case of the Saginaw Chippewa, this strategy was called ‘‘Op-
56 

115 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Operation 

Redwing—A Strategy for making the Saginaw Chippewa Tribe the most dominant political entity in Michigan’’) (December 6, 2001). 116 Id. (emphasis added). 117 Id. 118 Id. 119 Id. 120 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Market 

Share Infringement and Political Analysis’’) (May 18, 2002). 121 Id. 

eration Redwing.’’ According to a draft of the proposal that was 

likely presented to the Tribe, entitled ‘‘Operation Redwing—A 

Strategy for Making the Saginaw Chippewa Tribe the Most Dominant Political Entity in Michigan,’’ the first step to developing a 

successful political strategy ‘‘is to tap into your natural political resources and integrate them into a custom-built political database.’’ 115

It elaborated on a ‘‘Grassroots Database’’: 

We will gather lists of your vendors, employees, tribal 

members etc. (if you approve, customer lists), and we will 

import those lists into your new database. Our computer 

program will match the individuals or businesses with addresses, phone numbers, political registrations and e-mail 

addresses, and then sort them by election districts. The 

districts run from U.S. Senator down to school board and 

once completed, you can tap into this database and mobilize your supporters in ANY election, or on any issue of 

your choosing.116

The proposal separately described a ‘‘Qualitative (opposition) Research Database’’: 

This custom built database acts as the information center 

of Operation Redwing. Over the next six weeks, our team 

will gather qualitative information on any entity who can 

be classified as opposition and enter it into this database. 

The research will include nearly every piece of information 

on the opposition you can imagine. Once gathered, it is 

then sorted by subject matter and made retrievable by a 

phrase search. The information can then be instantly disseminated to any audience we choose such as our universe 

of supporters, the press, third party [sic] interest groups or 

other interested parties.117

According to the proposal, at the end of the day, ‘‘the tribe will 

have built a grassroots army of over 50,000 real voters that it can 

call on for offensive or defensive political efforts.’’ 118 The total cost 

of Operation Redwing, $4,207,000.119

CCS also proposed a ‘‘Market Infringement and Political Analysis’’ that identified ‘‘several serious threats ... throughout the 

[S]tate of Michigan’’ which could threaten the Tribe’s primary business, the Soaring Eagle Casino and Resort.120 Those threats included the land-into-trust applications of the Pokagon Band of Potawatomi Indians and the Huron Band of Potawatomi Indians; the 

prospect that the Gun Lake Band of Potawatomi Indians may get 

a state compact; and various non-gaming expansion initiatives.121

According to the ‘‘Overview’’ of a ‘‘Market Share Infringement and 
57 

122 Id. 123 Id. 124 Id. 125 Id. 126 Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, 

D.C. (September 13, 2004). 127 Id. 128The term ‘‘racino’’ refers to a combined race track and casino. In some cases, gaming available in racinos is limited to slot machines. However, some locations include table games such 

as blackjack, poker, and roulette. Saginaw Chippewa Sub-Chief Bernie Sprague noted that there 

were no meaningful efforts by CCS to stop racinos in Michigan. See Interview of Bernie Sprague, 

Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (June 13, 2006). 129 Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, 

D.C. (September 13, 2004). 130 Id. 131 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Market 

Share Infringement and Political Analysis’’) (May 18, 2002). 

Political Analysis,’’ dated May 18, 2002, that CCS prepared for the 

Tribe, ‘‘[T]he tribe could lose over $100 million annually if two of 

the four facilities become operational.’’ 122 And, ‘‘[i]f all 4 entities 

become operational the financial impact will be devastating, so 

much so that we can not even measure its impact.’’ 123 By contrast, 

in its ‘‘Conclusion,’’ the document states that ‘‘placing a figure on 

such a scenario is extremely difficult to do, but we can say without 

a shadow of a doubt, that if all four of the facilities ... become operational, at the very least the tribe will loose [sic] $200 million dollars annually.’’ 124 The bases of these apparently irreconcilable conclusions are unclear. The cost of this program, an additional 

$3,455,000.125

In his interview with staff, Tribal Sub-Chief Bernie Sprague disagreed with CCS’ analysis. He said that ‘‘[e]veryone knew there are 

three southern [t]ribes that will eventually open casinos’’ and that 

‘‘[they] are in different stages of development.’’ 126 According to 

Sprague, when they open, they will only affect a small percentage 

of the Saginaw’s market, between 10 and 17 percent.127 He noted 

that the Tribe ultimately executed four contracts with CCS, which 

related to (1) building the CCS database; (2) opposing ‘‘racino’’ 128

proposals; (3) opposing pending land-into-trust applications filed by 

competing tribes; and (4) supporting a statewide smoking ban that 

would theoretically drive smokers into the Tribe’s casino.129 However, Sprague recalled that because the Council received only 

vague updates from Petras about the progress of CCS’ work, he 

and other critics of the lobbying contracts were limited in their 

ability to object.130

In furtherance of each ‘‘campaign’’ to oppose gaming competition, 

CCS pledged to ‘‘execute the following tactics’’: grassroots mobilization of environmental and anti-gaming activists; patch-through 

phone calls to governmental environmental protection agencies; 

local advertising highlighting any project deficiencies; direct mail; 

opposition research; mobilization of environmental and ‘‘citizen 

groups’’; federal lobbying efforts on the competitions’ land-into-trust 

application deficiencies; Michigan state lobbying efforts; and polling 

on each facility.131 Analysis as to how most of the money that the 

Tribes paid Scanlon was diverted for unintended purposes is discussed below in Part 2, Chapter 3, ‘‘Capitol Campaign Strategies.’’ 
58 

132 Email from Jack Abramoff, Greenberg Traurig, to Todd Boulanger, Greenberg Traurig 

(GTG–E000026398) (May 30, 2002). 133 Email from Jack Abramoff, Greenberg Traurig, to Todd Boulanger, Greenberg Traurig 

(GTG–E000026141) (February 21, 2002). 134 Email between Jack Abramoff, Greenberg Traurig, and Todd Boulanger, Greenberg Traurig 

(GTG–E000000327) (January 22, 2002). 135 Id. 136 Id. 137 Id. 138 Id. 139 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000024827) (February 6, 2002). 

F. ABRAMOFF ON TRIBAL CLIENT MANAGEMENT—‘‘KEEPING OUR

PEOPLE IN POWER’’ 

Apparently, Abramoff was not content simply to have Tribal 

members supportive of his representation of the Tribe elected to 

the Tribal Council. As he told one of his senior associates, 

‘‘[u]nderstanding tribal politics, and keeping our people in power, 

is the priority of client management.’’ 132 Evidence in the Committee’s possession indicates that Abramoff attempted to interfere in 

internal tribal politics to assure that the Tribe would remain supportive. Abramoff did so primarily by manipulating Petras and 

Petras’ apparent influence over then-Chief Maynard Kahgegab and 

other members of the Slate of Eight. According to Abramoff, Petras 

was his ‘‘one secure ally’’ at the Tribe.133

Abramoff’s machinations began almost immediately. In January 

2002, when Petras requested that Abramoff’s team set up meetings 

with Members of Congress for then Sub-Chief David Otto, one of 

Abramoff’s colleagues inquired whether there was a problem with 

the representation. Abramoff explained, ‘‘[Petras] wants an excuse 

to get Otto to town to make sure he is OK with us. Otto and Maynard are starting to be at contretemps.’’ 134

One of Abramoff associates asked, ‘‘I thought Otto was one of our 

guys?’’ 135

Abramoff answered, ‘‘He is, but there is an ego thing going on 

there. He is not mad at us, but he has been nervous about our getting such a big contract, figuring correctly that their enemies at the 

tribe would be upset. That’s why deliverables are the key.’’ 136

He explained, ‘‘He and Maynard are at odds a bit. The original 

deal was that whoever got the most votes would be chief and the 

next guy would be subchief, as between the two of them. Maynard 

beat him out.’’ 137

Furthermore, Abramoff noted, ‘‘Problem is that Maynard’s style 

needs some work: too much ‘me’ and ‘I’ and not enough ‘we’. David 

just needs to hold our hands again so he is calm on the lobbying 

front.’’ 138

With the Tribe’s casino operations serving as a premium revenue 

source for his secret partnership with Scanlon and even though he 

had co-opted the Tribe’s trusted legislative director, Abramoff was 

keen on shoring up his supporters on the Tribal Council. He told 

Scanlon, ‘‘Regarding Sagchip, we need to present a plan to resolidify these guys politically.’’ 139

And, he intended to travel to the Tribe to do precisely that: ‘‘I 

am going there tomorrow by the way, on the way back from Nevada. Meeting with our slate on the council, chief, subchief, et al 
59 

140 Email from Jack Abramoff, Greenberg Traurig, to Todd Boulanger, Greenberg Traurig 

(GTG–E000025064) (February 12, 2002). 141 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Saginaw 

Chippewa Indian Tribe of Michigan Public Relations Plan’’) (April 5, 2002) (emphasis in original). 142 Id. 143 Id. 144 Id. 145 Id. 146 Id. 147 Id. 

[sic], to make sure they start doing the local political work they 

need to do to stay in power.’’ 140

With the Slate of Eight keenly interested in assuring its incum- bency, CCS appears to have served as an extension of Abramoff’s 

interest in ‘‘keeping [his] people in power.’’ A CCS document, entitled ‘‘Saginaw Chippewa Indian Tribe of Michigan Public Relations 

Plan,’’ dated April 5, 2002, identifies its objective as ‘‘provid[ing] 

the Saginaw Chippewa Tribal Council with the tools and resources 

necessary to successfully and proactively promote their agenda and improve their image among tribal members, the media and legislators.’’ 141

Furthermore, the document states, ‘‘The goal is to make this Tribal Council the most powerful and effective Administration in 

the history of the Saginaw Chippewa Indians of Michigan and secure their reelection.’’ 142

How did CCS intend to do this? CCS’ strategy was ‘‘to arm the Tribal Council with an effective message and the resources needed 

to communicate that message in a clear, accurate and concise fashion ... Each action and activity is conceived to maximize the Tribal 

Council’s visibility and bolster its political capital.’’ 143 In particular, CCS intended to ‘‘identify opportunities to promote the 

Tribal Council’s agenda through targeted media and Saginaw Chippewa-sponsored events and activities.’’ 144 With ‘‘CCS ... 

propos[ing], stag[ing] and help execut[ing] all intra-tribe communications as directed by the council,’’ intra-tribe relations would 

‘‘focus on establishing dialogue between the Tribal Council and 

tribal members, ultimately building a trust that leads to voter capital.’’ 145 Rather cryptically, the plan proposed to have ‘‘CCS ... col- laborate with the Tribal Council to develop a response system for 

the notification of an incident/emergency, as it relates politically.’’ 146 In conclusion, the public relations plan noted that the 

‘‘internal and external strategies outlined above will enable the 

Saginaw Chippewa Tribal Council to effectively communicate their 

agenda, resulting in a successful and highly regarded Administration.’’ 147

In an update memorandum from CCS associate Christopher 

Cathcart to Otto and Petras, dated April 19, 2002, Cathcart described CCS’ efforts to date: 

Our public relations team parachuted in to manage your 

community meeting April 1. As you know, we produced 

and delivered a ‘‘save the date’’ mailer that was mailed the 

week prior to the meeting. Additionally, we were able to 

produce a press release for your internal press person to 

distribute. While in Mt. Pleasant, the CCS team prepared 

Sub-Chief Otto’s and your remarks to the membership and 
60 

148 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Memorandum’’) (April 19, 2002). 149 Email between Michael Scanlon, Capitol Campaign Strategies, and Jack Abramoff, Green- berg Traurig (GTG–E000001168) (May 17 and 19, 2002). 150 Email from Jack Abramoff, Greenberg Traurig, to Chris Petras, Saginaw Chippewa Indian 

Tribe (GTG–E000024973) (February 11, 2002). 151 Email between Christopher Petras, Saginaw Chippewa Indian Tribe, and Jack Abramoff, 

Greenberg Traurig (GTG–E000001142) (February 19, 2002). 152 Id. 

also developed a comprehensive timeline for the entire 

meeting.148

As internal strife began emerging among the Slate of Eight—specifically between Chief Kahgegab and Sub-Chief Otto—Abramoff 

and Scanlon focused on securing their allies on the Council: ‘‘Maynard and David are totally going at it. David has turned on Chris 

and possibly us (or at least is stupid and is the one who has been 

giving out our memos to the council). This could be a good thing 

ultimately if we can get Maynard secured in power, because he is 

now focused on needing us.’’ 149

One tactic the Slate of Eight apparently employed to neutralize 

its opponents on the Tribal Council was to deny them access to important information and meetings. They did so, if not on the advice 

of, then with the encouragement of, Abramoff. For example, when 

Petras reported that ‘‘another Council member or two could be joining’’ a Tribal Council meeting, Abramoff became alarmed: ‘‘This is 

a potential problem! Who might be joining? They have to be totally 

part of the family. We cannot risk that they are in the opposing 

camp. Please let me know what you have in mind as soon as possible. thanks. [sic]’’ 150

Similarly, when Abramoff attempted to convince the Saginaw 

Chippewa to participate in his program to have tribes underwrite 

his use of sky boxes at D.C.-area sporting venues, he and Petras 

discussed limiting information that would be seen by the full Tribal 

Council. Preparing to present that program to the Tribal Council, 

Petras advised Abramoff: 

When I brought up the issue previously, the response was 

it was too soon to ask. However, I just talked to the Chief 

and he said bring the materials over. I have the materials 

but need to know if all can see the documents or if there 

is another document that needs to be typed outlining the 

program and payment costs? Something that says basically 

here is the program, here is what the Tribes use the program for, here is what it will cost total and with quarterly 

payments. I need a document that everyone who would be 

utilized throughout the process can see. Thanks.151

Abramoff advised shutting out the opposition to the greatest extent possible: ‘‘Can you hand out the invoice (but only to the slate 

[sic] of 8) and just read them the memo? The opposition should just 

hear this at the table orally and get nothing in writing. Will that 

work?’’ 152

Abramoff even attempted to control the Tribe’s external relations 

with other tribes. For example, when the Saginaw Chippewa’s leadership prepared to meet with the leadership from the Mississippi 
61 

153 Email from Jack Abramoff, Greenberg Traurig, to C. Bryant Rogers, Roth, Van Amberg, Rogers, Ortiz & Yepa (GTG–E000001146) (February 18, 2002). 154 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Saginaw Chippewa Indian Tribe of Michigan Communications Program 2003’’) (2003). 155 Id. 156 Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (September 13, 2004). 157 Id. 158 Id. 159Letter from Chief Audrey Falcon, Saginaw Chippewa Indian Tribe, to Michael Scanlon, Capital Campaign Strategies (January 23, 2004). 160Letter from Robert K. Tompkins, counsel to Capitol Campaign Strategies, Patton Boggs, to Saginaw Chippewa Indian Tribe (February 6, 2004). 161 Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (June 13, 2006). 

Band of Choctaw Indians, Abramoff attempted to manipulate the 

meetings between the chiefs: 

Chris told me this morning that Cheryl is setting up the 

SagChips [sic] to visit the Choctaws, which is great. it [sic] 

is important that they see how things are done right. 

There is one thing I wanted to mention though. I was told 

that Cheryl might be working to set up a separate meeting 

for Chief Maynard with Chief Martin. Based on the dynamic in the room during our meeting last week, I think 

you could tell that there are some jealousies among the 

group, particularly Sub-Chief Otto and the others feeling 

that Chief Maynard might not be including them in stuff. 

Therefore, I think we should be careful about setting up 

separate meetings and, ideally, keep everyone together for 

everything for now. Let me know if you agree on this. 

Thanks Bryant.153

A draft of CCS’ ‘‘Communications Program’’ for the Tribe, dated 2003, ‘‘briefly recap[s] what CCS, in its public relations role, accomplished [for the Tribe] in 2002.’’ 154 According to this document, ‘‘CCS planned, staged and produced Community Meetings held by 

the Council’’; ‘‘[w]rote speeches for the Chief and other Tribal Members as needed’’; ‘‘[p]repped the Chief and other Tribal Council 

members and fine-tuned speeches.’’ 155 Documents reflecting the work that CCS did for the Tribal Council is attached to the end of 

this Report. 

In December 2003, the Saginaw Chippewa held new elections.156

As a result of those elections, Maynard Kahgegab and the other 

members of the Slate of Eight allies lost their grip on the Tribal 

Council and a new chief and sub-chief were elected.157 The newly elected Tribal Council decided not to retain Abramoff and Scanlon 

as their lobbyist and public relations specialist, respectively.158

Newly elected Tribal Chief Audrey Falcon informed Scanlon of the Tribe’s decision on January 23, 2004, citing CCS’s failure to 

provide reports and work product regarding a state-wide smoking 

ban initiative.159 On February 6, 2004, one of Scanlon’s lawyers, Robert Tompkins of the Washington firm of Patton Boggs, demanded payment of $2,755,000 in connection with the agreement 

relating to the initiative.160 Just days after the election, Petras had also repeatedly tried to get the new Tribal Council to pay Scanlon.161 But, on March 5, 2004, shortly after the Committee an- nounced its investigation, another of Scanlon’s lawyers, Stephen 

Braga of Baker Botts, withdrew Scanlon’s demand, indicating that 
62 

162 Email from Steven Braga, Esq., Baker Botts, to Saginaw Chippewa Indian Tribe (no Bates number) (March 30, 2006) (conveying responses from Scanlon to questions posed by Tribe). 163 Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (September 13, 2004). 164From its internal investigation, the Tribe has found that Petras wrote these pieces. Inter- view of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (June 

13, 2006). 165 Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (September 13, 2004). 166 Email from Steven Braga, Esq., Baker Botts, to Saginaw Chippewa Indian Tribe (no Bates number) (March 30, 2006) (conveying responses from Scanlon to questions posed by Tribe). 167 Email from Todd Boulanger, Greenberg Traurig, to Jack Abramoff, Michael Smith, Kevin Ring and Michael Williams, Greenberg Traurig (GTG–E000028359) (February 9, 2004). 168See Email from Steven Braga, Esq., Baker Botts, to Saginaw Chippewa Indian Tribe (no Bates number) (March 30, 2006) (conveying responses from Scanlon to questions posed by 

Tribe). 169 Email from Todd Boulanger to Jack Abramoff, Michael Smith, Kevin Ring, Shawn Vasell and Michael Williams, Greenberg Traurig (GTG–E000028361) (February 9, 2004). 

‘‘[CCS] has no desire to try to force this contractual relationship 

forward with an unwilling party.’’ 162

Opposition to the new ruling bloc in the Tribal Council began cir- culating ‘‘hit pieces’’ around the Tribe, attacking newly elected 

Chief Audrey Falcon, Sub-Chief Bernie Sprague, and others.163

While who authored those pieces is unclear to the Committee, the 

Committee understands that, as a result of its own internal investigation, the Tribe has attributed them to Petras.164

In an attempt to regain power, former Chief Maynard Kahgegab and former Sub-Chief Robert Pego sought to have the new council 

recalled.165 Information obtained by the Committee suggests that Abramoff and Petras were involved in the recall effort. Apparently, 

on several occasions, they approached Scanlon about helping with 

that effort.166 An email from Boulanger to other members of Abramoff’s lobbying team, in February 2004, describes Abramoff’s 

work with the ousted leadership against the duly elected members 

of the Tribe: 

As of Friday, Maynard had just under 200 signatures for 

the recall petition (250 is required). They are going to get 

300 just to be sure. This was completed in less than one 

week, which is highly unusual because the Saginaw are a 

very slow moving tribe. Diana, who was originally on 

Maynard’s team and then switched to Bernie has finally 

come back into the fold. Her family was planning on signing the petition this weekend. Also, two of Bernie’s guys on 

the council are scared and trying to get in Maynard’s good 

graces ... they don’t know that they are also on the recall 

list. Once the recall is completed, we are going to have to 

get a letter to BIA asking that they send monitors, etc, to 

the special election date ... if Robert Pego wins the special 

election on the 11th for the vacant seat, we may actually 

have a majority and can at a minimum get Rosenthal 

fired. This is confidential, obviously.167

With Petras serving as Abramoff’s point man on the recall effort, Abramoff was prepared to help fund it.168 In a status report later 

that day, Boulanger reported: ‘‘They are less than 50 signatures 

short of the recall. Maynard has been pounding them with mailings 

... which to be honest with you, aren’t that bad.’’ 169

He continued, ‘‘They are running out of money for copying, stamps, etc. Petras asked if we could come up with $2500 to help 
63 

170 Id. 171 Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, 

D.C. (September 13, 2004). 172 Email from Jack Abramoff, Greenberg Traurig, to Todd Boulanger, Capitol Campaign 

Strategies (GTG–E000028364) (February 11, 2004). 173See Interview of David Otto, former Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (August 27, 2004); Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (September 13, 2004). 174 Id. (conveying concern about gratuities). 175 ‘‘Tribal Lobbying Matters,’’ Hearing before the Committee on Indian Affairs, 108th Cong. 

at 45 (September 29, 2004). 176 Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, 

D.C. (September 13, 2004). 177 Id. 178 Id. 

them out.’’ 170 Kahgegab and Pego’s efforts, apparently with assistance from Petras and Abramoff, to have the newly elected council 

recalled failed.171

Abramoff was prepared to contribute, instructing associate 

Shana Tesler to get Petras money from one of his accounts, which 

Boulanger carefully specified should be ‘‘cash.’’ Two days later, 

Boulanger reported that Kahgegab would have 300 signatures 

within the next few days.172 The foregoing describes Abramoff and 

Scanlon’s elaborate, albeit unsuccessful, attempts to assure, by further interfering in internal tribal matters, that the Tribe would 

keep them on as its paid representatives. 

G. CHRISTOPHER PETRAS’ HEARING TESTIMONY IS NOT CREDIBLE

On September 29, 2004, former Saginaw Chippewa legislative director Christopher Petras testified before the Committee. The Committee is concerned about the veracity of his testimony. It appears 

that, with his testimony, Petras intended to obscure his contemporaneous relationship with Abramoff and Scanlon and the assistance he gave them in maximizing their interests at the Tribe’s considerable expense. 

1. Petras’ Relationship With Abramoff and Scanlon 

Serving as Abramoff and Scanlon’s primary point of contact with 

the Tribe, Petras proved to be their key to access to the Saginaw 

Chippewa.173 Abramoff and Scanlon apparently obtained Petras’ 

help by assisting in the election of a slate of candidates supportive 

of his promotion to legislative director (and the considerable increase in his salary). Apparently, they also did so by lavishing him 

with attention and favors during his visits to Washington, D.C., including sky box tickets for sporting events and concerts at area stadiums.174 On one such visit, Petras had his photograph taken with, 

separately, President George W. Bush and his chief political advisor Karl Rove.175

Those trips, during which Petras was driven around town in a 

private car and for which his meals and entertainment were expensed back to the Tribe, seem to have been frequent.176 In his 

interview with staff, tribal Sub-Chief Bernie Sprague stated that 

Petras traveled to Washington about every two weeks.177 Sprague 

regarded the purpose of those trips as dubious.178 Former Abramoff 

associate Stephanie Leger Short agreed that Petras was ‘‘around a 
64 

179 Interview of Stephen Leger Short, former associate, Greenberg Taurig, in Washington, D.C. (August 18, 2005). 180 Id. 181 Id. 182 Email between Todd Boulanger, Greenberg Traurig, and Jack Abramoff, Greenberg Traurig (GTG–E000078656) (March 22, 2002). 183 Id. 184 Id. 185 Email from Christopher Petras, Saginaw Chippewa Indian Tribe, to Jack Abramoff, Green- berg Traurig (GTG–E000078774) (July 2, 2002). 186 Email between Jack Abramoff, Greenberg Traurig, and Todd Boulanger, Greenberg Traurig (GTG–E000078773–74) (July 2, 2002). 187 Id. 

lot’’—at least once a month, if not more.’’ 179 In her interview, Short 

described Petras’ visits as ‘‘high maintenance’’ and noted that ‘‘[the 

Greenberg Traurig’s associates] were running out of people [for 

Petras] to meet with, because they had pretty much met with everybody at that point.’’ 180 After a while, the meetings were being set up as ‘‘dog-and-pony shows,’’ she said.181

In fact, Petras’ trips were so frequent and so demanding on Abramoff’s staff, he was regarded as something of a nuisance. This 

is reflected in, for example, a March 22, 2002, email between 

Abramoff senior associate Todd Boulanger. It begins with Petras 

informing Boulanger of his itinerary of an upcoming trip to Washington: 

Todd, I am scheduled to arrive in D.C. on April 9 and returning on the 12th... I have asked Members of the Council to join me and will await their response. However, 

please schedule meetings, [i]ncluding lunch and dinner 

meetings at Signature’s [sic]. Jack had mentioned a possible lunch or dinner with Mr. Norquist on one of the days 

if he is available. If Signature’s [sic] is serving breakfast 

maybe you can schedule a meeting then. Also, I will probably be returning April 15–18th.182

Boulanger was not pleased, writing Abramoff, ‘‘How am I going to schedule six days [of] meetings. This is fucking ridiculous. There 

is no way I can basically take 2 weeks to shuttle him around. This 

has to be dealt with.’’ 183

Abramoff offered some consolation, ‘‘I will set up the Grover 

meeting. What a loser.’’ 184

Similarly, on July 2, 2002, during another visit to Washington, Petras suggested, ‘‘Perhaps on the next visit, you and I can host 

an official for dinner at Signature’s [sic].’’ 185

Abramoff wrote Boulanger, ‘‘Host an official for dinner at Signa- tures? What the hell is this?’’ 186

Boulanger answered, ‘‘U 100 percent need to tell him he can’t come back until post August [sic]. Approps staff are getting mad 

at us.’’ 187

From information obtained by the Committee, it appears that the foregoing was not atypical of Petras’ trips to Washington. During the Committee’s hearing, then-Vice-Chairman Inouye probed what gifts Petras may have received from Abramoff or 

Scanlon while he served as the Tribe’s legislative director: 

VICE-CHAIRMAN INOUYE: Did you receive any gift or remu- neration or compensation from these two men from Washington? 
65 

188 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. 

at 41 (September 29, 2004) (testimony of Christopher Petras, former legislative director, Saginaw Chippewa Indian Tribe). 189See Email from Jack Abramoff, Greenberg Traurig, to Shana Tesler, Greenberg Trauirg 

(GTG–E000028361) (February 9, 2004). 190 Email from Jack Abramoff, Greenberg Traurig, to Holly Bowers, Greenberg Traurig (GTG– E000000008) (July 21, 2003). 191 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 42 (September 29, 2004) (testimony of Christopher Petras, former legislative director, Saginaw Chippewa Indian Tribe). 192 Id. at 40 (emphasis added). 193 Id. at 41. 

MR. PETRAS: All I can recall receiving was a video cameradigital camera, a leather travel document holder and some 

type of slide projection desktop screen. 

VICE-CHAIRMAN INOUYE: Did you feel that it was proper or 

improper? 

MR. PETRAS: It was at Christmas. [Laughter] 188

Among the gratuities that Petras did not disclose was the $2500 

he solicited in 2004 from Abramoff to support a recall campaign 

against the incumbent Tribal Council.189 Documents in the Committee’s possession also indicate that, Maynard Kahgegab, whose 

campaign for Tribal Chief Petras (and CCS) helped with, also received gifts from Abramoff. On July 21, 2003, Abramoff discussed 

with one of his assistants a ‘‘television gift’’ for Chief Kahgegab: 

‘‘We bought him one for Christmas, right? Can you show me what 

we got him? [H]e complained tonight that it was too small. We 

might have to get him another one. [W]hat joy!’’ 190

2. Problems With Petras’ Testimony 

During its September 29, 2004, hearing, the Committee posed 

several questions to Petras about his involvement in tribal elections—both the campaign of the Slate of Eight for seats on the 

Tribal Council and subsequent efforts to keep the then-incumbent 

members of the slate on the Tribal Council. In response, Petras relied on a chronic failure of recollection. In particular, he testified 

that he could not recall ‘‘at any time having anything to do with 

[Tribal Council] elections.’’ 191 He also stated that he did ‘‘not recall 

any discussion regarding bringing in Mr. Scanlon to run any type 

of campaign.’’ 192 In response to a specific question from the Committee about the strategy meeting with Scanlon and Otto at the 

Bob Evans restaurant, Petras testified that he could not recall ‘‘discussing any strategy for a [S]late of [E]ight.’’ 193

However, this Report has presented testimony and documents 

that indicate that Petras not only came up with the ‘‘Slate of 

Eight’’ concept but also was heavily involved in helping Scanlon implement a plan to help elect the Slate of Eight to the Tribal Council. Given the volume of that evidence, discussed above, the Committee finds Petras’ failure of recollection on this point misleading. 

Despite his alleged failure to remember having had anything to 

do with Tribal elections, documents indicate that Petras actually 

persisted in trying to get CCS to help on the re-election of incumbent members of the Tribal Council. For example, an October 1, 

2003, memorandum from then-CCS associate Christopher Cathcart 

to the file, entitled ‘‘MI Elections,’’ reflects that Scanlon had ‘‘repeated and contentious discussions with Petras’ about his attempts 
66 

194 Capitol Campaign Strategies document production (BB/SC 08552) (entitled ‘‘Memorandum, from Christopher Cathcart, Capitol Campaign Strategies, to file, ‘MI Elections’ ’’) (October 1, 

2003). 195 Interview of Christopher Cathcart, former associate, Capital Campaign Strategies, in Washington, D.C. (October 6, 2004). 196 Capitol Campaign Strategies document production (BB/SC 08552) (entitled ‘‘Memorandum, from Christopher Cathcart, Capitol Campaign Strategies, to file, ‘MI Elections’ ’’) (October 1, 

2003). 197 Capitol Campaign Strategies document production (BB/SC 08547) (entitled ‘‘Memorandum, from Christopher Cathcart, Capitol Campaign Strategies, to file, ‘MI Elections’ ’’) (October 6, 

2003). 198 Id. 199 Id. 200 Capitol Campaign Strategies document production (BB/SC 08551) (entitled ‘‘Memorandum, 

from Christopher Cathcart, Capitol Campaign Strategies, to file, ‘Tribal Council Election in 

Michigan’ ’’) (October 7, 2003). 201 Capitol Campaign Strategies document production (BB/SC 08549) (entitled ‘‘Memorandum, from Michael Scanlon, Capitol Campaign Strategies, to file, ‘Saginaw Chippewa/Chris Petras’ ’’) 

(October 9, 2003) (carbon-copying Cathcart). 202 Email from Steven Braga, Esq., Baker Botts, to Saginaw Chippewa Indian Tribe (no Bates number) (March 30, 2006) (conveying responses from Scanlon to questions posed by Tribe). 203 Id. 204 Id. 205 Id. 

to have CCS work on individual election efforts of Tribal Council 

members.194 To Cathcart, this ‘‘looked fishy and smelled fishy.’’ 195

According to the memorandum, Cathcart ‘‘repeatedly advised ... 

Chris Petras ... that we as a firm can do no work [on such efforts].’’ 196

Days later, Petras apparently ‘‘came to [CCS’] offices today asking again that we help in the council elections scheduled for next 

Tuesday, October 14th.’’ 197 According to a memorandum reflecting 

this discussion, Cathcart ‘‘again expressed [his] opinion that since 

[CCS is] contracted with the tribe, [CCS] cannot be involved with 

the elections.’’ 198 In this document, Cathcart memorialized that 

‘‘[Petras] was very upset by this line of discussion ...’’ 199 On October 7, 2003, in another note to the file, Cathcart memorialized that 

‘‘[Scanlon] expressed that he would discuss the matter with Chris 

Petras and express to [him] that that [sic] was our position.’’ 200

Memorializing ‘‘the behavior of Chris Petras, our sole contact at 

Saginaw Chippewa[,] to be inappropriate with regard to [CCS’] relationship with the tribe,’’ Scanlon drafted his own note to the file 

that ‘‘[Petras] has repeatedly pressed his and the chiefs [sic] political concerns into our business relationship with the tribe.’’ 201 He 

also memorialized that he and Cathcart ‘‘have continually told 

[Petras] that we (CCS) can not [sic] use tribal funds to conduct 

campaign activity ...’’ 

As described above, the Committee has received information indicating that Petras was heavily involved in the 2004 recall effort. 

Apparently, at one point, Petras and Abramoff were on a speaker 

phone yelling at Scanlon because Scanlon would not help with that 

effort.202 The Committee has also received information indicating 

that Petras asked Scanlon to write a negative letter about a Tribal 

Member associated with the effort—perhaps Bernie Sprague.203

Petras apparently provided Scanlon with negative personal information about that member.204 About three weeks before Sprague 

was elected to the Tribal Council, an anonymous letter conveying 

disturbing allegations was mailed out to members of the Tribe.205

Not only did Petras claim to not recall what he did to support 

the re-election efforts of particular Tribal Council members, he al-
67 

206 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 40 (September 29, 2004). 207 Id. at 42–44, 48. 208 Interview of David Otto, former Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (August 27, 2004). 209 Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, 

D.C. (September 13, 2004). 210 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. 

at 39 (September 29, 2004) (testimony of Christopher Petras, former legislative director, Saginaw Chippewa Indian Tribe). 211 Id. 212 Interview of David Otto, former Sub-Chief, Saginaw Chippewa Indian Tribe, in Wash- ington, D.C. (August 27, 2004). 213 Id. 214 Id. 

legedly could not recall anything about Abramoff’s involvement in 

assisting in the recall of the other members of the Tribal Council, 

who were elected after the Slate of Eight left office.206 However, 

given the evidence described above that indicate that Petras knew 

a great deal about Abramoff’s involvement here, the Committee 

finds Petras’ chronic failure to recall matters about this issue, and 

other issues, disingenuous. Of additional interest to the Committee 

is Petras’ inability to recall all of the gifts or remuneration he may 

have received from Abramoff or Scanlon, also discussed above. 

On areas apparently unaffected by his chronic failure of recollection, Petras made statements that are inconsistent with the testimony of other, more credible, witnesses. Two areas that the Committee probed with Petras during the hearing were his role in the 

Tribe’s hiring of Abramoff and his role in getting the Tribe to pay 

on Abramoff’s requests for political and charitable contributions. 

During the hearing, Petras described his role in the Tribe’s hiring 

of Abramoff as merely passing information on to the Tribal Council 

as to who it should hire as an outside counsel or lobbyist and that 

legislative assistant Kim Sawmick actually made the recommendation.207 Inasmuch as Petras covered federal legislative matters for 

the Tribe, the Tribal Council likely would have given substantial 

deference to Petras as to who the Tribe should hire as its federal 

lobbyist. Indeed, former Tribal Sub-Chief David Otto stated that 

Petras actually recommended Abramoff as his choice for the job.208

Likewise, Tribal Sub-Chief Bernie Sprague told staff that Petras 

‘‘brought in Abramoff.’’ 209

Petras likewise testified that ‘‘[t]here were no efforts on my behalf to try to push either way any type of political contribution.’’ 210

This was offered in response to a question from the Committee as 

to whether Petras ‘‘encourage[d] or assist[ed] Mr. Abramoff in encouraging the tribes to donate to [the] so-called charities that he 

promoted.’’ 211

However, Otto’s testimony rebuts Petras’ recollection. In particular, Otto recalled Petras’ telling him that the Council of Republicans for Environmental Advocacy (‘‘CREA’’) was a group with 

which Interior Secretary Gale Norton was ‘‘involved.’’ 212 According 

to Otto, Petras also said that supporting a project the Secretary 

was involved with would ‘‘look good for the Tribe.’’ 213 Otto also recalled that he was told that doing so would ‘‘help [the Tribe] with 

appropriations for their school, drug abuse center, senior center, 

and etc.’’ 214
68 

215 Email from Jack Abramoff, Greenberg Traurig, to Christopher Petras, Saginaw Chippewa Indian Tribe (GTG–E000105233–34) (September 19, 2001). 216 Id. 217 Email from Jack Abramoff, Greenberg Traurig, to Allison Bozniak, Greenberg Traurig 

(GTG–E000107697) (January 31, 2002). 218 ‘‘Tribal Lobbying Matter,’’ Hearings before the Committee on Indian Affairs, 108th Cong. 

at 29 (September 29, 2004) (prepared statement of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe). 219 Email from Jack Abramoff, Greenberg Traurig, to Mike Scanlon, Capitol Campaign Strate- gies (GTG–E000002363) (December 17, 2001). 220 Email from Jack Abramoff, Greenberg Traurig, to Mike Scanlon, Capitol Campaign Strate- gies (GTG–E000002365) (December 17, 2001). 221 Email between Michael Scanlon, Capitol Campaign Strategies, and Jack Abramoff, Green- berg Traurig (GTG–E000002365) (December 17, 2001). 222 Id. 

Documents indicating that Abramoff told Petras that the Secretary supported CREA help corroborate Otto’s account. In an 

email, dated September 19, 2001, from Abramoff to Petras, 

Abramoff tried to persuade the Tribe to make a sizeable contribution to CREA.215 In connection with a CREA fund-raiser at a private Washington, D.C. home, Abramoff falsely pitched CREA as 

‘‘hav[ing] been incredibly helpful on certain specific tribal issues’ 

and misrepresented CREA as ‘‘[Secretary] Norton’s main group outside the department.’’ 216 After having told Petras about the Secretary’s connection to CREA, on January 31, 2002, Abramoff directed his assistant make the following change to a requested contribution list going to the Saginaw Chippewa: ‘‘add in $50,000 for 

CREA and put a note in the candidate column as follows: Sec. Norton.’’ 217

From its due diligence, the Tribe estimates that ‘‘[t]he Saginaw 

Chippewas were taken by Mr. Petras and Mr. Scanlon and Mr. 

Abramoff over a 2-year period of approximately $1 million in contributions ... Campaign contributions to people we never heard of, 

people we knew nothing about, organizations, different things of 

this nature.’’ 218 Given the foregoing, the Committee is concerned 

about the accuracy of Petras’ testimony to the Committee. 

H. ABRAMOFF AND SCANLON PRIVATELY EXPRESS CONTEMPT FOR THE

TRIBE

While Abramoff and Scanlon worked closely with the Tribe for 

their own purposes, they expressed an unsettling contempt for 

their clients. Evidence of their contempt can be traced to the beginning of their representation of the Saginaw Chippewa. For example, on December 17, 2001, shortly after the Tribal Council elections, Abramoff and Scanlon awaited the new Council’s vote on a 

project proposed by Scanlon’s CCS: ‘‘Just spoke with Chris. Did you 

get Maynard? Chris said they are voting on the project today!! Can 

you smell money?!?!?!’’ 219

When the new Council failed to vote on the project, Abramoff 

was unreserved in his contempt: ‘‘The f ’ing troglodytes didn’t vote 

on you today. Dammit.’’ 220

Scanlon asked, ‘‘What’s a troglodyte?’’ 221

Abramoff responded, ‘‘What am I a dictionary? :) It’s a lower form 

of existence basically.’’ 222

Continuing their exchange, Abramoff explained the Saginaw 

Chippewa’s failure to vote on one of Scanlon’s proposals: ‘‘They 

spent the whole time discussing the firings of late. I like these 
69 

223 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000002363) (December 18, 2001). 224 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000026246) (March 13, 2002). 225 Id. 226 Id. 227 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000026311) (April 11, 2002). 228 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg Traurig (GTG–E000001175) (June 5, 2002). 229 Email from Jack Abramoff, Greenberg Traurig, to Rodney Lane (GTG–E000024633) (May 24, 2001). 230 Email from Jack Abramoff, Greenberg Traurig, to Todd Boulanger, Greenberg Traurig (GTG–E000027857) (February 18, 2003). 

guys, and truly believe they are going to do the program, but they 

are plain stupid. They should have had you on board first and then 

done the firings. Morons.’’ 223

Likewise, on March 13, 2002, Mr. Abramoff simply referred to 

the Tribe, in the subject line of an email to Scanlon, as ‘‘those 

f ’ing SagChips.’’ 224

In that e-mail, Abramoff expressed concern that the Tribe was 

not going to participate in his Sports Suites program, because the 

Tribe was already spending too much money and was not seeing 

results from Scanlon.225

Scanlon retorted that the tribe ‘‘are just friggin cheap—and losers ...’’ 226

Furthermore, in an e-mail bearing the subject line ‘‘SagChip idiots’’, Abramoff wrote: 

Someone leaked out the Operation Red Wing memo to the 

enemy up there. Petras told me this tonight. The PR guy, 

Joe?, is the enemy and—I did not know this—is a Sagchip, 

and is now going to run for council!! These mofos are the 

stupidest idiots in the land for sure. 227

In discussing a trip to the Tribe in June 2002, Scanlon wrote: 

Also, we need to figure something out on the trip to sag— 

I can travel two weekd [sic] in [a] row and you know that 

petras is always dramtic [sic]. It would really be better for 

me—and us[,] I believe[,] to just do the whole swing. I 

really think a trip out to those fools solo is not worth it 

regardless, because we will not come back with cash or a 

firn [sic] commitiment [sic], but when you throw in the 

pain in the ass factor and the petras bullshit factor, its 

[sic] a really bad idea.228

As the foregoing suggests, Christopher Petras, Abramoff and 

Scanlon’s champion within the Tribe, did not escape their contempt. Apparently from the outset, Abramoff disparaged Petras as 

a ‘‘dork.’’ 229 When Petras attempted to get concert tickets for a 

Michigan state representative running for Congress, Abramoff 

wrote to a colleague, ‘‘Neither rain, nor snow [sic], nor the heat of 

day will keep him from his appointed idiocy.’’ 230

Ironically, Abramoff and Scanlon ridiculed Petras privately for 

talking about people behind their backs. In an email with the subject line ‘‘Just Talked to Petras,’’ Scanlon wrote, ‘‘No worries—Im 

[sic] sorry I felw [sic] off the handle—that guy drives me nuts 
70 

231 Email between Michael Scanlon, Capitol Campaign Strategies, and Jack Abramoff, Green- berg Traurig (GTG–000024691) (December 12, 2002). 232 Id. 233 Email between Todd Boulanger, Greenberg Traurig, and Jack Abramoff, Greenberg Traurig (GTG–E000027698) (March 16, 2003). 234 Id. 235 Id. 236 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. 

at 41–42 (September 29, 2004) (testimony of Christopher Petras, former legislative director, 

Saginaw Chippewa Indian Tribe). 

sometimes—especially the way he back stabs and talks about everybody behind thier [sic] backs.’’ 231

Abramoff replied, ‘‘That’s why he has a mullet.’’ 232

Months later, Abramoff had a similar exchange with his senior lobbying associate Todd Boulanger: ‘‘What are you doing? Petras is 

coming to town this week’’ I’m gonna schedule ... Some Jack— 

Petras time everyday ...’’ 233

He continued, ‘‘Have you noticed that he’s wearing better ties and shirts ... [?] I’ve got him to spend some cash on it. He’s into 

it. Ahahahahhahahhaahhaha. If he would [sic] only cut that 

hair.’’ 234

Abramoff replied, ‘‘Then he wouldn’t look like an Indian, 

though.’’ 235

When, at its September 29, 2004, hearing the Committee asked Petras for his reaction to various communications in which 

Abramoff and his associates disparaged him, his loyalty to 

Abramoff stood fast—he asked for their context.236

I. CONCLUSION

Abramoff and Scanlon’s efforts to sign on the Saginaw Chippewa as clients is particularly notable. As they had done with the Agua 

Caliente, Abramoff and Scanlon insinuated themselves in Tribal 

Council elections to maximize their chance of getting hired afterwards. In particular, they provided, among other things, strategic 

advice and logistic support to some of the candidates. Those who 

ran in the Saginaw Chippewa election called themselves the ‘‘Slate 

of 8.’’ While Scanlon came up with the name of this slate of candidates, the concept was apparently created by a non-Tribal member—Tribal legislative director, Christopher Petras. While his motivation for helping Abramoff and Scanlon oust the incumbent Tribal Council remains unclear, evidence indicates that, 

over the course of (originally) Abramoff’s and (later) Scanlon’s representation of the Saginaw Chippewa, Petras was given things of 

value. In fact, Petras traveled to Washington, D.C. so often and 

(with private cars, tickets to sporting events and concerts, meals at 

posh restaurants, and ‘‘meetings’’ with prominent political personalities) his trips became so demanding on Abramoff’s staff that one 

former Abramoff associate described what they did for and with 

Petras as ‘‘dog and pony shows.’’ The weight of evidence obtained by the Committee indicates that (1) Petras’ assistance was key to Abramoff and Scanlon’s success in 

getting contracts with the Saginaw Chippewa and (2) those candidates who were elected to the council with Abramoff and Scanlon’s assistance ultimately supported Abramoff and Scanlon’s contract proposals because of, or in exchange for, the assistance that 

Abramoff and Scanlon provided them. 
71 

From June 2002 through October 2003, the Saginaw Chippewa 

paid Scanlon about $3,500,000 for grassroots activities and political 

consulting. Of those proceeds, Scanlon secretly kicked back to 

Abramoff about $540,000—about 50% of his total profit from the 

Tribe during this period. Discussion and analysis of how Abramoff 

and Scanlon successfully perpetrated their ‘‘gimme five’’ scheme on 

the Tribe, on an entity-by-entity basis, is contained infra in Part 

2 of this Report. 

(73) 

1 Email from Linsey Crisler, Greenberg Traurig, to Jack Abramoff, Greenberg Traurig (GTG– E000010608) (February 3, 2004). 2 Id. 

3 Id. 

4 Id. 

5 Id. 

6 Id. 

CHAPTER IV 

AGUA CALIENTE BAND OF CAHUILLA INDIANS 

Can you smell money? 

Email from Jack Abramoff to Michael Scanlon, June 14, 2002 

I think the key thing to remember with all these clients 

is that they are annoying, but that the annoying losers are 

the only ones which have this kind of money and part with 

it so quickly. 

Email from Jack Abramoff to Michael Scanlon, March 5, 2003 

A. INTRODUCTION

During her February 2004, interview of Jack Abramoff, The 

Washington Post reporter Susan Schmidt queried him about allega- tions that he and Michael Scanlon may have interfered with Tribal 

elections to get lobbying contracts. Specifically, Schmidt asked, 

‘‘You know, isn’t there some, you know concern about outside people getting involved in tribal elections and isn’t that frowned upon 

by the regulators here in Washington?’’ 1

Abramoff pushed back a little: ‘‘I’m sorry I don’t understand, trib- al elections?’’ 2

Schmidt explained, ‘‘Getting involved in tribal elections [—] out- side firms[;] outside influences[;] bringing money or expertise or 

whatever[;] getting involved in tribal elections[;] getting people 

ousted[;] getting people elected[;] getting people re-elected using 

tribal funds for that purpose.’’ 3

Abramoff asked, ‘‘Well I don’t know, I’m not sure I understand 

the question, do you mean with the Sac and Fox in Iowa, or our 

getting involved?’’ 4

Schmidt pressed, ‘‘No, I was actually thinking of the Agua Caliente[:] some people running for election getting dominance on 

the tribal council and then bringing you guys in and you guys 

bringing in Scanlon, in sort of unfolding. ...’’ 5

Abramoff obfuscated, ‘‘With Agua Caliente, I, you can check, but I don’t think the tribal council makeup has changed much over the 

years, I’m not certain.’’ 6

Notwithstanding Abramoff’s evasive answers to Schmidt’s ques- tions, Abramoff and Scanlon did, in fact, insinuate themselves into 

the elections at the Agua Caliente Band of Cahuilla Indians (‘‘Agua 

Caliente’’). In 2002, one of their allies prevailed and paved the way 
74 

7 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 

51 (September 29, 2004) (Prepared statement of Richard M. Milanovich, Chairman, Agua 

Caliente Band of Cahuilla Indians). 8 Id. 

9 Cultural History (visited Mar. 22, 2006) <http://www.aguacaliente.org/ 

index.php?PID=CULTURAL> (describing the cultural history of the Cahuilla). 10 Id. 11 Id. 12 Id. 13 Homepage (visited Mar. 22, 2006) <http://www.aguacaliente.org/ 

index.php?PID=TRIBALHOME> (providing a brief introduction to Cahuilla history). 14 Cultural History (visited Mar. 22, 2006) <http://www.aguacaliente.org/ 

index.php?PID=CULTURAL> (describing the cultural history of the Cahuilla). 15 Id. 16 Id. 17 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. 

at 51 (September 29, 2004) (Prepared statement of Richard M. Milanovich, Chairman, Agua 

Caliente Band of Cahuilla Indians). 18 Id. 19 Id. 20 Id. 21Political History (visited March 22, 2006) <http://www.aguacaliente.org/ 

index.php?PIC=POLITICAL> (describing the political history of the Cahuilla). 

for the lucrative contracts that the Tribe ultimately awarded to 

Abramoff and Scanlon. 

B. BACKGROUND ON THE TRIBE

The Agua Caliente’s traditional homelands are in the Palm 

Springs, California area.7 In 1876, the Federal Government deeded 

into trust 32,000 acres of the Tribe’s ancestral homeland as the 

Agua Caliente Indian Reservation.8

Traditionally, a Cahuilla village consisted of approximately 100 

to 200 inhabitants with several villages combining together to compose a larger political and territorial unit called a tribelet or sib.9

The villages were permanent; however, groups would leave periodically to hunt, gather, or trade, setting up temporary camps for several weeks at a time.10

The Cahuillas belong to the Shoshonean division of the Uto-Aztecan linguistic family, which ranges from the Aztecs of Mexico to 

the Hopi in Arizona.11 Cahuilla society was divided into exactly 

two descent groups or moieties, the Wildcat and the Coyote.12 The 

Cahuilla were adept at farming and grew crops such as melons, 

squash, beans, and corn.13 They irrigated their crops with water 

from nearby streams.14 They also gathered other food items such 

as acorns, seeds, wild fruit, agave, and yucca.15 In addition, they 

participated in extensive trade routes with neighboring tribes 

where food, shells, animals, and mineral products were traded.16

The Agua Caliente adopted its constitution and by-laws in 

1955.17 The Agua Caliente Tribal Council consists of five members: 

chairman, vice chairman, secretary, and two members.18 The chairman, vice-chairman, and secretary serve 2-year terms and members serve a 1-year term.19 Under the Tribe’s constitution, action 

is taken by a majority vote of the Tribal Council.20

In 1989, the Tribe formed the Agua Caliente Development Authority, a subsidiary of the Tribe, which handles decisions on economic development.21 The Tribe operates two casinos. One, opened 
75 

22Miller & Schroeder Completes $70 Million Debt Financing for Agua Caliente Band of 

Cahuilla Indians (visited March 22, 2006) <http://www.casinocitytimes.com/news/article.cfm?contentID=123148> (discussing the financial history of the Cahuilla casinos). 23 Id. 24 Email from Jack Abramoff, Greenberg Traurig, to Michael Smith, Greenberg Traurig (GTG– 

E000059107) (January 7, 2002). 25 Email between Michael Chapman and Jack Abramoff, Greenberg Traurig (GTG– 

E000059081) (January 22, 2002); Email between Jack Abramoff, Greenberg Traurig, and Michael Chapman (GTG–E000056764) (January 22, 2002). 26 Although she was not on the Tribal Council at the time, C. Patencio had been involved in 

tribal politics and had served on the Tribal Council previously, from 1996–2001, losing her bid 

in 2001 for the vice chairman’s seat by one vote. Interview of Candace Patencio, former council 

member, Agua Caliente Band of Cahuilla Indians, by telephone (April 25, 2006). 27 Email from Michael Chapman to Jack Abramoff, Greenberg Traurig (GTG–E000056764) 

(January 22, 2002); see also Email from Michael Chapman to Jack Abramoff, Greenberg Traurig 

(GTG–E000059086) (January 22, 2002) (‘‘I am dear friends with both and we have vacationed 

together in Utah and Hawaii—under the guise of Indian business.’’). During his interview with 

Committee staff, Chapman said that while he considers Siva a friend, he only feels he is close 

friends with C. Patencio. Interview of Michael Chapman, by telephone (March 31, 2006). 28 Email from Michael Smith, Greenberg Traurig, to Jack Abramoff, Greenberg Traurig (GTG– 

E000059106–07) (January 7, 2002). 29 Interview of Michael Chapman, by telephone (March 31, 2006). 30 Email from Michael Chapman to Jack Abramoff, Greenberg Traurig (GTG–E000056764) 

(January 22, 2002). 

in 1995, is located on the hot springs for which the Tribe was 

named.22 The other casino opened in 2001.23

C. ABRAMOFF AND SCANLON OFFER THE PROMISED LAND

In early 2002, Abramoff was on his way to Palm Springs, California for a meeting with members of the Agua Caliente.24 Michael 

Chapman, an enrolled member of the Menominee Indian Tribe of 

Wisconsin, had arranged the introduction.25 Chapman had claimed 

to be ‘‘very good friends’’ with Candace Patencio (‘‘C. Patencio’’) and 

Virginia Siva, members and Tribal leaders 26 of the Agua 

Caliente.27

Abramoff had become acquainted with Chapman through Michael Smith, then a lobbyist in Greenberg Traurig’s Washington, 

D.C. governmental affairs practice.28 Smith and Chapman initially 

met by phone through a mutual friend, and later met face-to-face 

in Chicago over Christmas vacation.29

Chapman proved a useful resource. Before Abramoff’s meeting in 

Palm Springs, Chapman provided Abramoff with information about 

the Tribe, its key players, and internal dynamics. More specifically, 

he provided background on C. Patencio and Siva and their involvement in Tribal politics: 

[Virginia] has held her At-Large seat for several years. She 

is contemplating running for Chairman, pending a preliminary polling of key families. What is remarkable about her 

is the At-Large seats are up for election each year, so she 

has a consistent power base in the tribe that is loyal to 

her.30

On C. Patencio, Chapman provided the following information: 

Candace comes from the Petencio [sic] family which is one 

of the largest families at Agua Caliente—both of her parents have served on council in the past and her father was 

once Tribal Chairman. She has served on council for several years as an At-Large Councilor. Last year she ran for 
76 

31 Id.; see also Interview of Candace Patencio, former council member, Agua Caliente Band of Cahuilla Indians, by telephone (April 25, 2006) (explaining she received a degree in Business 

Administration from University of San Diego and an MBA from University of Phoenix in San 

Diego, and confirming her one-vote loss for Vice Chairman in 2001). 32 Email from Michael Chapman to Jack Abramoff, Greenberg Traurig (GTG–E000056764) (January 22, 2002). In her interview, C. Patencio confirmed that she, Moraino Patencio, and 

Siva are related. Interview of Candace Patencio, former council member, Agua Caliente Band 

of Cahuilla Indians, by telephone (April 25, 2006). 33 Interview of Candace Patencio, former council member, Agua Caliente Band of Cahuilla In- dians, by telephone (April 25, 2006); see also Emails between Jack Abramoff, Greenberg Traurig, and Ilisa Gertner, Greenberg Traurig (GTG–E000056766) (January 22, 2002). 34 Interview of Candace Patencio, former council member, Agua Caliente Band of Cahuilla In- dians, by telephone (April 25, 2006). 35 Id. 36 Id. 37 Id. 38 Id. C. Patencio was likely referring to Abramoff’s production of the movie ‘‘Red Scorpion,’’ 

an action film starring actor Dolph Lundgren. 39 Interview of Michael Chapman, by telephone (March 31, 2006). 40 Email from Michael Chapman to Jack Abramoff, Greenberg Traurig (GTG–E000059086) (January 22, 2002). 41 Interview of Candace Patencio, former council member, Agua Caliente Band of Cahuilla In- dians, by telephone (April 25, 2006). 42 Email from Michael Chapman to Jack Abramoff, Greenberg Traurig (GTG–E000056764) 

(January, 22, 2002). 

Vice-Chairman of the tribe and lost by one vote. This year 

she is seeking her old seat. Candace has an MBA.31

Chapman also identified the consequences of a successful election 

for C. Patencio and Siva: 

They [C. Patencio and Siva] are also related to the Tribe’s 

Treasurer [Moraino Patencio]—so if they prevail in their 

election pursuits in March—they will have controlling interest on the Tribal Council.32

Once in Palm Springs, Abramoff dined with C. Patencio, Siva, 

and Moraino Patencio (‘‘M. Patencio’’) at the Canyon Bistro restaurant.33 During her interview with Committee staff, C. Patencio 

admitted that she and Siva were dissatisfied with Pace-Capstone, 

the Tribe’s lobbyists at the time.34 Indeed, C. Patencio said that if 

she assumed control of the Tribal Council at the time, she would 

have definitely ended that lobbying firm’s contract.35

Yet, she claimed that before her meeting with Abramoff, she did 

not know he was a lobbyist, and there was no purpose to the meeting.36 She simply met with him because Chapman had suggested 

she do so.37 According to C. Patencio, she only knew that Abramoff 

was a movie producer who had produced ‘‘red something.’’ 38

Chapman recalled the genesis of the meeting much differently. 

Chapman told the Committee that he had recommended C. 

Patencio meet with Abramoff because she and Siva were dissatisfied with the Tribe’s lobbyists at the time.39 Indeed, after speaking 

with C. Patencio about arranging the meeting, Chapman reported 

to Abramoff that they are ‘‘eager to hear what you think.’’ 40

In light of Chapman’s statement to the Committee and his contemporaneous email to Abramoff, the Committee has considerable 

difficulty with C. Patencio’s claim that she did not know that 

Abramoff was a lobbyist or the purpose of the meeting. Ms. 

Patencio holds a business administration degree and a Masters of 

Business Administration.41 Her family has been heavily involved in 

Tribal politics: both her father and mother served on the Tribal 

Council, and her father was once chairman.42 C. Patencio served on 
77 

43 Interview of Candace Patencio, former council member, Agua Caliente Band of Cahuilla Indians, by telephone (April 25, 2006). 44 Id. Provided certain conditions are met, the Indian Gaming Regulatory Act (‘‘IGRA’’) allows 

for self-regulation by Indian tribes of Class II gaming (e.g., bingo and games similar to it, pull 

tabs, and non-house banked card games). IGRA does not allow for self-regulation of Class III 

gaming. In 1999, the Choctaw successfully secured self-regulation for Class III gaming in an 

omnibus appropriations bill. 45 Id. 46 Id. 47 Id. 48 Id. 49 Id. 50 Id. 51 Id. 52 Email from Candace Patencio, Agua Caliente Band of Cahuilla Indians, to Jack Abramoff, 

Greenberg Traurig (GTG–E000057210) (February 18, 2002); See also Email from Michael Chapman to Jack Abramoff, Greenberg Traurig (GTG–E000056873) (February 16, 2002) (‘‘Candace 

and Virginia are both going to be in Washington the week of February 24th—initially for NCAI’s 

Executive Council meeting and then NIGA business.’’). 53 Email from Michael Smith, Greenberg Traurig, to Jack Abramoff, Greenberg Traurig (GTG– E000056872) (February 16, 2002). 54 Email from Michael Chapman to Jack Abramoff, Greenberg Traurig (GTG–E000056872) (February 16, 2002). 55 Email from Michael Chapman to Jack Abramoff, Greenberg Traurig (GTG–E000056867) (February 17, 2002). 56 Id. 

the Tribal Council for five years.43 The Committee has difficulty 

believing that a woman with C. Patencio’s educational and political 

background would not have known the purpose of the meeting and 

Abramoff’s profession. 

C. Patencio told Committee staff that during their dinner, 

Abramoff boasted that he was part of the lobbying team that had 

secured self-regulation of Class III gaming under the Indian Gaming Regulatory Act for the Mississippi Band of Choctaw Indians 

(‘‘Choctaw’’).44 That, according to C. Patencio, was why she became 

so interested in having the Tribe hire Abramoff.45 In addition to 

her dissatisfaction with Pace-Capstone, C. Patencio was at odds 

with the Tribe’s Chairman and Vice Chairman.46 Although she had 

just met Abramoff, C. Patencio shared this information with him.47

C. Patencio could recall little else about that meeting.48 C. 

Patencio did not recall Abramoff mentioning any other clients aside 

from Choctaw, or discussing Michael Scanlon.49 She also did not remember discussing the upcoming 2002 Tribal elections with 

Abramoff at that dinner.50

The following month, in Washington, D.C., Abramoff met again 

with C. Patencio, M. Patencio, and Siva.51 The three Tribal members were attending meetings of the National Congress of American 

Indians and the National Indian Gaming Association.52 Before the 

trio arrived in Washington, D.C., Chapman advised Smith that ‘‘a 

dinner and sporting event would go a long way with Virginia et al 

[sic] (especially dinner at your [Abramoff’s] place).’’ 53

Chapman also revealed: ‘‘I assisted them [C. Patencio and Siva] 

with their candidacy statements and will fly out the weekend before the election to see what we can shore-up. The actual election 

is March 19th.’’ 54 The very next day, Chapman wrote that ‘‘[o]n the 

election front, Agua voters must register weeks in advance in order 

to participate in the election—so now is the time they need to shore 

up their support!’’ 55 Abramoff forwarded Chapman’s email to Scanlon, noting ‘‘[l]et’s discuss this.’’ 56 It thus appears that Chapman, 
78 

57 Email from Jack Abramoff, Greenberg Traurig, to Candace Patencio, Agua Caliente Band of Cahuilla Indians (GTG–E000057166) (February 17, 2002). 58 Id. 59 Id. 60 Email between Candace Patencio, Agua Caliente Band of Cahuilla Indians, and Jack Abramoff, Greenberg Traurig (GTG–E000057210) (February 18, 2002). 61 Id. 62 Id. 63 Interview of Candace Patencio, former council member, Agua Caliente Band of Cahuilla In- dians, by telephone (April 25, 2006). 64 Email between Michael Chapman and Jack Abramoff, Greenberg Traurig (GTG– E000059253) (February 26, 2002). 65 Id. 66 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon (GTG–E000059252) (February 26, 2002). 

intentionally or unintentionally, gave Abramoff the idea to insinuate himself and Scanlon into the Agua Caliente elections. Abramoff followed Chapman’s advice, and on February 17, in- vited C. Patencio: 

Michael tells me that Virginia and you are going to be in 

Washington, DC [sic] next week. I would love to get together with you if possible. Coincidentally, that is the 

week that we open Signatures, a high end fine dining restaurant which I own. We have a special reception there 

Wednesday night for Senator Tim Hutchinson (I’d love to 

introduce you to him—and then we could all have dinner).57

Abramoff continued, ‘‘Thursday night is the grand opening, and you are certainly invited to attend that one as well. There should 

be quite a few Members and Senators there. Anyway, I’ll call you 

this week to see if you can make it and if we can get together.’’ 58

‘‘Are you guys basketball fans? If so, the Wizards (Michael Jor- dan) are playing and I’d love to have you join us for that too,’’ 

Abramoff added 59

C. Patencio confirmed that, ‘‘Yes, Virginia, Moraino and I will be in DC from 2/24–3/31. The full Tribal Council along with the proxies will be attending the NCAI & NIGA meetings.’’ 60

She continued, ‘‘Spoke with Virginia [and] she said she would like to go to dinner but neither of us are basketball fans (As you 

can tell fine dining is something we enjoy).’’ 61

In response, Abramoff told her he would call her the next day to make plans.62

C. Patencio recalled two meetings with Abramoff during her 

visit.63 Contemporaneous emails suggest there might have been three. Abramoff apparently first met with the trio on February 26. 

That day, Chapman advised Abramoff, ‘‘Just a short note to say 

that once again my Agua crew enjoyed the pleasure of your company! They’re looking forward to seeing you tomorrow! I hope Virginia prevails—it could be a great relationship/client!’’ 64

Abramoff assured Chapman, ‘‘Mike Scanlon and I are going to do everything we can to help them.’’ 65

Separately, Abramoff forwarded Chapman’s email to Scanlon and suggested, ‘‘You should call them for tomorrow and get together to 

discuss strategy.’’ 66

Abramoff met again with C. Patencio and her companions on February 27. At that point, Abramoff apparently began to scheme 

on how he could use political contributions from the Agua Caliente 
79 

67 Email from Jack Abramoff, Greenberg Traurig, to Ilisa Gertner, Greenberg Traurig (GTG– E000057185) (February 27, 2002). 68 Interview of Candace Patencio, former council member, Agua Caliente Band of Cahuilla In- dians, by telephone (April 25, 2006). See also Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000057184) (February 27, 2002). 69 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000057184) (February 27, 2002). 70 Interview of Candace Patencio, former council member, Agua Caliente Band of Cahuilla In- dians, by telephone (April 25, 2006). 71 Id. 72 Id. 73 Id. 74 Id. 75 Email between Michael Scanlon, Capitol Campaign Strategies, and Jack Abramoff, Green- berg Traurig (GTG–E000057254) (March 5, 2002). 76 Id. 77 Interview of Christopher Cathcart, associate, Capitol Campaign Strategies, in Washington, D.C. (October 6, 2004). 78 Id. 

to further his lobbying practice. Before his meeting with the Tribal 

members, Abramoff told his assistant Ilisa Gertner: 

Please let the Hutchinson guys know that they are coming 

(Candace, Virginia Siva, and a third fellow—can’t remember his name). tell [sic] them that they are not currently 

going to be able to contribute, but that they will in March 

be in a position where they control their tribe and will be 

able to be helpful on a Choctaw level.67

While at Signatures, Abramoff, C. Patencio, M. Patencio and 

Siva discussed Abramoff possibly representing the Tribe.68 They 

also apparently discussed Scanlon helping out C. Patencio and Siva 

on their 2002 elections, because, after the meeting, Abramoff immediately reported to Scanlon: ‘‘I saw them tonight. They really can’t 

wait for you to lead them to the promised land! Tomorrow night, 

after the reception at Sigs, let’s take them to dinner and lock up 

the deal.’’ 69

Later during her trip, C. Patencio met alone with Abramoff and 

Scanlon at another restaurant in Washington, D.C.70 There she 

learned that Scanlon was in public relations.71 She believed that 

Scanlon worked for Abramoff, that he was a member of ‘‘Jack’s 

team.’’ 72 C. Patencio believed that they discussed the 2002 Agua 

Caliente Tribal Council elections, although she said she did not ask 

Scanlon for help with her election.73 In fact, C. Patencio denied 

that Abramoff and Scanlon offered to help in her election; instead, 

she claimed, ‘‘things kinda fell in place.’’ 74

D. SCANLON WORKS ON C. PATENCIO AND SIVA’S ELECTION CAMPAIGNS

Before the Agua Caliente Tribal Council elections, Scanlon asked 

Abramoff, ‘‘Hey—How much do you want me to spend on the AC 

race—I gotta get a team out there ASAP—Like 3 people—Then rotate a new team in after that—So travel is goanna [sic] run about 

20k and materials like 5–10k. Should we go for it?’’ 75

Abramoff instructed Scanlon, ‘‘Yes, go for it big time.’’ 76

And, so Scanlon did. He sat down with his team and said, ‘‘We’re 

going to California to work on the election.’’ 77 Scanlon and his 

team performed the same type of work as they had for the Slate 

of Eight during the 2001 elections at the Saginaw Chippewa Indian 

Tribe.78 From March 6 through 10, 2002, Scanlon’s team drafted 
80 

79 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Agua Caliente Tribal Chairman and Council Election GOTV Timeline’’) (undated). 80 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000057241–51) (February 17, 2002); see also Email from Jack Abramoff, 

Greenberg Traurig, to Mohunwit@[REDACTED] (GTG–E000057216–22) (February 28, 2002). 81 Email between Jack Abramoff, Greenberg Traurig and Candace Patencio, Agua Caliente Band of Cahuilla Indians (GTG–E000057252) (March 6, 2002). 82 Id. 83 Interview of Candace Patencio, former council member, Agua Caliente Band of Cahuilla In- dians, by telephone (April 25, 2006). 84 Id. 85See Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Dear Friend’’) (undated); Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Candace Patencio MEET CANDACE PATENCIO!!’’) (undated). 86 Capitol Campaign Strategies document production (BB/AC 005407–12) (entitled ‘‘Virginia Siva Talking Points Community Meeting’’) (March 10, 2002). 87 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Agua Caliente Tribal Chairman and Council Election GOTV Timeline’’) (undated). 88 Id. 89 Id. 

candidate letters and fliers, paid for the envelopes and postage, secured a site and catering for a community meeting, assisted in 

door-to-door campaigning, and prepared the candidates for the community meeting.79

Abramoff and Scanlon’s objective was ensuring that ‘‘friendly’’ 

tribal members who would support contracts with them were elected and, conversely, potentially unsupportive members were defeated. Richard Milanovich, Chairman of the Tribe and Siva’s opponent in the 2002 elections, was targeted by Abramoff as ‘‘our 

enemy.’’ 80

Meanwhile, Abramoff asked C. Patencio, ‘‘how are we doing?’’ 81

When C. Patencio shared Siva’s apprehension and reluctance about 

the campaign, he urged, ‘‘Keep pushing her. We’re near the finish 

line and can’t slow down now. I know you know this more than 

anyone! Let me know if there is more we can do to help.’’ 82

Before the Agua Caliente Tribal Council election, Scanlon and C. 

Patencio spoke over the telephone about what she needed to do to 

win her election.83 C. Patencio confirmed that Scanlon either developed, or had a hand in developing, the themes of her election campaign.84 From the records uncovered by the Committee, those 

themes were ‘‘honesty, effectiveness, and experience.’’ 85

The Committee has not obtained evidence establishing that Scanlon had similar conversations with Siva. Among the computer files 

from Scanlon’s companies, however, the Committee discovered a 

talking points memorandum for Siva, containing ‘‘key message 

points’’ and general pointers on answering questions from voters.86

In early March, Scanlon’s team drafted three seminal documents 

governing their assistance in the Agua Caliente elections. The first 

document is entitled, ‘‘Agua Caliente Tribal Chairman and Council 

Election GOTV Timeline.’’ 87 The document appears to be a checklist for Scanlon and his employees for the Agua Caliente 2002 election. According to the document, by March 6, 2002, Scanlon and his 

team were to have completed a number of tasks, including but not 

limited to, drafting talking points for Siva; drafting candidate letters and fliers; creating invitations for a community meeting; securing a location for candidates’ meeting; and, contacting candidates.88

It also identified two days over which Scanlon’s team would assist 

C. Patencio and Siva in door-to-door campaigning.89
81 

90 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Candidate’s Timeline’’) (undated). 91See Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Tribal Election 2002 Agua Caliente Band of Cahuilla Indians’’) (undated). 92 Id. 93 Id. 94 Id. 95 Id. 96 Id. 97 Id. 98 Id. 99 Id. 100See Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Dear Friend’’) (undated). 101 Id. 102 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘draft letter from Candace Patencio’’) (March 8, 2002). 103See Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Dear 

Friend’’) (undated). 

The second document, entitled ‘‘Candidates’ Timeline,’’ established deadlines by which Scanlon and his team would complete or 

help C. Patencio and Siva complete mailers, phone calls, door-todoor campaigning, and a community meeting.90

The third document was entitled, ‘‘Tribal Election 2002 Agua 

Caliente Band of Cahuilla Indians.’’ 91 Scanlon and his team envisioned a specific message for C. Patencio and Siva to convey to 

their fellow Tribal members: ‘‘We will communicate that this election is about direct leadership by people who are in touch with the 

tribe. You are the new leaders, the leaders who will take the tribe 

into the future. Not the old leaders who are only looking out for 

number one.’’ 92 The campaign was purportedly designed to put the 

candidates ‘‘in contact with every voter at least five times over the 

next 7 days.’’ 93 Scanlon and his team divided potential voters into 

three tiers, and supposedly tailored their candidates’ messages to 

each tier.94 The campaign plan consisted of four general components: (1) mail; (2) door-to-door; (3) phones; and, (4) a candidates 

meeting.95

1. Mail 

The strategy memorandum claimed to ‘‘have developed three separate mail pieces’’ to articulate the candidates’ message.96 The first 

was ‘‘a personalized letter from you, explaining why you are a superior candidate for your position.’’ 97 The second was ‘‘a comparison piece that draws distinctions between you and your opponents.’’ 98 The third piece was a ‘‘traditional Get Out The Vote piece 

(GOTV) that asks for their support and reminds them to mail in 

their ballot.’’ 99

Among the documents discovered by the Committee is a draft letter from C. Patencio regarding the 2002 election.100 The letter 

stressed the importance of the upcoming election, and twice emphasized the themes of honesty, effectiveness, and experience, the very 

themes that Scanlon had developed.101 The Committee found essentially the same text on letterhead reading ‘‘Candace Patencio 

Candidate for Member of the Tribal Council.’’ 102

Similarly, the Committee found another draft letter, for Siva, on 

her bid for Tribal Chairman.103 It focused on the theme of fresh 

leadership: ‘‘Our tribe needs a leader who understands your concerns and is in tune with your needs ... It is time that our tribe 
82 

104 Id. 105 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Virginia Siva Sincere Leadership Inspired Results) (March 8, 2002). 106 Interview of Candace Patencio, former council member, Agua Caliente Band of Cahuilla Indians, by telephone (April 25, 2006). 107 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Tribal Election 2002 Agua Caliente Band of Cahuilla Indians’’) (undated). 108 Id. 109 Interview of Candace Patencio, former council member, Agua Caliente Band of Cahuilla Indians, by telephone (April 25, 2006). 110 Interview of Christopher Cathcart, associate, Capitol Campaign Strategies, in Washington, D.C. (October 6, 2004). 111 Interview of Candace Patencio, former council member, Agua Caliente Band of Cahuilla Indians, by telephone (April 25, 2006). 112 Id. 113 Id. 114See Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Menu 

and Credit Card Authorization Form’’) (undated). 

has a leader who is dedicated to working for you.’’ 104 This draft letter, too, was apparently in final form on letterhead reading ‘‘Virginia Siva Sincere Leadership Inspired Results.’’ 105

Although Scanlon’s action plan called for three letters, the Committee only found evidence of two. C. Patencio believed that Scanlon and his team did no more than two mailers, since the Tribe’s 

election ordinance limited election mailings to two.106

2. Door-to-Door 

Scanlon’s plan called for C. Patencio and Siva to go door-to-door 

making personal contact with potential voters, which Scanlon believed would ‘‘go miles making yourselves visible to the voters.’’ 107

Scanlon claimed, ‘‘This is your chance to prove that you are the 

candidates who are truly working for the tribal members.’’ 108

To effect this part of the plan, Scanlon had one of his employees 

drive C. Patencio around in a car rented by Scanlon specifically for 

C. Patencio’s personal visits with Tribal members. C. Patencio 

could not recall who that person was.109 Christopher Cathcart, 

Scanlon’s right-hand man, told Committee staff he was the one who 

drove C. Patencio around for the door-to-door meetings.110 In furtherance of the strategy, Scanlon also put together a walking map 

with voters and a document entitled ‘‘Palm Springs and Cathedral 

City Walk List’’ containing the names of tribal members and their 

addresses. C. Patencio, however, claimed the map was inaccurate 

and, therefore, unhelpful.111

3. Telephone 

The Committee has seen no evidence that either C. Patencio or 

Siva made the type of telephone calls outlined in Scanlon’s plan. 

C. Patencio did not recall making such telephone calls.112

4. Candidates’ Meeting 

On March 10, 2002, Scanlon hosted a candidate’s night for C. 

Patencio and Siva at the Wyndham Palm Springs Hotel.113 Among 

the documents reviewed by the Committee were a catering menu 

and a credit card authorization form from the Wyndham Palm 

Springs Hotel.114

Before the meeting, Scanlon’s team prepared separate two-sided 

color brochures for C. Patencio and Siva, which provided details of 
83 

115 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Candace 

Patencio MEET CANDACE PATENCIO!!) (undated); Capitol Campaign Strategies document 

production (no Bates number) (entitled ‘‘Virginia Siva MEET VIRGINIA SIVA!!’’) (undated). 116 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Candace Patencio MEET CANDACE PATENCIO!!’’) (undated). 117 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Virginia Siva MEET VIRGINIA SIVA!!’’) (undated). 118 Capitol Campaign Strategies document production (BB/AC 005407–12) (March 10, 2002). 119 Interview of Candace Patencio, former council member, Agua Caliente Band of Cahuilla Indians, by telephone (April 25, 2006). 120 Email between Michael Smith, Greenberg Traurig, and Jack Abramoff, Greenberg Traurig (GTG–E000059267) (March 19, 2002). 121 Id. 122 Email between Jack Abramoff, Greenberg Traurig, and Candace Patencio, Agua Caliente Band of Cahuilla Indians (GTG–E000057264) (April 1–2, 2002). 123 Id. (emphasis added). 124 Id. (emphasis added). 125 Id. 

the ‘‘Meet the Candidates’ Meeting.115 For C. Patencio, the flyer 

once again stressed the campaign themes of ‘‘honesty, effectiveness, 

and experience’’ that Scanlon had developed.116 Likewise, Siva’s 

flyer emphasized ‘‘Sincere Leadership’’ and ‘‘Inspired Results.’’ 117

Scanlon’s team also drafted C. Patencio’s and Siva’s talking 

points for the March 10, 2002, community meeting.118 C. Patencio 

told Committee staff that fewer than 20 people attended the meeting, most of whom were her family members.119

The elections were held on March 18, 2002; while Patencio won 

her race, Siva did not.120 In response to an email from his colleague Mike Smith, Abramoff attributed Siva’s loss to her failure 

to listen to Scanlon’s advice and work hard enough.121

E. C. PATENCIO AND M. PATENCIO PAVE THE WAY FOR ABRAMOFF AND

SCANLON

Despite Siva’s loss, Abramoff pressed forward. On April 1, 2002, 

Abramoff asked C. Patencio when he and Scanlon could visit the 

Tribal Council to pitch their services.122 Throughout his correspondence, Abramoff promised power, not just for the Tribe, but 

for her: ‘‘I think what we have in mind is helping the tribe set up 

the kind of political strength we have done for others, but doing it 

very carefully so that you are the ultimate controller of the political 

power.’’ 123

Abramoff continued: ‘‘To do this, unfortunately, we’ll have to get 

the approval of the current regime, I guess. I leave it to you to 

guide us on how to get in there. Again, Mike and I see the mission 

here as getting in, getting you guys organized so we can get the 

slot cap off and other things the tribe needs, and getting you into 

a position where the next time an election comes, we will win all 

the offices (and install you as Chairperson!!!).’’ 124

C. Patencio sought Abramoff’s guidance on how to introduce him: 

‘‘I’m not sure if an introductory letter from you [sic] firm searching 

for work is the best way or if the Tribe seeks you out through 

Moraino and I. What are your thoughts??? If the opportunity occurs 

I will push to seek for a qualified firm (YOU). I will see if in today’s 

meeting I can lay the foundation.’’ 125

In guiding C. Patencio on how to best introduce him and Scanlon 

to the Tribal Council, Abramoff suggested invoking the names of 

his other clients: ‘‘Tell them that you have heard from the Choctaws and Coushattas that their political folks are the best and that 
84 

126 Email from Jack Abramoff, Greenberg Traurig, to Candace Patencio, Agua Caliente Band of Cahuilla Indians (GTG–E000057623) (April 2, 2002). 127 Id. 128 Interview of Candace Patencio, former council member, Agua Caliente Band of Cahuilla Indians, by telephone (April 25, 2006). 129 Id. 130 Interview of Richard M. Milanovich, Chairman, Agua Caliente Band of Cahuilla Indians, by telephone (September 16, 2004). 131 Email between Jack Abramoff, Greenberg Traurig, and Candace Patencio, Agua Caliente Band of Cahuilla Indians (GTG–E000057279) (May 8, 2002). 132 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000057298) (June 12, 2002). 133 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000057295) (June 14, 2002). 134 Id. 135 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000059357) (June 19, 2002). 136 Interview of Candace Patencio, former council member, Agua Caliente Band of Cahuilla 

Indians, by telephone (April 25, 2006). 

you think it is a prudent thing for the tribe to invite us in to have 

a discussion as to what they can do for the tribe.’’ 126

Abramoff did not want his pre-existing relationship with C. Patencio to be known and so counseled: ‘‘if the others on the tribal 

council perceive that we are your guys (which we are!) it might 

make it difficult.’’ 127

At the time of Abramoff’s email to C. Patencio, the Tribe had a 

conflict-of-interest ordinance in place.128 When asked whether 

Abramoff’s intentions to help her secure the Chairman’s position 

once he and Scanlon were hired raised any red flags requiring her 

to disclose her relationship with Abramoff and Scanlon to the Tribal Council, C. Patencio responded ‘‘no’’—she took Abramoff’s words 

with a grain of salt’’ and thought Abramoff was simply ‘‘blowing 

smoke.’’ 129

M. Patencio first brought up Abramoff at a meeting or study session.130 Meanwhile, he and C. Patencio purportedly laid the groundwork with the swing vote on the Tribal Council by attempting to have her meet with Abramoff.131

While part of Abramoff’s plan involved promises of power, the 

other part apparently involved fear. On June 12, 2002, in an email 

entitled ‘‘great call with Candace,’’ Abramoff advised Scanlon: ‘‘Told 

her that Barona was courting us and she is now moving as fast as 

possible. moolah!!!’’ 132 Two days later, Abramoff wrote an email to Scanlon with the subject line, ‘‘can you smell money?’’ 133 In it, 

Abramoff reported: 

I just spoke with Candace. The tribe is calling us Monday 

to schedule our coming out for a pitch on the whole shooting match. They want Choctaw/Coushatta power. They 

think that if they don’t hire us Barona is going to do so. 

They are scared about that one! call [sic] me Saturday 

night or Sunday so we can plan our pitch. We need to go 

out there with a full blown plan.134

When Scanlon advised Abramoff that he wanted to depart early from Palm Springs, Abramoff replied: ‘‘The whole thing here is 

being pitched as a rush since we are ‘‘about to take on the Barona 

tribe—’’.135 During her interview, C. Patencio confirmed that she 

was concerned that the Barona Tribe was allegedly seeking 

Abramoff’s services, since she did not want that tribe to have the 

power.136
85 

137 Email between Michael Chapman and Jack Abramoff, Greenberg Traurig (GTG– 

E000057379) (June 24, 2002). 138 Id. 139 Id. 140 Email between Jack Abramoff, Greenberg Traurig, and Ilisa Gertner, Greenberg Traurig 

(GTG–E000059370) (June 17, 2002). 141 Email from Jack Abramoff, Greenberg Traurig, to DCCon (GTG–E000059329) (June 26, 

2002). 142 Email from Jack Abramoff, Greenberg Traurig, to Michael Smith, Greenberg Traurig 

(GTG–E000059332) (June 27, 2002). 143 Email from Jack Abramoff, Greenberg Traurig, to Allison Bozniak, Greenberg Traurig 

(GTG–E000057922–23) (June 27, 2002). 144 Id. 145 Id. 146 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000059428) (July 2, 2002). 

Before he and Scanlon met with the Agua Caliente, Abramoff apparently received advice and guidance on their presentation from 

Chapman and C. Patencio. Just two days before the meeting, Chapman wrote Abramoff, ‘‘Glad to learn you’re going out to Agua 

Caliente—I hope it proves to be fruitful! I am sure Candace will 

coach you.’’ 137

Chapman gave his own advice, ‘‘[R]emember their Post Office 

land exchange ordeal ... In addition, they have a great land management agreement with BLM [Bureau of Land Management] over 

joint management of their canyons–so some mention of DOI contacts, beyond BIA, may be useful!’’ 138

Abramoff confirmed, ‘‘Candace is being the usual wonderful help 

...’’ 139

Abramoff made arrangements for himself and Scanlon to travel 

by private jet to Palm Springs for their meeting with the Tribal 

Council.140 After the June 26, meeting with the Tribal Council, 

Abramoff reported to his colleagues, ‘‘I pitched them [the Agua 

Caliente] this morning on a $150K/month representation and they 

basically agreed (subject to formal approval of the same council— 

5 members—who just approved—next week). This is going to be a 

biggie!’’ 141 Abramoff wrote separately to his colleague Michael 

Smith, who had introduced him to Chapman: ‘‘Looks like we got 

’em! They vote next week, but after 4 trips here, tons of work and 

all sorts of political activities, I think we’re there.’’ 142

Thus, on June 27, Abramoff instructed his assistant Allison 

Bozniak to send a retainer agreement to M. Patencio.143 The retainer agreement called for a flat fee of ‘‘$150,000.00 per month 

plus reasonable out-of-pocket expenses.’’ 144 The agreement also 

provided that the ‘‘firm undertakes to not represent any other tribal government located within the geographical borders of the State 

of California during the duration of our representation of the 

Tribe.’’ 145

The deal was not as done as Abramoff believed, however. On 

July 2, Abramoff advised Scanlon, ‘‘[T]hings are not as hunky dorey 

as we thought out there. I just got off the phone with Candace. I 

have to be out there to meet them on Sunday.’’ 146 When Scanlon 

asked whether they would get paid, Abramoff assured him, ‘‘We’re 

going to get paid. We have the votes. We can ram it through, but 
86 

147 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000057397) (July 3, 2002). 148 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000057339) (July 5, 2002). 149 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Agua Caliente Global Political Strategy’’) (July 8, 2002) (prepared by Michael Scanlon, Capitol Campaign Strategies). 150 Id. 151 Id. 152 Id. 153 Id. 154 Id. 155 Id. 156 Id. 157 Id. 

Moraino and Candace want to get the others on board. They have 

3 votes, though.’’ 147

Before the meeting, Abramoff asked Scanlon to forward him a copy of Scanlon’s proposal to the Tribe, so that he could ‘‘be aware 

of where we are going on this, and push it[.]’’ 148

For the meeting, Scanlon prepared a document he called ‘‘Agua Caliente Global Political Strategy.’’ 149 Scanlon laid out a comprehensive political strategy ‘‘[t]o support and secure all federal objectives of the council’’ and ‘‘[t]o successfully negotiate an unlimited 

slot position compact for the tribe.’’ 150

As with the other Tribes, CCS’s strategy supposedly centered heavily on the use of customized databases. According to Scanlon, 

‘‘The true key to any successful political effort is its organizational 

design. For the compact negotiation campaign we have developed 

a two-tiered system.’’ 151 Scanlon described the first tier as 

‘‘compil[ing], classify[ing] and organiz[ing] the tribe’s existing natural resources into a national political network.’’ 152 Scanlon described the second part as ‘‘identify[ing], classify[ing], and 

organiz[ing] allies of the tribe.’’ 153 According to Scanlon, ‘‘[b]oth will be imported into your new custom built political databases.’’ 154

In the document, Scanlon elaborated on the ‘‘new custom built 

databases.’’ The first, the ‘‘Grassroots Database’’, Scanlon described 

as follows: 

We gather lists of your vendors, employees, tribal 

members[,] etc. and we import those lists into your new 

database. Our computer program will match the individuals or businesses with addresses, phone numbers, political registration and e-mail addresses (when available), 

and then sort them by FEDERAL election districts nationwide. The district breakdown in your database will from 

[sic] U.S. Senator down to State Representative. Once completed, we will be able to tap into this database and mobilize supporters in ANY election of your choosing nationwide in a matter of moments. At this point you will have 

a national political network. 155

Scanlon boasted that with this customized database, he could 

‘‘reach out and mobilize tens of thousands of voters almost instantaneously.’’ 156 Scanlon represented that ‘‘[t]his is an extremely powerful tool that is absolutely necessary if we are to be successful.’’ 157

Moreover, Scanlon’s proposal described an entirely separate ‘‘Qualitative Research Database’’: 
87 

158 Id. 159 Id. 160 Email from Holly Bowers, Greenberg Traurig, to Jack Abramoff, Greenberg Traurig (GTG– E000059380) (July 5, 2002). 161 Email from Jack Abramoff, Greenberg Traurig, to Michael Chapman (GTG–E000059404) 

(July 8, 2002). 162See Email from Holly Bowers, Greenberg Traurig, to Jack Abramoff, Greenberg Traurig 

(GTG–E000059380) (July 5, 2002). 163 Interview of Candace Patencio, former council member, Agua Caliente Band of Cahuilla 

Indians, by telephone (April 25, 2006). 164 Interview of Candace Patencio, former council member, Agua Caliente Band of Cahuilla Indians, by telephone (April 25, 2006). See also Interview of Richard M. Milanovich, Chairman, 

Agua Caliente Band of Cahuilla Indians, by telephone (September 16, 2004). 165 Agua Caliente document production (no Bates number) (entitled ‘‘Verbatim Excerpt—Tribal Council Meeting of Tuesday, July 9, 2002’’) (July 9, 2002) (excerpt only). 166 Id. 

This custom built database acts as the information center 

of our efforts. Over the next three weeks, our team will 

gather qualitative information on the allies and opponents 

related to our campaign and we store this information into 

this database. The research will include nearly every piece 

of information on the targets that is [sic] relevant to our 

campaign. In addition we will be waging a simultaneous 

effort to gather qualitative research on the key opponents 

of our position. This research can be classified as unfriendly, and is solely intended to give us the ammunition 

to fight on an even playing field if the battle turns nasty. 

Rest assured, if it does turn nasty, we will be far better 

positioned than our opponents. Once the research is gathered, it is then sorted by subject matter and made retrievable by a phrase search. This [sic] purpose of this is so 

that information can then be instantly disseminated to any 

audience we choose such as our universe of supporters, the 

press, third party interest groups or other interested parties.158

The total cost of Scanlon’s proposal: $5.4 million, with another $2 

million, should an ‘‘advertising fight’’ occur.159

On July 7, Abramoff and Scanlon departed by private jet for 

Palms Springs for their meetings with the Agua Caliente Tribal 

Council, and a presentation to the Council and membership.160 Before Abramoff and Scanlon made their pitch at the membership 

meeting, Abramoff finally met Chapman in person.161

Abramoff and Scanlon met with the Tribal Council on July 8, 

and the Tribal membership on July 9.162 Although Abramoff represented that Scanlon ‘‘work[ed] very closely with our firm [Greenberg Traurig],’’ at no point in the presentation did either disclose 

their financial relationship.163 Nor did they disclose the behind-thescenes conversations they had been having with C. Patencio and M. 

Patencio, or the election assistance they had rendered to C. 

Patencio and Siva.164

Abramoff built-up Scanlon, calling him ‘‘one of the top political 

and grass roots public affairs people in the United States’’.165 As 

he had before, Abramoff traded on the name of the Mississippi 

Band of Choctaw Indians (‘‘Choctaw’’).166 Abramoff also boasted 

about the efforts he and Scanlon had undertaken for the Coushatta 

Tribe of Louisiana (‘‘Louisiana Coushatta’’) and the Chitimacha 
88 

167 Id. 168 Id. 169 Id. 170 Id. 171 Id. Of course, that was true only by default. According to Fred Baggett, the national chairman of Greenberg Traurig’s public policy practice, Scanlon was free to work for other clients; 

indeed, Greenberg Traurig did not hire Scanlon precisely because he wanted to work on his own 

clients. Interview of Fred Baggett, chair, National Governmental Affairs Practice, Greenberg 

Traurig, in Washington D.C. (September 29, 2005). 172 Agua Caliente document production (no Bates number) (entitled ‘‘Verbatim Excerpt—Tribal Council Meeting of Tuesday, July 9, 2002’’) (July 9, 2002) (excerpt only). 173 Id. 

Tribe of Louisiana on their compact re-negotiations with the State 

of Louisiana.167

Although Abramoff and Scanlon were representing the Ysleta del 

Sur Pueblo of El Paso (‘‘Tigua’’), in direct conflict with the interests 

of the Louisiana Coushatta, Abramoff nevertheless claimed that 

‘‘we certainly don’t engage in the situation where we have two 

tribes that might have differing interests ‘cause unfortunately obviously tribes who are nearby to each other sometimes have the same 

interests or same market share ...’’ 168 Abramoff later continued: ‘‘If 

we work together with you we would not work for any other Tribe 

in California. That would be our approach.’’ 169

Abramoff spoke, too, about political contributions: 

Each of the tribes we work with we recommend that they 

exercise their right to make political contributions. However, we generally are very targeted and with the contribution recommendations we make ... we do strongly recommend and all of our tribes do give a lot of money politically. It’s very targeted and when it’s all basically added 

up we sort of like have a little ledger so to speak informally, see the money they spent politically and the money 

they spent contributions and the money they spent lobbying wise compared to what they get back so to speak, 

not only benefits that can’t be monetarized but also the actual appropriations. ... So we will recommend to the tribe 

or any of our clients that they contribute to certain specific 

Members that may have to them nothing do with what 

they’re doing, but we know that that Member will be able 

to control or influence a bill, that kind of thing.170

Scanlon picked up on the presentation. Scanlon claimed that his 

‘‘firm is in a strategic alliance with Jack and Greenberg meaning 

we only provide services to the clients of Greenberg Traurig.’’ 171

Scanlon described his operations as the ‘‘ground army for what 

Jack does.’’ 172 More specifically, Scanlon said: 

A force, a grassroots army of people of employees, of business owners, of people who live on your lands and anybody 

who’s made a buck off of you over the last ten to fifteen 

years and has a vested interest in seeing your future be 

better. Our job is to go out and find those people, educate 

those people on the issues that are important to the Tribe 

and objectives of Tribe as identified. Most importantly, it 

is to mobilize those people to ensure that the politicians 

get the message that the people are behind the position of 

the Tribe.173
89 

174 Id. 175 Id. 176 Interview of Candace Patencio, former council member, Agua Caliente Band of Cahuilla 

Indians, by telephone (April 25, 2006). 177 Id. 178 Id. 179 Id. 180 Id. 181 Agua Caliente document production (AC 0276–78) (July 9, 2002). 182 Id. 183 Id. 

Scanlon characterized his work as ‘‘technical,’’ ‘‘labor intensive’’ 

and ‘‘expensive’’.174 The cornerstone of this program was a ‘‘custombuilt database,’’ which Scanlon claimed he designed.175

After Abramoff and Scanlon’s presentation, the Tribal Council 

met to vote. C. Patencio admitted that she did not disclose her relationship with Abramoff or Scanlon, or the help they had given her 

on her election campaign, before the vote.176 She also admitted 

that she did not pay for any of the work that Scanlon and his team 

performed for her election bid.177 She said that Scanlon never 

asked to be paid for his services, and she never discussed how 

Scanlon would benefit from helping her election campaign.178 C. 

Patencio also claimed that people offer her free things all the time, 

and she did not find Abramoff and Scanlon’s supposed generosity 

odd.179 According to C. Patencio, she simply believed Abramoff and 

Scanlon helped her because they liked her.180

The Committee has considerable difficulty reconciling C. 

Patencio’s statements with the body of evidence before it. Even if, 

as C. Patencio claimed, she had not expressly agreed to help 

Abramoff and Scanlon secure contracts with the Tribe in exchange 

for their campaign assistance, a reasonable person with C. 

Patencio’s business education and political experience would have 

realized that Abramoff and Scanlon were providing her assistance 

as gratitude or because of C. Patencio’s intention to help them secure contracts with the Tribe. 

On July 2, 2002, the Tribal Council voted 3–0 to accept the contract with Greenberg Traurig. On July 11, 2002, Chairman 

Milanovich signed a retainer agreement with Greenberg 

Traurig.181 According to the contract, the Tribe retained Greenberg 

Traurig, 

[T]o assist the Agua Caliente Band of Cahuilla Indians 

(‘‘the Tribe’’) with all political activities related to obtaining a satisfactory outcome to gaming compact renegotiations, environmental matters and other policy and political goals in California. In addition, at the Tribe’s discretion, the Firm shall assist the Tribe with federal issues, including but not limited to matters concerning federal appropriations, specific needs of the tribe related to the U.S. 

Postal service and tax matters, general Washington, D.C. 

and selected national public relations activities, federalTribal relations and promotion of sovereignty.’’ 182

The cost: ‘‘$150,000.00 per month plus reasonable out-ofpocket expenses.’’183

Similarly, on July 23, the Tribal Council voted 3–2 to accept 

Scanlon’s contract. C. Patencio, M. Patencio, and Jeannette Prieto- 
90 

184 Email between Michael Scanlon, Capitol Campaign Strategies, and Jack Abramoff, Greenberg Traurig (GTG–E000059386) (July 16, 2002). 185 Id. 186 Agua Caliente document production (AC 0287–89) (July 24, 2002). 187 Id. 188 Id. 189 Id. 190 Id. 191 Email from Jack Abramoff, Greenberg Traurig, to Duane Gibson, Greenberg Traurig (GTG–E000057541) (September 18, 2002). 192 Email from Duane Gibson, Greenberg Traurig, to Neil Volz, et al., Greenberg Traurig (GTG–E000057613) (October 8, 2002). 

Dodd voted for the contract; Chairman Milanovich and Vice Chairman Gonzales Lyons voted against it. Before the Tribal Council 

voted, however, Chairman Milanovich argued against hiring Scanlon. According to Scanlon, Chairman Milanovich was ‘‘trying to 

sink it [Scanlon’s contract]—he has a whole bunch of Suncruz articles he is handing out at the meeting.’’ 184 Meanwhile, C. Patencio 

called to report to Abramoff on what was happening.185

On July 24, 2002, Scanlon apparently submitted a letter agreement between Scanlon Gould Public Affairs and the Tribe.186 According to the agreement, ‘‘the primary goal of Scanlon Gould is to 

execute public affairs and political strategies to ensure successful 

re-negotiation of the Tribe’s gaming compact.’’ 187 The letter agreement described the scope of the activities by reference to Scanlon 

Gould’s July 8, 2002 proposal.188 Unlike his written agreements 

with other Tribes, Scanlon specifically reserved Scanlon Gould’s 

right to use external firms: ‘‘Scanlon Gould will execute its duties 

by employing its internal political team (full time employees) and 

reserves the right to sub-contract with external firms when necessary.’’ 189 The Tribe agreed to pay Scanlon Gould $5,400,000 and 

agreed ‘‘to budget an additional $2,000,000.00 for advocacy efforts 

should the compact renewal campaign become intensive.’’ 190

F. ABRAMOFF AND SCANLON SEEK ADDITIONAL MONEY FROM THE

TRIBE

Once Abramoff and Scanlon locked up their contracts with the 

Agua Caliente, Abramoff began to seek more funding for his pet 

projects, as well as those of others, ostensibly designed to increase 

his and the Tribe’s standing in the eyes of Congressmen and Senators. In September 2002, Abramoff told his associate Duane Gibson that they needed ‘‘to move on Agua contributions asap.’’ 191

Abramoff and his team used the Tribe’s contributions to get ‘‘credit 

for delivering checks to certain members.’’ 192

Abramoff also sought money from the Tribe to cover the costs of 

his Sports Suites program. A master lobbying plan that Abramoff 

presented to the Agua Caliente laid out his rationale for why the 

Tribe should participate. 

Sporting and Event Tickets—Goal: provide Members and staff 

with courtesy tickets to sport games and other events, which 

help to create the relationships needed to advance issues important to the Tribe. Many of our Tribal clients participate in 

ownership of Executive Suites and Boxes at the MCI Center, 

FedEx Field, and Camden Yards (Baltimore), in order to get 

the tools for relationship building to advance your issues. The 
91 

193 Email from Duane Gibson, Greenberg Traurig, to Jack Abramoff, Greenberg Traurig 

(GTG–E000057000) (December 5, 2002) (attaching ‘‘DRAFT Agua Caliente Plan for the 108th 

Congress’’) (last page only). 194 Email from Candace Patencio, Agua Caliente Band of Cahuilla Indians, to Duane Gibson, 

Greenberg Traurig (GTG–E000057785) (January 10, 2003). 195 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. 

at 29 (September 29, 2004) (testimony of Richard M. Milanovich, Chairman, Agua Caliente Band 

of Cahuilla Indians). 196 Email between Michael Scanlon, Capitol Campaign Strategies, and Jack Abramoff, Greenberg Traurig (GTG–E000056773) (December 10, 2002). 197 Id. 198These figures do not include political, charitable, and other contributions the Agua Caliente 

made at Abramoff’s request. 199Discussion and analysis of how Abramoff and Scanlon successfully perpetrated their 

‘‘gimme five’’ scheme on the Tribe, on an entity-by-entity basis, is contained in Part 2 of the 

this Report. 200 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000057878) (March 5, 2003). 

Tribe should evaluate pooling its resources with other tribes so 

that it can utilize these effective assets as well.193

The Tribal Council approved the Tribe’s participation in the 

sports suites program in December 2002, 194 and paid $300,000 into 

the program.195

Pursuant to his agreement with the Tribe, Scanlon sought additional money under the Scanlon Gould contract. When it came time 

to solicit additional funds, Scanlon decided to leave little to chance. 

Scanlon and Abramoff manipulated the schedule so that Scanlon 

would make his presentation for more money in the absence of the 

two Tribal Council members who opposed the program. On December 10, Scanlon wrote: 

Well we got paid 5—and had in our contract that we may 

need an additional 2—but that we would have to come before the council to get it. So I did up a presentation—and 

we are asking for 1.785 on Thursday—The reason we are 

doing git [sic] Thursday is that Richard and Barbara are 

out of town. I could ask for the whole 2—but I though [sic] 

that would look strange—I could bump it up to 1.875? 

Whatta think? 196

Abramoff responded, ‘‘Absolutely!’’ 197

In less than two years, the Tribe paid Greenberg Traurig 

$3,079,816 in fees and expenses.198 Similarly, Scanlon collected 

$7,195,000 from the Agua Caliente during the relevant period and 

appears to have secretly split about 50% of his total profit from the 

Tribe with Abramoff.199

These substantial sums purchased no loyalty from Abramoff and 

Scanlon. When Scanlon complained about his dealings with C. 

Patencio, Abramoff counseled: ‘‘I think the key thing to remember 

with all these clients is that they are annoying, but that the annoying losers are the only ones which have this kind of money and 

part with it so quickly.’’ 200

G. ABRAMOFF AND SCANLON’S WORK FOR THE TRIBE

The Agua Caliente hired Abramoff and Greenberg Traurig ‘‘to assist the tribe with all political and lobbying activities relating to a 
92 

201 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. 

at 21 (September 29, 2004) (statement of Richard Milanovich, chairman, Agua Caliente Band 

of Cahuilla Indians). 202 Id. 203 Interview of Christopher Cathcart, associate, Capitol Campaign Strategies, in Washington, 

D.C. (October 6, 2004). 204 Interview of Chris Cathcart, associate, Capitol Campaign Strategies, in Washington, D.C. 

(October 6, 2004). 205 Agua Caliente document production (AC 0287–89) (July 24, 2002). 206See, e.g., Capitol Campaign Strategies document production (BB/AC04990–92) (January 29, 

2003); Capitol Campaign Strategies document production (BB/AC04993) (February 6, 2003); 

Capitol Campaign Strategies document production (March 12, 2003) (BB/AC04995); Capitol 

Campaign Strategies document production (BB/AC04996–98) (March 17, 2003); Capitol Campaign Strategies document production (BB/AC05000); Capitol Campaign Strategies document 

production (BB/AC05002–04) (March 26, 2003); Capitol Campaign Strategies document production (BB/AC05010) (April 2, 2003); Capitol Campaign Strategies document production (BB/ 

AC05012–15) (April 24, 2003); Capitol Campaign Strategies document production (BB/AC05004– 

48) (May 14, 2003); Capitol Campaign Strategies document production (BB/AC05050–54); Capitol Campaign Strategies document production (BB/AC05068–69) (July 10, 2003); Capitol Campaign Strategies document production (BB/AC05070) (July 22, 2003); Capitol Campaign Strategies document production (BB/AC05072–73) (July 24, 2003); Capitol Campaign Strategies document production (BB/AC05074–75) (August 4, 2003); Capitol Campaign Strategies document 

production (BB/AC05076–77) (August 14, 2003); Capitol Campaign Strategies document production (BB/AC05078–80) (August 26, 2003); Capitol Campaign Strategies document production 

(BB/AC05081) (September 8, 2003); Capitol Campaign Strategies document production (BB/ 

AC05082) (October 15, 2003); Capitol Campaign Strategies document production (BB/AC05083) 

(November 17, 2003); Capitol Campaign Strategies document production (no Bates number-BB/ 

AC05084) (November 24, 2003); Capitol Campaign Strategies document production (BB/ 

AC05085–86) (December 3, 2003); Capitol Campaign Strategies document production (BB/ 

AC05087–88) (December 4, 2003); Capitol Campaign Strategies document production (BB/ 

AC05089) (December 16, 2003); Capitol Campaign Strategies document production (BB/ 

AC05090) (December 26, 2003). 207 Interview of Christopher Cathcart, associate, Capitol Campaign Strategies, in Washington, 

D.C. (October 6, 2004). 208 Id. 209 Id. 210 Id. 211 Interview of Richard M. Milanovich, Chairman, Agua Caliente Band of Cahuilla Indians, 

by telephone (September 16, 2004). 

wide range of public policy issues.’’ 201 The Tribe hired Scanlon ‘‘to 

help the tribe with respect to pending gaming compact issues in 

California.’’ 202

From July 2002 to March 2004, Abramoff and his team represented the Agua Caliente in Washington, D.C. The Tribe has not 

complained to the Committee about the level or quality of the services that Abramoff and his team at Greenberg Traurig provided the 

Tribe. 

Scanlon hired a number of subcontractors to renegotiate the 

Tribe’s compact with the State of California.203 Scanlon subcontracted lobbyists and attorneys.204 Per his agreement, he operated 

as a turnkey operation.205 Scanlon and his team provided regular 

updates to the Tribe on its efforts.206

Among the work that Scanlon Gould performed, was a letterwriting campaign. Scanlon’s team set up tables with laptop computers and blank letters at the Tribe’s casino.207 As employees 

would come to the tables, Scanlon’s employees would brief them 

and ask them to sign letters to the Governor.208 Scanlon also had 

opinionmaker letters written to the Governor.209 That work was 

subcontracted out to Lunde Burger.210 After examining Scanlon’s 

work, the Tribe does not believe that Scanlon actually performed 

the work he had proposed when he pitched his contract to the 

Tribe.211
93 

212 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg 

Traurig (GTG–E000057616) (October 24, 2002). 213 Email from Candace Patencio, Agua Caliente Band of Cahuilla Indians, to Jack Abramoff, 

Greenberg Traurig (GTG–E000057834) (January 14, 2003). 214 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000057847–49) (January 29, 2003). 215 Id. 216 Id. 217 Email from Christopher Cathcart, Capitol Campaign Strategies, to Michael Scanlon, Capitol Campaign Strategies (January 21, 2003). 218 Email between Michael Chapman and Jack Abramoff, Greenberg Traurig (GTG– 

E000057842–43) (February 9, 2003). 219 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg 

Traurig (GTG–E000057842) (February 10, 2003). 

H. 2003 TRIBAL ELECTIONS

Even after the Agua Caliente hired Abramoff and Scanlon, the 

two continued to conspire about how to increase their influence 

over the Tribal Council. In October 2002, Scanlon wrote to 

Abramoff: 

I am working on setting them up right now for their elections next year. We are looking at Candice [sic] for Vice 

Chairman—which we are looking good on. We are also 

looking good at getting Virginia Elected [sic] under one 

scenario and Moreno is a lock. 

The most Likely [sic] scenario right now is Barbara become [sic] chairman, with Candice [sic] as Vice Chair, 

Moreno, Janette and Virginia on the council—which would 

give us 4 out of 5 all the time—and possibly 5 out of 5 if 

we play it the right way. 

This will be very very good for us.212

Later, C. Patencio emailed Abramoff asking for a time they could 

‘‘talk strategy for the up and coming election.’’ 213 Abramoff and 

Scanlon’s goal was to ensure that C. Patencio would win in an effort to oust their only opposition within the Tribe, Chairman 

Milanovich and Vice Chairman Gonzales-Lyons.214 When C. 

Patencio advised Abramoff that she and M. Patencio planned ‘‘to 

set [the Agua Caliente Vice Chairman] up’’, Abramoff offered his 

help: ‘‘let me know what we can do.’’ 215 Separately, he told Scanlon 

‘‘We need to make sure Candace wins and bye bye Barbara and 

Richard.’’ 216

Meanwhile, Scanlon and Cathcart discussed how to impact C. 

Patencio’s election: ‘‘[w]ant to touch base re the aguas too, i[sic] 

told candace we would help with her letter of intent, and of course, 

i[sic] assume we’ll be helping with the campaign.’’ 217

On February 9, 2003, Chapman urged Abramoff and Scanlon to 

assist their allies on the Tribal Council: ‘‘We definitely need to devise a strategy to help Candace—it is now or never! Since there are 

so few tribal members we should be able to do a breakdown of each 

potential vote to be cast.’’ 218 In response, Scanlon maintained that 

he had ‘‘been all over this for weeks’’ and already had ‘‘a pretty 

good plan in place.’’ 219

Ultimately, the Committee finds that Scanlon devoted nowhere 

near the time and resources to C. Patencio’s election bid in 2003 
94 

220 Interview of Christopher Cathcart, associate, Capitol Campaign Strategies, in Washington, 

D.C. (October 6, 2004). 221 Email between Duane Gibson, Greenberg Traurig, and Jack Abramoff, Greenberg Traurig (GTG–E000057623) (November 12, 2002). 222 Id. 223 Id. 224 Id. 225 Email between Michael Chapman and Jack Abramoff, Greenberg Traurig (GTG– 

E000057342) (July 12, 2002). 

as he had in 2002. Scanlon Gould wrote C. Patencio’s platform 

statement and may have made door signs or mail pieces for her.220

In the 2003 elections, C. Patencio lost her race. Within months, 

the Committee would start its investigation, and the Tribe would 

learn the truth about Abramoff and Scanlon’s assistance to C. 

Patencio and Siva in their elections. It would also learn about their 

secret partnership. 

I. CHAPMAN AND SIERRA DOMINION CONSULTING

On November 12, 2002, Abramoff’s associate Duane Gibson, who 

was the client manager for the Agua Caliente account, discovered 

charges on the account with which he was unfamiliar. Gibson inquired of Abramoff: 

[O]n the Agua bill, there are two items—$10K for consulting from Michael Chapman and $5K for consulting for 

Sierra Dominion Financial Resources. These were part of 

the itemized expenses on the draft bill that I am reviewing. I do not know what the arrangements are for work by 

these people, and want to make sure that they are authorized. These items constitute $15K of the $25 K [sic] in expenses. Is this ok? 221

Abramoff replied, ‘‘One is the finders [sic] fee for Chapman and 

the other is one I will tell you about. they [sic] come out of our retainer, and should not be listed to the client ever. Please make sure 

they are never on the bill which goes to them.’’ 222

When Gibson alerted Abramoff to the possibility that Chapman’s 

fees might have appeared on the previous bill, Abramoff panicked: 

‘‘This is a disaster!!!!!!’’ 223 Gibson subsequently allayed Abramoff’s 

fears by assuring him Chapman’s fees had only appeared on the 

draft bill.224

Just what was the nature of the payments to Chapman and Sierra Dominion, and why was Abramoff determined for them not to 

appear on the Agua Caliente’s bill? The rest of this Chapter attempts to answer these questions. 

1. Payments to Chapman 

Shortly after the 2002 Agua Caliente election, Chapman inquired: ‘‘What are you thinking the terms of a consultancy might 

be? Curious, and want to know what the incentives might be in assisting you in landing new clients—especially, since I may be able 

to pitch your services later tonight!’’ 225

Abramoff responded: 

I think we can organize $10/month on a Agua Caliente 

sized representation (the firm’s profit on that kind of representation is around 20$, which is $30k/month, and I can 
95 

226 Id. 227 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000057372) (July 9, 2002). 228 Interview of Michael Chapman, by telephone (March 31, 2006). 229 Id. 230 Email from Michael Chapman to Jack Abramoff, Greenberg Traurig (GTG–E000059446) (July 24, 2002). 231 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000059446) (July 24, 2002). 232 Email from Jack Abramoff, Greenberg Traurig, to Michael Chapman (GTG–E000059444) (July 24, 2002). 233 Interview of Michael Chapman, by telephone (March 31, 2006). 234See Michael Chapman document production (no Bates number) (September 2002 through March 2004) (Invoices from Michael Chapman to Jack Abramoff). 235Greenberg Traurig document production (GTG 005390–ACCT–AC) (undated) (Greenberg 

Traurig Vendor Payments Report for Michael Chapman; Fifteen Greenberg Traurig checks to 

Michael Chapman, dated September 13, 2002 to March 3, 2004; Invoices from Michael Chapman 

to Greenberg Traurig, dated September 3, 2002 through March 2004). 

probably get them to give up 1⁄3 of that). On the grassroots 

budget, it is a little trickier, because the margin is very 

tight (Mike gets his fee from the Greenberg side), and 

most of that is spend [sic] as direct costs.226

After the Agua Caliente approved Greenberg Traurig’s contract, 

Abramoff wrote to Scanlon: ‘‘We should give this guy [Chapman] a 

small tip out of the gimme five money too. I want him to have 

mega incentive to scan the nation and hook us up with all his 

friends.’’ 227 Chapman told the Committee during his interview that 

Abramoff told him that ‘‘he would take care of me’’ once Abramoff 

secured Agua Caliente as a client.228 Chapman claimed that 

Abramoff did not make this offer, until after Abramoff and Scanlon 

had secured contracts with the Tribe.229

Shortly thereafter, Chapman once again inquired into the ‘‘consulting’’ arrangement: ‘‘I am eager to learn what the final dynamics 

of a consultancy might be with Greenberg, while also hearing what 

might be a practical consideration for the political organizing contract.’’ 230 Abramoff immediately wrote to Scanlon: ‘‘This guy delivered for us. he [sic] wants to know what he can get from the pot. 

I will give him $10k/month from GT, but we should give him a tip 

from the grass roots. I think we should do $100k, but not from the 

first traunche. I told him that you budget this stuff very, very 

tightly, but might be able to eek out something. I don’t want to 

waste money, but he clearly has a lot of contacts and could get us 

a ton of biz.’’ 231 That same day, Abramoff reverted to Chapman, 

and committed to giving him ‘‘additional funds on the effort at 

Agua’’ that would ‘‘run the life of the representation of Agua.’’ 232

Chapman confirmed to Committee staff that Abramoff had 

Greenberg Traurig pay him $10,000/month.233 Beginning in September 2002 and ending in March 2004, Chapman submitted invoices to Greenberg Traurig for payment. The invoices requested 

payment of a $10,000 retainer, which was purportedly ‘‘associated 

with work on the Agua Caliente Band of Cahuilla Indians’ account.’’ 234

Per Abramoff and Gibson’s instructions, Greenberg Traurig paid 

Chapman a total of $171,482.48 235 over the course of the Agua 

Caliente retainer. The payments are detailed below: 

Payments from Greenberg Traurig to Michael Chapman 

09/13/02 ................................................................................................... $10,489.81 
96 

236Michael Chapman document production (no Bates number) (entitled ‘‘Invoice from Michael 

Chapman to Greenberg Traurig’’) (September 3, 2002 ). 237Michael Chapman document production (no Bates number) (entitled ‘‘Invoices from Michael 

Chapman to Greenberg Traurig’’) (September 3, 2002 through February 2004). 238 Interview of Michael Chapman, by telephone (March 31, 2006). See Interview of Duane 

Gibson, former associate, Greenberg Traurig, in Washington, D.C. (September 12, 2002). 239See Greenberg Traurig document production (GTG–005416–ACCT–AC) (April 10, 2003) 

(Check Requests, signed by Jack Abramoff). 240 Interview of Duane Gibson, former associate, Greenberg Traurig, in Washington, D.C. (March 17, 2006). 241 Id. 242 Interview of Michael Chapman, by telephone (March 31, 2006). 243 Id. 244 Id. 245 Id. 

Payments from Greenberg Traurig to Michael Chapman—Continued 

10/10/02 ................................................................................................... $10,000.00 

11/25/02 ................................................................................................... $10,000.00 

02/04/03 ................................................................................................... $10,000.00 

03/11/03 ................................................................................................... $10,000.00 

03/17/03 ................................................................................................... $10,000.00 

04/11/03 ................................................................................................... $10,000.00 

07/08/03 ................................................................................................... $10,000.00 

08/06/03 ................................................................................................... $20,992.67 

08/11/03 ................................................................................................... $10,000.00 

09/22/03 ................................................................................................... $10,000.00 

10/31/03 ................................................................................................... $10,000.00 

12/19/03 ................................................................................................... $20,000.00 

01/26/04 ................................................................................................... $10,000.00 

03/03/04 ................................................................................................... $10,000.00 

Total ................................................................................................. $171,482.48 

Except one request for expense reimbursement, 236 the invoices 

from Chapman to Greenberg Traurig listed the purpose of the payment request as ‘‘Retainer which is associated with work on the 

Agua Caliente Band of Cahuilla Indians’ account.’’ 237 According to 

Chapman, Abramoff told him how to characterize and phrase the 

invoices to Greenberg Traurig.238 On internal Greenberg Traurig 

accounting forms, Abramoff described the payment as a consulting 

fee.239

During its interview of Duane Gibson, Committee staff inquired 

into the nature of the services Chapman provided. Gibson, who was 

the Agua Caliente client manager, said that Chapman provided 

consulting services on the Agua Caliente account.240 He said he 

had substantive conversations with Chapman about issues affecting the Tribe before Congress.241

During his interview with Committee staff, however, Chapman 

was unequivocal: the $10,000 was not a consulting fee and he did 

not provide substantive advice on issues facing the Agua Caliente 

or otherwise work on the Agua Caliente account.242 Chapman was 

clear that the money he received was a finder’s fee or referral fee, 

for helping Abramoff and Scanlon secure the Agua Caliente account 

and to help them secure other tribal business.243 Chapman said he 

would also give Abramoff or Gibson a ‘‘heads up’’ whenever C. 

Patencio was getting frustrated because she could not reach them 

on the telephone.244 Chapman did say he spoke with Gibson about 

once every other week, and did exchange e-mails with him.245

Chapman said that Gibson was interested in expanding Greenberg 
97 

246 Id. 247 Interview of Michael Chapman, by telephone (March 31, 2006). 248 Interview of Candace Patencio, former council member, Agua Caliente Band of Cahuilla 

Indians, by telephone (April 25, 2006). 249 Id. 250 Email between Allison Bozniak, Greenberg Traurig, and Jack Abramoff, Greenberg Traurig 

(GTG–E000034178) (September 12, 2002). 251 Email from Michael Chapman to Jack Abramoff, Greenberg Traurig (GTG–E000059566) 

(September 24, 2002) (emphasis added). 252 Id. 253 Email from Michael Chapman to Michael Scanlon, Capitol Campaign Strategies (GTG– 

E000057596) (October 9, 2002). 

Traurig’s tribal business, and solicited Chapman for his suggestions for other, potential accounts.246

Around this time, Chapman said he told C. Patencio about his 

finder’s fee from Abramoff.247 C. Patencio likewise told the Committee that after the Agua Caliente had hired Abramoff, Chapman 

told her that Abramoff had put him on a retainer to help Abramoff 

land other tribal accounts.248 C. Patencio, however, did not know 

the amount, or that Abramoff was paying Chapman from the 

Tribe’s retainer.249

Although Chapman submitted invoices ostensibly for work related to the Agua Caliente account, it appears from internal Greenberg Traurig billing records that Abramoff did not bill the payments to Chapman as expenses to the Tribe. Greenberg Traurig instead paid Chapman out of the monthly retainer funds it received 

as fees from the Tribe.250 It thus appears the Tribe was probably 

not injured in any meaningful way by this, if at all. 

Chapman also received money from Scanlon’s Capitol Campaign 

Strategies (‘‘CCS’’), but not right away. After Scanlon secured the 

Agua Caliente representation, months passed and Chapman did 

not receive any payment from Scanlon. He then sent the following 

email to Abramoff: ‘‘I never received any inquiry at all from 

Scanlan [sic]—which I thought was a little strange, since he was 

‘sitting pretty’ because of my intervention! ... In fact, I was going 

to ask you to ask him for a campaign contribution, over and beyond 

the payment, since his firm seems to have benefitted the most from 

my Agua intervention!’’ 251 Chapman continued, ‘‘I rely on your instincts and sense of necessity to guide my motivations!’’ 252

On October 8, 2002, Scanlon had CCS pay Chapman $100,000. 

Chapman, however, sought more. Just one day later, Chapman 

wrote Scanlon: 

When Jack first broached the terms of a finder’s fee—we 

discussed this initial payment as the fee for the first $4 

million and then if [sic] was necessary for you to go into 

the second phase and expend another $4 million that another comparable fee would be forthcoming. Is this how 

you understand it? I know the tribe has approved $8 million in their budget in anticipation of a Phase II—let me 

know if we’re on the same page! 253

The Committee finds no evidence establishing that Chapman received further payments from Scanlon or his companies. 
98 

254See, e.g. Greenberg Traurig document production (GTG005518–ACCT–AC) (January 2, 

2003). Julie Doolittle’s husband is Congressman John T. Doolittle. 255 Email between Jack Abramoff, Greenberg Traurig, and Allison Bozniak, Greenberg Traurig 

(GTG–E000034178) (September 12, 2002); Email from Allison Bozniak, Greenberg Traurig, to 

Jack Abramoff, Greenberg Traurig (GTG–E000057489) (September 30, 2002). 256 Email from Joe Reeder, Greenberg Traurig, to Rudy DeLeon (GTG–E000121933) (March 

7, 2003). 257 Id. 258 Id. 259 Email between Allison Bozniak, Greenberg Traurig, and Jack Abramoff, Greenberg Traurig (GTG–E000121929) (March 7–9, 2003). 260 Email between Jack Abramoff, Greenberg Traurig, and Allison Bozniak, Greenberg Traurig (GTG–E000121929) (March 8, 2003). 

2. Payments to Sierra Dominion 

Sierra Dominion Financial Solutions, Inc. (‘‘Sierra Dominion’’) is 

a company located in Oakton, VA, and headed by Julie Doolittle.254

Over the course of the Agua Caliente retainer, Greenberg Traurig 

paid Sierra Dominion $66,690.42 as detailed below: 

Payments from Greenberg Traurig to Sierra Dominion 

09/20/02 ................................................................................................... $6,612.90 

10/10/02 ................................................................................................... $5,000.00 

11/25/02 ................................................................................................... $5,000.00 

01/13/03 ................................................................................................... $10,077.52 

07/02/03 ................................................................................................... $5,000.00 

07/22/03 ................................................................................................... $5,000.00 

08/06/03 ................................................................................................... $5,000.00 

09/25/03 ................................................................................................... $5,000.00 

11/25/03 ................................................................................................... $5,000.00 

12/29/03 ................................................................................................... $5,000.00 

01/26/04 ................................................................................................... $5,000.00 

02/19/04 ................................................................................................... $5,000.00 

Total ................................................................................................. $66,690.42 

While Sierra Dominion apparently provided no services to or for 

the benefit of Agua Caliente, almost all of the money paid to Sierra 

Dominion came out of the monthly retainer that the Agua Caliente 

paid to Greenberg Traurig.255 So the Tribe was probably not injured in any material way. 

One payment of $5,000 to Sierra Dominion, however, was billed 

to the Agua Caliente as an expense in September 2002, and the 

Tribe, in fact, paid the expense in October 2002. This gives rise to 

concerns that Abramoff defrauded the Tribe, because the payments 

were not used for the benefit of the Agua Caliente; rather, 

Abramoff apparently hired Doolittle to work on an event, ‘‘The Spy 

Game’’ at the Spy Museum in Washington, D.C., which Abramoff 

wanted as a fundraiser for his personal charity, the Capital Athletic Foundation (‘‘CAF’’). 

The event was originally scheduled for March 26, 2003.256 The 

event was supposed to honor Jim Kimsey, AOL Founding CEO and 

Chairman, with CAF’s ‘‘Lifetime Achievement Award.’’ 257 The CAF 

advertised that participants would ‘‘win up to $50,000 in 

prizes.’’ 258 Prizes included airline vouchers, portable DVD players, 

digital cameras, and tickets for Wizards [basketball], Caps [hockey], and Redskins [football] games.259 Abramoff also considered a 

trip to Scotland as a prize.260

The Spy Museum event never happened. According to a CAF notice listing Doolittle as the Director of Community Relations for the 
99 

261See ‘‘The Capital Athletic Foundation’s ‘‘The Spy Game’’ Important Event Update’’ (un- dated). 262 Email between Julie Doolittle, Sierra Dominion Financial Solutions, and Linsey Crisler, Greenberg Traurig (GTG–E000069554) (June 30, 2003). 263 Id. 264 Email from Jack Abramoff, Greenberg Traurig, to Linsey Crisler, Greenberg Traurig (GTG–E000069554) (July 7, 2003). 265 Email from Linsey Crisler, Greenberg Traurig, to Jack Abramoff, Greenberg Traurig (GTG–E000069550) (July 7, 2003). 266 Email from Jack Abramoff, Greenberg Traurig, to Linsey Crisler, Greenberg Traurig (GTG–E000069550) (July 7, 2003). 267 Email from Julie Doolittle, Sierra Dominion Financial Solutions, to Linsey Crisler, Green- berg Traurig (GTG–E000069555) (July 6, 2003). 268 Email from Jack Abramoff, Greenberg Traurig, to Julie Doolittle, Sierra Dominion Finan- cial Solutions (GTG–E000069555) (July 6, 2003). 269 Email from Jack Abramoff, Greenberg Traurig, to Julie Doolittle, Sierra Dominion Finan- cial Solutions (GTG–E000069551) (July 7, 2003). 270 Interview of Richard Milanovich, Chairman, Agua Caliente Band of Cahuilla Indians, by telephone (September 16, 2004). 271 Id. 272 Id. 273 Id. 

CAF, the event was postponed due to the United States’ commencement of military operations in Iraq.261

There is no evidence that Doolittle knowingly participated in 

Abramoff’s funding arrangement. To the contrary, the Committee 

possesses evidence that Abramoff attempted to conceal his funding 

source from Doolittle. In June 2003, Doolittle inquired about the 

status of her retainer.262 Abramoff’s assistant Linsey Crisler responded, ‘‘Accounting tells me that your check in [sic] processed, 

but we are waiting for the client to pay their bill before we can distribute any funds. As soon as we have their money wired to us, 

your check will be cleared for payment.’’ 263

Although true, Abramoff scolded Crisler, ‘‘This is not OK with 

me. I want her paid asap. She [sic] should not be told that her payments are dependent on anything. Who told you that?’’ 264

Crisler explained, ‘‘I was told by Accounting that we couldn’t pay 

any bills to outside consultants if there wasn’t money in the retainer.’’ 265

Abramoff replied, ‘‘Thanks. just [sic] make sure she is not unpaid 

at any point or told that her payment is dependent on anything.’’ 266

When Doolittle told Crisler, that she ‘‘was not aware that my retainer was dependent on the payment from a client,’’ 267 Abramoff 

assured her, ‘‘It is absolutely not dependent.’’ 268 He then assured 

Doolittle, ‘‘I will speak with Linsey to get this moving.’’ 269

J. CONCLUSION

Following The Washington Post article, in February 2004, Agua 

Caliente Chairman Milanovich met with Scanlon in Washington, 

D.C.270 At the meeting, Milanovich recalled, Scanlon described the 

article as an attack piece, and asked the Tribe to write a letter to 

The Post to help Scanlon and Abramoff.271 The Tribe declined to 

do so.272

Subsequently, during a telephone conversation with Duane Gibson, Milanovich recalled Gibson also asking the Tribe to send a 

similar letter to The Post in support of Abramoff.273 Indeed, 

Milanovich told Committee staff, Gibson said he hoped the Tribe 
100 

274 Id. 275 Interview of Duane Gibson, former associate, Greenberg Traurig, in Washington, D.C. 

(March 17, 2006). 276 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. 

at 52 (September 29, 2004) (Prepared statement of Richard M. Milanovich, Chairman, Agua 

Caliente Band of Cahuilla Indians). 277 Id. 

would not cooperate with this Committee’s investigation.274 When 

asked, Gibson did not recall ever expressing a preference on whether the Tribe should cooperate with the Committee’s investigation.275

At the beginning of April, the Tribe suspended its contracts with 

Greenberg Traurig and Scanlon Gould.276 Concerning attempts to 

manipulate the Tribal elections, the Tribe suspended certain individuals from any appointed role in Tribal government.277
(101) 

1 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000001141) (February 19, 2002). 2From the pamphlet The Tiguas People of the Sun, obtained from the Tigua Indian Cultural 

Center: ‘‘Ysleta del Sur Pueblo is the historical and legal name of the American Indian tribe 

commonly known in the El Paso, Texas area as the ‘‘Tiguas’ or ‘‘Tigua Indians’’. ‘‘Tigua’’ or 

‘‘Tihua’’, an even older spelling, is the Spanish phonetic spelling of the term ‘‘Tiwa’’ and is the 

name of the Indian language spoken by this tribe.’’ 3 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000001141) (February 19, 2002). 

CHAPTER V 

YSLETA DEL SUR PUEBLO (TIGUA) 

ABRAMOFF: Fire up the jet baby, we’re going to El Paso!! 

SCANLON: I want all their MONEY!!! 

Email between Jack Abramoff and Michael Scanlon, February 6, 2002 

I wish those moronic Tiguas were smarter in their political 

contributions. I’d love us to get our mitts on that moolah!! 

Oh well, stupid folks get wiped out. 

Email from Jack Abramoff to Ralph Reed, February 11, 2002 

A rattlesnake will warn you before it strikes. We had no 

warning. They did everything behind our back. 

Carlos Hisa, Lieutenant Governor, Ysleta del Sur Pueblo, commenting on 

Abramoff and Scanlon, November 17, 2004 

A. INTRODUCTION

‘‘Is life great or what!!!’’ exclaimed Jack Abramoff to his friend 

and business partner Michael Scanlon on February 19, 2002.1 Few 

would have quibbled with Abramoff at the time. The two men enjoyed a secret partnership, their self-styled ‘‘gimme five’’ scheme. In 

less than one year, it had yielded $6 million in ill-gotten gains. 

Over the next couple years, it would generate almost $36 million 

more. In February 2002, the money flowed; life was indeed great 

for Jack Abramoff and Michael Scanlon. 

At the same time, life was not so good for the Ysleta del Sur 

Pueblo Indian Tribe of El Paso, Texas (‘‘Tigua’’).2 The Tribe was 

fighting for its financial life in the Texas courts and legislature, 

trying to keep open the doors to its Speaking Rock Casino. Indeed, 

Abramoff penned his ‘‘Is life great or what’’ email in reaction to a 

front-page El Paso Times article reporting that the Tigua had just 

terminated 450 casino employees.3

At the beginning of 2002, little did the Tigua know that Abramoff 

and Scanlon had played a role in thwarting the Tribe’s efforts to 

keep open its casino. Little could the Tribe know that it would soon 

become another victim of the duo’s ‘‘gimme five’’ scheme. 
102 

4The Tigua Indians of Texas (visited March 23, 2006) <http://www.texasindians.com/ 

tigua.htm> (providing a basic history of the Tigua). 5Tigua Indians (visited March 23, 2006) <http://www.tsha.utexas.edu/handbook/online/articles/TT/bmt45.html> (detailing the history of the Tigua); Thomas A. Green, Folk History and 

Cultural Reorganization: A Tigua Example, The Journal of American Folklore v. 89, no. 353, 

pp. 310–18 (1976). 6The Tigua Indians of Texas (visited March 23, 2006) <http://www.texasindians.com/ 

tigua.htm> (providing a basic history of the Tigua). 7 Id.; Clayhound Web (visited March 23, 2006) <http://www.clayhound.us/sites/ysleta.htm> (describing the history of the Tigua). 8Tigua Indians (visited March 23, 2006) <http://www.tsha.utexas.edu/handbook/online/articles/TT/bmt45.html> (detailing the history of the Tigua). 9The Tigua Indians of Texas (visited March 23, 2006) <http://www.texasindians.com/ 

tigua.htm> (providing a basic history of the Tigua); Tigua Indians (visited March 23, 2006) <http://www.tsha.utexas.edu/handbook/online/articles/TT/bmt45.html> (detailing the history 

of the Tigua). 10Tigua Indians (visited March 23, 2006) <http://www.tsha.utexas.edu/handbook/online/articles/TT/bmt45.html> (detailing the history of the Tigua). 11 Id. 12Texas v. del Sur Pueblo, 220 F.Supp.2d 668, 673 (W.D. Tex. 2001). 13 Id. 14 Id. 15 Id. 16 Id. 17 Id. 18 Id. 

B. BACKGROUND ON THE TRIBE

The Tigua are the only Pueblo tribe still residing in Texas.4 Although there are several versions of their migration to Texas, most 

believe that the Tigua were once inhabitants of Pueblo Gran 

Quivera, south of modern-day Albuquerque, New Mexico.5 In 1680 

the Pueblo Indians revolted against the Spanish and drove them 

out of New Mexico.6 Some Ysleta Pueblo Indians either by force or 

by choice left with the Spanish and joined the first migration of 

Tigua from Gran Quivera in El Paso.7

The Tigua follow a typical Pueblo governing organization with a 

cacique or religious leader appointed by the tribal council, a governor, lieutenant governor, war captain, and tribal council working 

together to run the government.8

In 1751 the King of Spain granted the Tigua thirty-six square 

miles of land upon which they built their Pueblo and a mission, 

which is now the oldest mission in Texas.9 Through extreme poverty and deceit by land hungry speculators, the Tigua lost all of 

this land.10 However, in 1967 the State of Texas finally recognized 

the Tigua as a tribe.11

In 1968, the Federal Government recognized the Tigua as an Indian tribe but simultaneously transferred responsibility for the 

Tribe to the State of Texas.12 Texas administered the Tribe’s affairs, which included holding the Tribe’s 100-acre reservation in 

trust and providing economic development funds to the Tribe.13 In 

1983, however, Texas became concerned that its trust relationship 

with the Tribe violated state constitutional law.14 Consequently, 

the United States and the Tribe began the process of granting the 

Tribe federal trust status.15 The culmination of those efforts came 

in the form of the 1987 Restoration Act, which established a trust 

relationship between the Federal Government and the Tribe.16

In 1993, the Tigua opened its Speaking Rock Casino near El 

Paso, Texas.17 This casino offered bingo games and Las Vegas-style 

gaming activities, and was a significant source of revenue for the 

Tribe.18 In 1999, however, based on an interpretation of the Tribe’s 
103 

19 Id. 20 25 U.S.C.S. § 1300g–6 (2001). 21Fifth Circuit Rules Against Tribe in State of Texas v. Ysleta Del Sur Pueblo (visited Mar. 

23, 2006) http://www.indiangaming.org/info/pr/press-releases–2002/texas-v-ysleta.shtml (describing the Tigua casino, Speaking Rock Casino); Texas v. del Sur Pueblo, 220 F.Supp.2d 668 

(W.D. Tex. 2001). 22 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. at 113 (November 2, 2005) (prepared statement of David Sickey, Councilman, Coushatta Tribe 

of Louisiana). 23 Id. 24 Indians Bet on casino bills/Texas Legislature May Settle Legal Dispute Targeting Tribe’s 

Casino Plans, Houston Chronicle, March 25, 2001; Email from Wilson Padgett to DCChoctaw (SENCREA 10/04 000001) (March 26, 2001) (attaching James Kimberly’s text). 25 Email from Brian Mann, American International Center, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000000626) (November 22, 2001) (attaching Gary Susswein, Two More 

Tribes Are Ready To Join Casino Battle, Austin American Statesman, November 22, 2001). 26 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. at 113 (November 2, 2005) (prepared statement of David Sickey, Councilman, Coushatta Tribe 

of Louisiana). Accord ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Af- fairs, 109th Cong. at 19 (November 2, 2005) (statement of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana). 27 Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 28 Id. 

1987 Restoration Act, the State of Texas brought a legal action 

challenging the Tribe’s ability to operate the casino.19 The Restoration Act provides that ‘‘[a]ll gaming activities which are prohibited 

by the laws of the State of Texas are hereby prohibited on the reservation and on lands of the tribe.’’ 20 The State of Texas argued 

that this provision prohibited the Tiguas from operating any type 

of gaming that was not allowed under Texas law, and that the 

gaming activities offered at the casino were prohibited by Texas 

law. The Fifth Circuit, in an unpublished opinion, affirmed a decision by the Texas district court agreeing with the State’s argument 

thereby forcing the Tribe to close its casino in 2002.21

C. ABRAMOFF, SCANLON, AND REED WORK AGAINST THE TIGUA

The Committee has seen no evidence suggesting that Jack 

Abramoff, Michael Scanlon, or Ralph Reed had any influence over 

the State of Texas’ decision to file suit against the Tigua in 1999. 

In fact, it was not until 2001, after the suit was well under way, 

that Abramoff and Scanlon took an interest in the Tigua and its 

fight with Texas. 

Abramoff and Scanlon’s mutual client the Coushatta Tribe of 

Louisiana (‘‘Louisiana Coushatta’’) long understood that legalized 

gaming in Texas would erode its casino’s customer base and revenue.22 The majority of the Louisiana Coushatta casino’s customers 

are from Texas, particularly the Houston area.23

While the State of Texas was pursuing its case to close the 

Tigua’s Speaking Rock Casino,24 press reports indicated that another tribe, the Alabama-Coushatta, was considering opening its 

own casino in eastern Texas.25 Abramoff and Scanlon were insistent with the Louisiana Coushatta Tribal Council that Texas was on 

the verge of legalizing gaming.26 Abramoff and Scanlon said that 

if the Tigua succeeded in its efforts to keep open its casino, the 

State of Texas would have no choice but to allow the Alabama 

Coushatta to have a casino.27 The Tribe therefore authorized 

Abramoff and Scanlon to pursue anti-gaming efforts in Texas 

against the Tigua and the Alabama Coushatta.28
104 

29 Cornyn is U.S. Senator John Cornyn of Texas, who was then the Attorney General for the 

State of Texas. 30 Email between Jack Abramoff, Greenberg Traurig, and Ralph Reed, Century Strategies (GTG–E000023259–61) (November 12, 2001). 31 Id. 32 Id. 33 Email from Ralph Reed, Century Strategies, to Jack Abramoff, Greenberg Traurig (GTG– E000023274) (November 12, 2001). 34 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg Traurig (GTG–E00023240–41) (November 13, 2001) (attaching Gary Scharrer, Tiguas seek support with state, DC ads, El Paso Times, November 13, 2001). 35 Id. Later that day, Abramoff forwarded an email from Isidro Garza to Reed. See Email from Jack Abramoff, Greenberg Traurig, to Ralph Reed, Century Strategies (GTG–E000023257) (November 12, 2001). Abramoff apparently believed that the Kickapoo nation would help them on 

Tigua. Id. To date, the Committee has not learned what, if any, assistance the Kickapoo nation 

rendered. 36 Email between Ralph Reed, Century Strategies, and Jack Abramoff, Greenberg Traurig (GTG–E000023240) (November 13–14, 2001). 37 Id. 38 Id. 39 Email between Isidro Garza, Kickapoo Traditional Tribe of Texas, and Jack Abramoff, 

Greenberg Traurig (GTG–E000023504) (November 15, 2001). 40 Id. Other than Abramoff’s email, the Committee has seen no evidence that such a call occurred. 

To pursue a grassroots effort against the Tigua, Abramoff turned 

once again to his long-time friend and business associate Ralph 

Reed. On November 12, 2001, Abramoff wrote to Reed: ‘‘Remember 

I mentioned the NIGC [National Indian Gaming Commission] 

today? We are going to get them on the Alabama Coushattas and 

I told our guy to get them on the Tiguas as well. Cornyn 29 needs 

to get Indians to lead the way. Let us help with that.’’ 30

Reed replied, ‘‘great work. Get me details so I can alert cornyn 

and let him know what we are doing to help him.’’ 31 Reed claimed 

he was already working with Ed Young, pastor of the Second Baptist Church of Houston, Texas, to mobilize the top pastors in Houston to provide cover for the State’s anti-gambling efforts.32 According to Reed, ‘‘[W]e have over 50 pastors mobilized, with a total 

membership in those churches of over 40,000—that includes second 

baptist, which has 12,000 members.’’ 33

In an effort to sway public opinion, the Tigua had earlier embarked upon a public relations campaign. Earlier that day, the 

Tigua had run articles in newspapers in Austin, Houston, Dallas, 

San Antonio and Fort Worth, imploring people to contact thenTexas Attorney General John Cornyn and ‘‘beg him to save our 

families.’’ 34 The Tigua also ran a similar full-page ad in The Washington Post, in the form of a letter to the President.35

Upon reading about the Tigua’s public relations campaign, Reed 

advised Abramoff, ‘‘i [sic] strongly suggest we start doing patchthroughs to perry and cornyn. [W]e’re getting killed on the 

phones.’’ 36 Apparently, Scanlon had already started.37 Reed again 

claimed he had already mobilized 50 pastors to provide ‘‘moral support’’ to then-Texas Attorney General Cornyn.38

On November 15, 2001, Isidro Garza, Chairman of the Kickapoo 

Tribe informed Abramoff that then-Texas Attorney General Cornyn 

was ‘‘fixing to get hammered in El Paso’’ and asked ‘‘are we prepared to have Ralph Reed move in?’’ 39

Abramoff replied, ‘‘Absolutely. Ralph and I spoke last night. 

Cornyn is supposed to call Ralph as soon as he can make it to a 

phone after El Paso. We should be in good shape.’’ 40
105 

41 Email between Jack Abramoff, Greenberg Traurig, and Ralph Reed, Century Strategies 

(GTG–E000023491–93) (December 5, 2001). 42 Id. 43 Email from Ralph Reed, Century Strategies, to Jack Abramoff, Greenberg Traurig (GTG– 

E000010854) (January 7, 2002). 44 Id. 45 Email from Ralph Reed, Century Strategies, to Jack Abramoff, Greenberg Traurig (GTG– 

E000076007) (January 23, 2002). 46 Email from Jack Abramoff, Greenberg Traurig, to Shawn Vasell, Greenberg Traurig (GTG– 

E000076245) (February 27, 2003). 47 Interview of Carlos Hisa, Lieutenant Governor, Ysleta del Sur Pueblo, in El Paso, Texas 

(October 28, 2004). 48 Id. 

By December 2001, Reed apparently was not achieving satisfactory results. With respect to the Alabama Coushatta’s new casino, 

Abramoff wrote, ‘‘We are going to lose this client [Louisiana 

Coushatta] if we can’t get this thing closed. What can we do? What 

are they waiting for?’’ 41

Reed reported on everything he was doing to ensure the casino 

would be shut down, and added, ‘‘Let’s talk today about what else 

we might do. But if the client loses us in the meantime, they will 

not get anyone better to advance their cause.’’ 42

On January 7, 2002, Reed reported on his discussions with the 

Attorney General’s Office, adding ‘‘[h]ope these developments help 

with client’’.43 Reed also reminded Abramoff that the information 

he had earlier passed on turned out to be true, and confirmed that 

he had gotten pastors riled up the week before to call the Attorney 

General’s office.44 Reed purportedly continued to supply Abramoff 

with information from the Attorney General’s office, claiming he 

was having direct conversations with the Texas Attorney General 

himself.45

While the trio worked to support the State’s legal efforts, evidence also suggests that Abramoff, Scanlon, and Reed worked behind the scenes in Texas to quash the Tigua’s attempts at a legislative solution. In 2003, Abramoff boasted to a colleague: 

A bill is moving (HB809) in the Texas state house which 

will enable the Indians in Texas to have totally unregulated casinos. It passed out of the house Criminal Jurisprudence Committee by a 6–2 vote. 

The current Republican Speaker Tom Craddick is a strong 

supporter. Last year we stopped this bill after it passed 

the house using the Lt. Governor (Bill ratcliff) [sic] to prevent it from being scheduled in the state senate.46

In fact, former Texas Lt. Governor Ratliff did refuse to schedule 

the legislation for a floor vote in the previous session, the state’s 

legal efforts succeeded, and the Tigua officially closed its casino on 

February 12, 2002.47

It was a low point for the Tigua. According to Tribal representatives, the revenue generated by the Speaking Rock Casino had 

helped the Tribe lift its members out of poverty, had enabled the 

Tribe to provide education for its children and health care for its 

elders.48 It created hope where there was none. Into their desperation and despair entered Abramoff and Scanlon. 
106 

49Marc Schwartz document production (no Bates number) (February 4, 2002) (Memorandum 

from Norman J. Gordon, Esq., Diamond, Rash, Gordon & Jackson, to Tom Diamond, Esq., Diamond, Rash, Gordon & Jackson). 50 Email from Ralph Reed, Century Strategies, to Jack Abramoff, Greenberg Traurig (GTG– 

E006970–JA) (February 5, 2002). 51 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E006970–JA) (February 5, 2002). 52 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. 

at 228 (November 17, 2004) (statement of Marc Schwartz, president, Partners Group Consultants). 53 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 54 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 228 (November 17, 2004) (statement of Marc Schwartz, president, Partners Group Consultants). 

D. ABRAMOFF AND SCANLON SEEK THE TRIBE’S MONEY

At the same time Abramoff and Scanlon were working to have 

the Tigua’s casino in El Paso closed, they began actively soliciting 

the Tigua for money to re-open its casino. According to an internal 

memorandum from Norman J. Gordon to Tom Diamond, both of 

whom were outside counsel for the Tigua: 

I had a telephone conversation this afternoon with Bryant 

Rogers, a lawyer in Santa Fe, who represents a number of 

Indian Tribes. He advises me that he was asked by Mr. 

Jack Abramoff, a lobbyist in Washington, D.C. whether the 

Tiguas were attempting a solution to the order that may 

be outside the courts. According to Mr. Rogers, Mr. 

Abramoff is with a firm that is well connected to the Bush 

Administration (Greenberg Trauring [sic] Firm in Washington, D.C. which represented the Bush Campaign in the 

Florida dispute-lobbying arm) and has been effective in the 

past in efforts for other tribes. He is willing to come to El 

Paso and meet with the Council at no cost to discuss 

whether he can be of assistance. His phone number is [REDACTION].49

Meanwhile, Reed forwarded to Abramoff an email from one of 

Reed’s Texas operatives reporting that the operative ‘‘[j]ust spoke 

with a source close to the Attorney General who tells me they anticipate either February 8 (this Friday) or February 11th—next 

Monday—will be the date Judge Eisele shuts down the Tigua casino. His order would dispatch federal marshals to the facility to 

close it.’’ 50 In forwarding Reed’s email to Scanlon, Abramoff was 

clear about his lack of care and concern for the Tigua’s plight: 

‘‘Whining idiot. Close the f’ing thing already!!’’ 51

Despite his disdain, the very next day, Abramoff was quickly on 

the telephone with Tigua public relations representative Marc 

Schwartz seeking the Tigua’s business.52 During their first telephone conversation, Abramoff lamented over the Tigua’s plight, 

and offered to visit the Tribe in El Paso to discuss a solution to the 

Tigua’s problem.53 According to Schwartz, Abramoff ‘‘expressed his 

indignation over what had occurred with the tribe and specifically 

referred to the need to right the terrible injustice that had been 

brought upon the tribe.’’ 54

To Schwartz, Abramoff appeared to have the right credentials. 

Abramoff claimed to be a close friend of Congressman Tom 
107 

55 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 56 Id. 57 Id. 58 Id. 59 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 228 (November 17, 2004) (statement of Marc Schwartz, president, Partners Group Consultants). 60 Id. 61 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign Strategies (GTG–E0075991) (February 6, 2002). 62 Id. 63 Email from Ralph Reed, Century Strategies, to Jack Abramoff, Greenberg Traurig (GTG– E006969–JA) (February 6, 2002). 64Marc Schwartz document production (no Bates number) (February 7, 2002) (Memorandum 

from Marc Schwartz, president, Partners Group Consultants, to Governor Albert Alvidrez, Lt. 

Governor Carlos Hisa, and Tribal Council, Ysleta del Sur Pueblo). 65Marc Schwartz document production (no Bates number) (February 8, 2002) (Memorandum 

from Marc Schwartz, Partners Group Consultants, to Governor Albert Alvidrez, Lt. Governor 

Carlos Hisa, and Tribal Council, Ysleta del Sur Pueblo); see also Marc Schwartz document production (no Bates number) (February 10, 2002) (Memorandum from Marc Schwartz, Partners 

Group Consultants, to Governor Albert Alvidrez, Lt. Governor Carlos Hisa, and Tribal Council, 

Ysleta del Sur Pueblo). 66 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 235 (November 17, 2004) (statement of Carlos Hisa, Lieutenant Governor, Ysleta del Sur 

Pueblo). 67 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. 

(November 10, 2004). 

DeLay.55 He also discussed his friendship with Reed, recounting 

some of their history together at College Republicans.56 When 

Schwartz observed that Reed was an ideologue, Schwartz recalled 

that Abramoff laughingly replied ‘‘as far as the cash goes.’’ 57

Abramoff also mentioned his representation of the Mississippi 

Band of Choctaw Indians (‘‘Choctaw’’) and his ability to get appropriations for them.58

Abramoff ‘‘offered the service of both himself and his firm at no 

charge.’’ 59 He later expressed a hope that the Tribe would hire 

him, if he succeeded in achieving a Federal legislative fix.60

After his call with Schwartz, Abramoff told Scanlon, ‘‘Fire up the 

jet baby, we’re going to El Paso!!’’ 61

Scanlon replied, ‘‘I want all their MONEY!!!’’ 62

Later that day, Reed sent Abramoff the Saturday copy of an El 

Paso Times-News article reporting that the Tigua had filed for a 

stay of the closing of its casino while the Tribe’s appeal was pending before the Fifth Circuit Court of Appeals with the note ‘‘here’s 

the latest move, just as we predicted.’’ 63

On February 7, 2002, Schwartz reported to Tigua Governor Albert Alvidrez, Lt. Governor Carlos Hisa, and the Tribal Council 

that he ‘‘spoke with Mr. Abramoff this morning and he would like 

to make a short presentation to the Council next week. He could 

be in El Paso for a meeting on Tuesday.’’ 64 Schwartz scheduled the 

meeting with Abramoff and the Tigua leadership for Tuesday, February 12, 2002, at the Tribal Council offices for Abramoff to make 

‘‘a short presentation on his capabilities.’’ 65

Before meeting with Abramoff, the Tigua undertook some due 

diligence, reviewing stories about Abramoff in The New York Times 

and The Wall Street Journal.66 The articles described Abramoff as 

an ‘‘uber lobbyist.’’ 67 The Tigua also reviewed information about 

the law firm Greenberg Traurig, which the Tribe determined was 

one of the top law firms, and concluded that Abramoff’s ‘‘creden-
108 

68 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 235 (November 17, 2004) (statement of Marc Schwartz, president, Partners Group Consultants). 69 Interview of Carlos Hisa, Lieutenant Governor, Ysleta del Sur Pueblo, in El Paso, Texas 

(October 28, 2004). 70 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign Strategies (GTG–E000000353) (February 9, 2002). 71 Id. 72 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 239 (November 17, 2004) (statement of Marc Schwartz, president, Partners Group Consultants). 73 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 74 Id. 75 Id. 76 Id. 77 Id. 78 Id. 79 Email between Ralph Reed, Century Strategies, and Jack Abramoff, Greenberg Traurig (GTG–E006967–JA) (February 11–12, 2002). 80 Id. 81 Id. 

tials appeared to be extremely legitimate.’’ 68 At a Tribal Council 

meeting, the Tribe considered Abramoff’s credentials: he was a topnotch lobbyist; he represented the Choctaw, widely known and respected in Indian country; and, his firm had represented President 

Bush in the 2000 presidential election dispute.69

Meanwhile, Abramoff and Scanlon continued to monitor the 

Tigua’s fight. On Saturday, February 9, 2002, the El Paso TimesNews reported that, following the Fifth Circuit Court’s denial of the 

Tigua’s application for a stay pending appeal, the Tigua intended 

to file an emergency request to the United States Supreme Court.70

Concerned by the Tigua’s latest actions, Scanlon wrote to Abramoff: 

‘‘Uh oh?’’ and Abramoff responded, ‘‘We have to strategize on this 

one.’’ 71

A day or so before Abramoff’s meeting with the Tribe, Abramoff 

called Schwartz to inform the Tribe that he was bringing Michael 

Scanlon, whom he called an associate.72 Abramoff said that Scanlon was Congressman DeLay’s former spokesman.73 Abramoff 

called Scanlon one of his best friends; said they worked together all 

the time; and, claimed that Scanlon was one of the pre-eminent political strategists in the nation.74

During their conversation, Abramoff never called Scanlon his 

business partner.75 According to Schwartz, Abramoff was always 

very careful to make it clear to the Tigua that ‘‘you’re hiring Scanlon independently. I use him because he’s the best. He has his own 

company.’’ 76 Abramoff never disclosed that he and Scanlon were 

partners; never said he would receive money from Scanlon that the 

Tigua paid; and, never mentioned any referral fee from Scanlon.77

To the contrary, when Schwartz asked whether Scanlon Gould was 

connected to Abramoff, Abramoff replied ‘‘no.’’ 78

The day he was supposed to meet with the Tigua leadership, 

Abramoff’s disdain for the Tribe again surfaced. Reed had reported 

that the Tigua was prepared to close its casino.79 Reed highlighted 

for Abramoff ‘‘major victory ... but note they plan a legislative battle now that they have lost in the courts.’’ 80

Abramoff responded, ‘‘I wish those moronic Tiguas were smarter 

in their political contributions. I’d love us to get our mitts on that 

moolah!! Oh well, stupid folks get wiped out.’’ 81
109 

82 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. 

at 228 (November 17, 2004) (statement of Marc Schwartz, president, Partners Group Consultants). 83 Id. at 239. 84 Interview of Tom Diamond, Esq., Diamond, Rash, Gordon & Jackson, outside counsel, 

Ysleta del Sur Pueblo, in El Paso, Texas (October 28, 2004). 85 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. 

at 231 (November 17, 2004) (statement of Carlos Hisa, Lieutenant Governor, Ysleta del Sur 

Pueblo). 86 Id. 87 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. 

at 228, 239 (November 17, 2004) (statement of Marc Schwartz, president, Partners Group Consultants). 88 Interview of Carlos Hisa, Lieutenant Governor, Ysleta del Sur Pueblo, in El Paso, Texas 

(October 28, 2004). 89 Interview of Tom Diamond, Esq., Diamond, Rash, Gordon & Jackson, outside counsel, 

Ysleta del Sur Pueblo, in El Paso, Texas (October 28, 2004). 90 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. 

(November 10, 2004). 91 Id. 92 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. 

at 228 (November 17, 2004) (statement of Marc Schwartz, president, Partners Group Consultants). 93 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. 

(November 10, 2004). 

Abramoff and Scanlon met with the Tigua Tribal Council on February 12, 2002.82 Ironically, it was the same day that the Tigua’s 

casino was going to close.83 The meeting occurred at the Tribal Administration Building, and lasted forty-five (45) minutes.84

Attendees at the meeting included the Tribe’s then-Governor Albert 

Alvidrez, Schwartz, and Tribal attorney Tom Diamond.85 As Lt. 

Governor Hisa later learned, at that meeting, Abramoff made a 

proposal for a lobbying effort led by himself and Scanlon’s firm to 

gain a federal legislative fix to the Tigua’s problem.86

The Tribe had no idea that Abramoff, Scanlon, and Reed had just 

worked to ensure the closure of its casino.87 According to Hisa, 

Alvidrez said that Abramoff disclosed his friendship with Reed, but 

Abramoff said that Reed was ‘‘crazy, like other folks in the Christian Coalition.’’ 88 According to Tom Diamond, counsel to the Tigua, 

Abramoff also claimed that as Reed was leading the anti-gambling 

efforts among Christian conservatives, Reed was supplying 

Abramoff with information about the effort and, therefore, 

Abramoff knew their strategy.89

Abramoff also disclosed his representation of the Louisiana 

Coushatta, but said the Louisiana Coushatta did not have any 

problem with the Tigua.90 Abramoff bragged about getting the 

Choctaw millions of dollars in appropriations.91

During the Committee’s hearing, Schwartz testified that 

Abramoff introduced Scanlon as ‘‘the preeminent expert in grassroots politics and that with his experience with Representative 

Tom DeLay had developed a reputation as ‘the go-to guy for the 

most difficult campaigns’.’’ 92 According to Schwartz, Abramoff further described Scanlon as a ‘‘bulldog’’, ‘‘tenacious’’, ‘‘people were 

afraid of him’’, he was ‘‘DeLay’s attack dog,’’ and was one of the 

reasons that Congressman DeLay was so successful.93 According to 

Lt. Governor Hisa, Scanlon claimed he would try to convince Representative DeLay to work for the Tigua’s benefit and try to use 
110 

94 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 242 (November 17, 2004) (statement of Carlos Hisa, Lieutenant Governor, Ysleta del Sur 

Pueblo). 95 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 96 Id. 97 Id. 98 Id. 99 Id. 100 Id. 101 Id. 102 Id.; Interview of Carlos Hisa, Lieutenant Governor, Ysleta del Sur Pueblo, in El Paso, 

Texas (October 28, 2004). 103 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 104 Id. 105 Id.; Interview of Tom Diamond, Esq., Diamond, Rash, Gordon & Jackson, outside counsel, 

Ysleta del Sur Pueblo, in El Paso, Texas (October 28, 2004) (recalling Abramoff said that Scanlon would ‘‘bring them [opponents] in line’’). 106 Id.; Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 107 Interview of Tom Diamond, Esq., Diamond, Rash, Gordon & Jackson, outside counsel, 

Ysleta del Sur Pueblo, in El Paso, Texas (October 28, 2004). 108 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 109 Id. 

Representative DeLay’s credibility to convince other representatives to support the Tigua.94

Abramoff said that Scanlon did the groundwork on his projects.95

When Schwartz asked whether Abramoff used Scanlon exclusively, 

Abramoff said that he liked to use Scanlon for the tough fights: ‘‘He 

always gets results’’, recalled Schwartz.96

At that first meeting, Scanlon said he worked in public affairs 

and direct response.97 Scanlon explained grassroots campaigns, and 

how he could get thousands of telephone calls to flood a senator’s 

office, or even the President’s office.98 Scanlon claimed he was 

‘‘DeLay’s guy’’ and had an ongoing relationship with Congressman 

DeLay.99

Abramoff and Scanlon proposed a nationwide political campaign 

for the Tigua.100 The duo brought a laptop with an example of the 

database they were proposing to construct for the Tigua.101

Abramoff told the Tribe that his plan was to have a friendly lawmaker sneak some fairly innocuous language into a federal bill permitting the Tigua to re-open the Speaking Rock Casino.102 But the 

Tribe would have to make contributions to grease the process: ‘‘You 

have to have some friends,’’ Schwartz recalled Abramoff saying.103

Schwartz further recalled Abramoff saying ‘‘my part is easy; the 

hard part is keeping this from being undone. Once the law is printed, someone’s going to know it and that’s where Mike comes in.’’ 104

Abramoff described Scanlon’s role as a submarine: once the bill 

passed, opponents would try to strip it or repeal it.105 Abramoff 

said that Scanlon’s operation would then surface, blanketing members’ offices with letters and phone calls, to ‘‘bring them in line.’’ 106

Scanlon would implement this ‘‘submarine strategy’’ through the 

database he was supposedly going to construct for the Tribe.107

Abramoff also said that he and Greenberg Traurig would represent the Tribe pro bono until the casino was up and running, but 

then wanted to represent the Tigua for $150,000 per month.108

Abramoff said he had done this arrangement before: he would work 

pro bono, but Scanlon had to be paid.109
111 

110 Id. 111 Id. 112 Id. 113 Id. 114 Id. 115 Id. 116 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 228 (November 17, 2004) (statement of Marc Schwartz, president, Partners Group Consultants). 117 Id. at 242 (testimony of Carlos Hisa, Lieutenant Governor, Ysleta del Sur Pueblo). 118 Id. 119 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 120 Id. 121 Interview of Carlos Hisa, Lieutenant Governor, Ysleta del Sur Pueblo, in El Paso, Texas 

(October 28, 2004). 122 Email from Marc Schwartz, Partners Group Consultants, to Jack Abramoff, Greenberg Traurig (GTG–E006968-JA) (February 13, 2002). 123 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E006968-JA) (February 13, 2002). 124 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 125 Id. 126 Id. 127 Id. 

Speaking about the grassroots efforts, Scanlon said there was a 

necessity of money.110 Scanlon was going to write a proposal for 

the Tigua.111 Schwartz recalled Abramoff saying ‘‘you won’t pay 

me, you’ll pay him a lot’’, indicating Scanlon.112 According to 

Schwartz, Abramoff said two or three times ‘‘I’m the only guy who’s 

gonna work for you and get results first and you pay second.’’ 113

Abramoff said his efforts ‘‘couldn’t exist without Scanlon.’’ 114 At 

the meeting, Abramoff and Scanlon suggested a ballpark figure of 

$5,000,000 for the plan, in addition to $1,000,000 in political contributions.115

During that same meeting, Scanlon represented that his part in 

the campaign ‘‘would be expensive, essential and exclusive.’’ 116 The 

Tribe had no understanding that Scanlon would pay Abramoff out 

of the funds paid to him by the Tribe.117 The Tribe never paid 

Abramoff any money.118 In discussing the project, Abramoff conveyed a sense of urgency.119 At the meeting, Abramoff again insisted the proposal was critical, that it needed to be done, the Tribe 

needed this defense, and Scanlon had done this before.120

At that meeting, neither Abramoff nor Scanlon disclosed that 

they were partners; that Abramoff had any type of financial interest in Scanlon’s operations; or, that Scanlon would pay Abramoff 

any part of what the Tribe paid Scanlon.121

After Abramoff met with the Tigua leadership, Schwartz sent an 

email to Abramoff: ‘‘Certainly enjoyed your visit and efforts to help 

our client. I look forward to receiving your proposal and we will do 

everything possible to make it come to fruition.’’ 122 Forwarding 

Schwartz’s email to Scanlon, Abramoff commented, ‘‘This guy 

NEEDS us to save his ass!!’’ 123

After Abramoff and Scanlon’s trip to El Paso, Abramoff pushed 

the Tigua to decide on Scanlon.124 Abramoff said that ‘‘bills were 

moving, timing is critical, he needed Scanlon ASAP.’’ 125 Abramoff 

insisted that if a bill moved quickly, he needed Scanlon in place 

working on the database along with some other elements of the 

strategy.126 At this point, Abramoff did not specify which lawmakers would help, or where the contributions would go.127
112 

128 Email between Michael Scanlon, Capitol Campaign Strategies, and Jack Abramoff, Greenberg Traurig (GTG–E000010895) (February 16–17, 2002). 129 Id. 130Greenberg Traurig document production (GTG–000076141) (February 18, 2002). 131 Id. 132 Id. 133 Id. 134 Id. 

Scanlon was responsible for drafting the Tigua strategy. On February 16, 2002, Scanlon reported to Abramoff that he was ‘‘still 

working—I’ll have it done befoer [sic] noon tomorrow so you can get 

it deon [sic] to schartz [sic].’’ 128 The next day, Abramoff responded: 

‘‘Dawg, we’re going to miss the meeting on Tuesday at this rate. 

Let’s not blow this one because we don’t get them a proposal. Get 

me something asap!’’ 129

Upon receiving the proposal, Abramoff sent Schwartz an email 

on February 18, 2002, reiterating that his and Greenberg Traurig’s 

services were free: 

As we discussed, until we are able to achieve the Federal 

legislative fix, we at Greenberg Traurig will not be engaged by the tribe for services officially. All our work will 

be done on a pro bono basis. Once the legislation is signed 

by the President, we would anticipate the tribe engaging 

us to represent it at the Federal level and assist with efforts to obtain a class III compact. Our normal rate in our 

tribal government practice is between $125,000 and 

$175,000 per month.130

Abramoff attached to his email to Schwartz a proposal entitled 

‘‘Operation Open Doors’’. According to the document, the ‘‘singular 

objective of our strategy is to open the doors of the Speaking Rock 

Casino within the next 4 months.’’ 131 The document continued, 

Our objective is clear, and in the following pages we are 

going to tell you exactly how we intend to reach our objective. Operation Open Doors is a massive undertaking 

fueled by a nation-wide political operation. This political 

operation will result in a Majority of both federal chambers either becoming close friends of the tribe or fearing 

the tribe in a very short period of time. 

The network we our [sic] are building for you will give you 

the political clout needed to end around the obstacles you 

face in your own back yard. Simply put, you need 218 

friends in the U.S. House and 51 Senators on your side 

very quickly, and we will do that through both love and 

fear.132

The document represented that ‘‘they’’ had ‘‘waged similar strategies in the past that have been successful and we will wage many 

more in the years to come.’’ 133 Although the document cautioned 

that the strategy was not ‘‘full proof’’, it also emphasized that 

‘‘under no circumstances do we believe it could be classified as high 

risk either.’’ 134 According to the document: ‘‘As we presented in our 

initial meeting, we firmly believe that if you execute this strategy 

in its entirety, your doors will be open and gaming will return in 
113 

135 Id. 136 Id. 137 Email from Brian Mann, American International Center, to Michael Scanlon, et. al., Capitol Campaign Strategies (GTG–E000001141) (February 19, 2002). 138 Email between Michael Scanlon, Capitol Campaign Strategies, and Jack Abramoff, Green- berg Traurig (GTG–E000001141) (February 19, 2002). 139 Id. 140 Email from Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign Strategies (GTG–E000001140) (February 19, 2002). 141 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 232 (November 17, 2004) (statement of Carlos Hisa, Lieutenant Governor, Ysleta del Sur 

Pueblo). 142 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 143 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 232 (November 17, 2004) (statement of Carlos Hisa, Lieutenant Governor, Ysleta del Sur 

Pueblo). 144 Id. 145 Id. 146 Contract between Ysleta del Sur Pueblo and Scanlon Gould Public Affairs (March 5, 2002) 

(no Bates number). 147Discussion and analysis of how Abramoff and Scanlon successfully perpetrated their 

‘‘gimme five’’ scheme on the Tribe, on an entity-by-entity basis, is contained in Part 2 of this 

Report. 

the immediate future.’’ 135 Scanlon requested a total amount of $5.4 

million to execute his strategy.136

On February 19, 2002, the El Paso Times reported that 450 people received their final termination notice and 60-day severance 

packages one week after Tigua Tribal officials complied with a federal court order to shut down their Speaking Rock Casino.137 Scanlon forwarded the story to Abramoff with the preface ‘‘This is on 

the front page of todays [sic] while they will be voting on our 

plan!’’ 138 Abramoff could hardly contain his excitement: ‘‘Is life 

great or what!!!’’ 139 Mere minutes later, Abramoff sent another 

email to Scanlon: ‘‘1 hour 45 minutes and counting my friend.’’ 140

Before voting on Operation Open Doors, the Tribe asked 

Abramoff and Scanlon to return. Abramoff therefore met with 

Tigua leadership again in El Paso on February 22, 2002.141

Abramoff was alone; Scanlon supposedly had health problems and 

was unable to attend.142

At that second meeting, Abramoff made a proposal on the legislative strategy, including Operation Open Doors and the database to 

be developed by Scanlon Gould.143 Later that day, through 

Schwartz, the Tribal Council requested that the cost of Operation 

Open Doors be reduced to $4.2 million.144 Abramoff accepted the 

Tribe’s counter-offer on Scanlon Gould’s behalf.145

On March 5, 2002, the Tribe executed a contract with Scanlon 

Gould for the implementation of Operation Open Doors.146 In less 

than a month, the Tribe paid Scanlon $4,200,000. 

Payments by Tigua to Scanlon Gould 

03/05/02 ................................................................................................... $2,100,000 

03/06/02 ................................................................................................... $817,000 

03/26/02 ................................................................................................... $1,283,000 

Total ................................................................................................. $4,200,000 

Having collected about $4,200,000 from the Tigua during the relevant period, Scanlon secretly kicked back to Abramoff about 

$1,850,000—about 50% of his total profit from the Tribe.147 The 
114 

148 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 242 (November 17, 2004) (testimony of Carlos Hisa, Lieutenant Governor, Ysleta del Sur 

Pueblo). 149 Id. at 238. 150 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 151 Id. 152 Interview of Carlos Hisa, Lieutenant Governor, Ysleta del Sur Pueblo, in El Paso, Texas 

(October 28, 2004). 153 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 229 (November 17, 2004) (statement of Marc Schwartz, president, Partners Group Consultants). 154 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000053576) (February 25, 2002). 155 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 229 (November 17, 2004) (statement of Marc Schwartz, president, Partners Group Consultants). 156 Id. at 237. 157 Id. 158 Interview of Marc Schwartz, president, Partners Group Consultants, by telephone (Novem- ber 14, 2004). 159 Id. 160 Id. 

Tribe never knew that Scanlon would pay Abramoff with the 

Tribe’s money, 148 and had no way of knowing of the scam the duo 

was running.149

E. SECRECY AND CONTRIBUTIONS

Secrecy was a key element of Abramoff and Scanlon’s program. According to Schwartz, Abramoff claimed, ‘‘Nobody can know I’m 

working on this deal. Stealth is the key.’’ 150 Abramoff repeatedly emphasized that his involvement in the effort needed to be kept secret.151 Neither Abramoff nor any other lobbyist on his team reg- istered with the Clerk of the House or the Secretary of the Senate 

as lobbyists for the Tigua. Abramoff claimed that part of the reason 

for representing the Tigua pro bono was to avoid filing the required lobbying disclosure forms.152 According to Schwartz, Abramoff ex- plained that the lawmakers who would advance the legislative 

measure required secrecy.153

When Schwartz sent a number of Tigua-related articles to a list of people—including Abramoff—Abramoff forwarded the articles to 

Scanlon with the note: ‘‘That fucking idiot put my name on an 

email list! What a fucking moron. He may have blown our cover!! 

Dammit. We are moving forward anyway and taking their fucking 

money.’’ 154

Another key component of the program, so Abramoff claimed, were the political contributions that Abramoff directed the Tigua to 

make.155 Abramoff gave the Tribe a list of contributions at the mo- ment he made his second presentation.156 According to Schwartz, ‘‘Those checks were required by Mr. Abramoff, directed that the 

Tribe do those immediately.’’ 157

During four or five conversations that Schwartz had with Abramoff between March 1–5, 2002, Abramoff said that political 

contributions were critical to the Tribe’s language going through.158

Abramoff told Schwartz that the Tribe needed to make the contributions to have lawmakers carry the Tribe’s water.159 Schwartz 

recalled Abramoff plainly saying that unless the Tribe made contributions, ‘‘it will not work’’ and ‘‘they will not vote for us.’’ 160

What Abramoff did not tell the Tribe was that he was going to use its contributions to achieve legislative results for other clients. 
115 

161 Email from Todd Boulanger, Greenberg Traurig, to Jack Abramoff, Greenberg Traurig 

(GTG–E000076355) (February 24, 2002). 162 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 236 (November 17, 2004) (testimony of Carlos Hisa, Lieutenant Governor, Ysleta del Sur 

Pueblo). 163 Email between Tony Rudy, Greenberg Traurig, and Jack Abramoff, Greenberg Traurig (GTG–E000089648) (March 18, 2002). 164 Id. 165 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000076443) (March 20, 2002). 166 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 229 (November 17, 2004) (statement of Marc Schwartz, president, Partners Group Consultants). The actual name of the bill was the Help America Vote Act of 2002, Public Law 107– 

252. 167 Interview of Honorable Robert W. Ney, Member, United States House of Representatives, in Washington, D.C. (November 12, 2004). 168 Id. 169 Id. 

On February 24, 2002, Abramoff’s associate Todd Boulanger wrote 

about the ‘‘Tigua Contribution Budget Proposal’’: 

I’m compiling this information now. How soon will be [sic] 

get this money ... [sic] since we are going to use this to leverage our friends for this year’s approps requests, prior to 

March 20th is best, since March 22nd is the general deadline. We’re looking strong on the school for the Sagchips. 

$4.5 million in da-bank. call [sic] me at the office if you get 

this soon ...161

The Tribe contributed approximately $300,000 at Abramoff’s direction.162

F. ABRAMOFF AND HIS COLLEAGUES SET THE PLAN IN MOTION IN THE

HOUSE

On March 18, 2002, Tony Rudy, an Abramoff colleague and 

former Deputy Chief of Staff to Congressman Tom DeLay, told 

Abramoff, ‘‘We need to meet with ney [sic]. I think you should be 

in on it.’’ 163

Abramoff responded, ‘‘I agree. when [sic] can we see him? We 

need to show him the list of those to whom they [the Tribe] gave. 

Was he on it? if [sic] not, find out the name of his PAC and his 

personal committee with addresses and we’ll get checks right 

now.’’ 164

Two days later, Abramoff exclaimed to Scanlon, ‘‘Just met with 

Ney!!! We’re f’ing gold!!!! He’s going to do Tigua.’’ 165

At the hearing before the Committee, Schwartz testified that 

Abramoff reported in March 2002 that he and his staff had spoken 

to Representative Bob Ney, who allegedly agreed to carry the Tigua 

provision by placing it in the Election Reform Bill.166

Congressman Ney had a different recollection of events. According to Congressman Ney, Abramoff told him that Senator Dodd 

wanted to insert a provision into the Election Reform Bill that 

would benefit a gaming tribe in Connecticut.167 Congressman Ney 

said there was never any mention of any Tribe in El Paso, Texas 

and no reference to any Tigua Indian tribe.168 As of the date of his 

interview with Committee staff, Congressman Ney said he was not 

at all familiar with the Tigua.169

To effect his legislative strategy, Abramoff enlisted other lobbyists at Greenberg Traurig, including Neil Volz, Jon van Horne, and 
116 

170 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 171 Email from Mayra Zilio, to Jack Abramoff, Greenberg Traurig (GTG–E000089431) (Feb- ruary 8, 2002). 172 Email from Neil Volz, Greenberg Traurig, to himself (GTG–E000089433) (February 6, 2002). He was therefore subject to the one-year lobbying ban prohibiting him from lobbying both 

Congressman Ney and his office, as well as the Committee. 173 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 174 Id. 175 Id. 176 Id. 177 Interview of Marc Schwartz, president, Partners Group Consultants, by telephone (Novem- ber 14, 2004). 178 Id. 179 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 180 Id. 181 Id. 182 Id. 183 Id. 184 Interview of Honorable Robert W. Ney, Member, House of Representatives, in Washington, D.C. (November 12, 2004). 185 Interview of Marc Schwartz, president, Partners Group Consultants, by telephone (Feb- ruary 22, 2005). 186 Id. 187 Id. 

Shawn Vasell.170 In particular, Volz was the former chief of staff 

to Congressman Ney and staff director for the House Committee on 

Administration, which Congressman Ney chaired at the time.171

Volz went to work for Team Abramoff at Greenberg Traurig on 

February 19, 2002.172

According to Schwartz, Volz was supposedly working on the 

Tigua issue on the House side.173 Abramoff told Schwartz that 

Volz, as Congressman Ney’s former chief of staff, was important to 

the process.174 Schwartz remembered Abramoff saying that ‘‘Volz 

was Ney’s guy and was working it for Ney.’’ 175 Volz was on the Hill 

to get information and to influence the Conference Committee.176

According to Abramoff, Volz was talking to Congressman Ney 

about the Tigua.177 Abramoff said that Volz had convinced Congressman Ney that supporting the effort was the right thing to 

do.178

Schwartz met Volz twice while working on the Tigua issue.179 He 

also spoke to him in conference calls with Abramoff.180 According 

to Schwartz, Volz told him that Congressman Ney got involved in 

the Tigua project because of Volz.181 Volz was supposedly talking 

with Congressman Ney or his staff daily, Schwartz told Committee 

staff in his interview.182 Volz told Schwartz that he was working 

with Congressman Ney’s Chief of Staff and knew him by name.183

Congressman Ney contradicted Volz’s representations to 

Schwartz. During his interview with Committee staff, Congressman Ney said that, aside from Abramoff, no one—including Volz— 

approached him about the provision that Abramoff had brought to 

his attention.184

Meanwhile, on or about March 26, 2002, Abramoff called 

Schwartz and said that Congressman Ney had set up a new political action committee (‘‘PAC’’) called American Liberty.185 Abramoff 

said it was imperative that the Tribe send checks that day.186

Abramoff and Schwartz had another conversation about the contributions.187 Volz was present during this conversation, Schwartz 
117 

188 Id. 189 Id. 190 Id. 191 Id. 192 Email from Allison Bozniak, Greenberg Traurig, to Marc Schwartz, Partners Group Consultants (no Bates number) (March 26, 2002). 193Tigua document production (no Bates number) (check from Tigua to ‘‘Bob Ney For Congress’’) (March 27, 2002); Tigua document production (no Bates number) (check from Tigua to 

‘‘American Liberty PAC Hard Money Account’’) (March 27, 2002); Tigua document production 

(no Bates number) (check from Tigua to ‘‘American Liberty PAC Soft Money Account’’) (March 

27, 2002). 194 Interview of Marc Schwartz, president, Partners Group Consultants, by telephone (February 22, 2005). 195 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000089650) (March 30, 2002). 196 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg 

Traurig (GTG–E000089670) (April 1, 2002). 197 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg 

Traurig (GTG–E000089681) (April 15, 2002). 

recalled.188 During the conversation, Volz chimed in that the 

checks needed to be delivered quickly.189 According to Schwartz, 

Abramoff said that the political contributions were necessary, often 

saying ‘‘this has to be done’’, ‘‘this is not optional’’, and went as far 

as to say that ‘‘in order to make this thing work, he [Ney] needs 

the money in his PAC so he can make contributions to members 

of his Committee to make it glide through.’’ 190 ‘‘This is not what 

I think you should do; this is what Bob needs to be done’’, Schwartz 

remembered Abramoff saying.191

After Schwartz’s conference call with Abramoff and Volz, 

Abramoff’s assistant Allison Bozniak sent Schwartz an email with 

information for donations to American Liberty PAC and Bob Ney 

for Congress.192 On March 27, 2002, the Tribe made the following 

contributions: 

$2,000 to Bob Ney for Congress 

$5,000 to American Liberty PAC Hard Money Account 

$25,000 to American Liberty PAC Soft Money Account 193

On April 12, 2002, Abramoff again informed Schwartz that the 

Tigua language would be included in the Election Reform Bill.194

G. SCANLON PURPORTEDLY SETS THE PLAN IN MOTION IN THE SENATE

While Abramoff was lobbying the House, Scanlon was apparently 

responsible for supervising the lobbying of the Senate. To that end, 

he was supposedly hiring two Democratic operatives: Harold Ickes 

and Lottie Shackelford. On March 30, 2002, Abramoff instructed 

Scanlon, ‘‘Ickes has to move now. They might go to conference as 

soon as they get back. let [sic] me know when he is ready. Ney is 

ready to approach Dodd, but is waiting to hear back from us 

first.’’ 195

Scanlon assured Abramoff, ‘‘Will do onthis [sic]. Ill [sic] give 

udatelater [sic].’’ 196

There apparently was some problem on Scanlon’s end, but he assured Abramoff, ‘‘OK—Im [sic] back in the driver seat—We got 

Dodds [sic] Finacne [sic] comitte [sic] chairman on board and we 

have the vice Char [sic] of the DNC—the one who actually sponsored the resolution now on the team.’’ 197
118 

198 Email between Jack Abramoff, Greenberg Traurig, and Neil Volz, Greenberg Traurig (GTG–E000089698) (April 18, 2002). 199 Id. 200 Id. 201 Email between Tony Rudy, Greenberg Traurig, and Jack Abramoff, Greenberg Traurig 

(GTG–E000089701) (April 19, 2002). 202 Id. 203 Email between Tony Rudy, Greenberg Traurig, and Jack Abramoff, Greenberg Traurig, and 

Neil Volz (GTG–E000089703–04) (April 19, 2002). 204 Id. 205 Id. 206See Capitol Campaign Strategies document production (BB/TI 000824–25) (January 9, 2003). 207See id. 208 Interview of Brian Lunde, formerly, Lunde & Burger, by telephone (November 16, 2004). 209 Id. 

On April 18, 2002 Abramoff reported to Volz that ‘‘Dodd is 

ready.’’ 198 He explained, ‘‘We need to get to Ney to give him the green light to raise it with Dodd whenever he wants.’’ 199

Volz responded, ‘‘Ney is in Florida this weekend, I talked with him yesterday and will talk with [then-House Administration Committee staff director] Paul [Vinovich] on Sunday to get teed up to 

get ready to implement.’’ 200

The next day, Rudy urged Abramoff, ‘‘We better get folks to talk to dodd [sic].’’ 201

Abramoff assured Rudy, ‘‘We’re all set. he [sic] is ready and Ney knows to chat with him now.’’ 202

Rudy also asked, ‘‘Is vinovich on board the tiquas [sic]?’’ 203

Including Volz in the exchange, Abramoff replied, ‘‘I think so. Ney told Neil he was going to tell him, right Neil?’’ 204

Volz reported that ‘‘Ney told vinovich last night and I will talk through with Paul on the golf course Sunday.’’ 205

It appears, however, that Scanlon had not paved the way in the Senate, as he had said. The Committee has seen no evidence suggesting, much less establishing, that Scanlon had hired Ickes. In 

fact, in a January 9, 2003 memorandum from Scanlon to Schwartz 

on the political campaign Scanlon supposedly waged on the Tigua’s 

behalf, nowhere does Scanlon mention Ickes.206 According to Scan- lon, 

We began to target Senator Dodd using a system of repeated contact from influential members of his political 

family. At the cornerstone of the project was the vice 

chairperson of the DNC and a member of his finance committee, Lottie Shackelford. Her support and access was 

critical for our ongoing efforts to influence the Senator. We 

directed her to make personal contact with the Senator 

throughout the campaign starting in April and lasting 

through the passage of the legislation in October.207

Even Scanlon’s summary was not true. Brian Lunde, whom 

Scanlon used ‘‘as a silent sub[contractor] in letter-writing, legislative-monitoring, and other projects for his Tribal clients,’’ told Committee staff that Scanlon approached him in 2002 about the 

Tigua.208 Scanlon told Lunde that he was going to have an amendment inserted into the House version of Election Reform, and wanted to know whether the provision had any chance in the Senate.209

Lunde told Scanlon that the Democratic National Committee 

(‘‘DNC’’) had issued a resolution supporting the Tigua’s sov-
119 

210 Id. 211 Id. 212 Id. 213 Id. 214 Id. 215 Interview of Lottie Shackelford, Democratic political consultant, in Washington, D.C. (November 12, 2004). Lunde could not recall when he first reached out to Shackelford. Interview 

of Brian Lunde, formerly, Lunde & Burger, by telephone (November 16, 2004). 216 Id.; Interview of Lottie Shackelford, Democratic political consultant, in Washington, D.C. 

(November 12, 2004). 217 Interview of Brian Lunde, formerly, Lunde & Burger, by telephone (November 16, 2004). 218 Id.; Interview of Lottie Shackelford, Democratic political consultant, in Washington, D.C. 

(November 12, 2004). 219 Id. 220 Id. 221 Id. 222 Id. 223 Interview of Sheryl Cohen, chief of staff, Senator Christopher J. Dodd, in Washington, D.C. 

(November 16, 2004). 224 Id. 225 Interview of Lottie Shackelford, Democratic political consultant, in Washington, D.C. (November 12, 2004). 

ereignty.210 Lunde identified Senator Dodd as the key Senator on 

this issue; the question was if the provision was in the House 

version, would Senator Dodd support it.211

Scanlon asked Lunde who knew Senator Dodd and could get the 

DNC’s position to him.212 Lunde identified Lottie Shackelford.213

Since Scanlon did not know Shackelford, he asked Lunde to have 

her advise Dodd’s office on the DNC’s position.214

Lunde apparently called Shackelford about this in the fall of 

2002.215 In their interviews with Committee staff, Shackelford and 

Lunde similarly recalled Shackelford’s role. Shackelford was supposed to do two things: (1) make sure Senator Dodd’s office was 

aware of the DNC’s resolution on the Tigua; and, (2) monitor the 

Election Reform Bill in the Senate.216 Lunde never discussed with 

Scanlon having Shackelford lobby Senator Dodd’s office for inclusion of the Tigua provision in the Senate version of Election Reform.217 Lunde, therefore, never asked Shackelford to lobby Senator Dodd or his office for inclusion of the Tigua language in the 

Senate’s version of Election Reform bill.218

After speaking with Lunde, Shackelford called Sheryl Cohen, 

Senator Dodd’s Chief of Staff, to make her aware of the DNC resolution.219 Shackelford recalled telling Cohen that ‘‘we’’ are hearing 

that an amendment may be attached to the House election Reform 

Bill to restore the Tribe’s sovereignty and told her the DNC supported the Tribe’s sovereignty rights.220 There was no discussion of 

the Tribe’s casino or the language that would allow the Tribe to reopen its casino.221 Shackelford told Committee staff she never 

spoke to Senator Dodd directly about the Tigua.222

Cohen did not recall specifics of her conversations with 

Shackelford about the Tigua.223 Nevertheless, Cohen was clear she 

would have deemed any rider about the Tigua a ‘‘non-starter’’, because it was not relevant to the bill.224 Consistent with Cohen’s 

recollection, Shackelford told Committee staff that Cohen told her 

that Senator Dodd did not want Election Reform bogged down by 

non-germane provisions.225 Indeed, when the bill went to conference, Lunde recalled telling Scanlon that Dodd’s chief of staff 
120 

226 Interview of Brian Lunde, formerly, Lunde & Burger, by telephone (November 16, 2004). 227Marc Schwartz document production (no Bates number) (June 5, 2002) (Memorandum from 

Marc Schwartz, Partners Group Consultants, to Governor Albert Alvidrez, Lt. Governor Carlos 

Hisa, and Tribal Council, Ysleta del Sur Pueblo). 228 Id. 229 Email between Jack Abramoff, Greenberg Traurig, and Neil Volz, Greenberg Traurig 

(GTG–E000089758) (June 12, 2002). 230 Id. 231 Email from Neil Volz, Greenberg Traurig, to Jack Abramoff, Greenberg Traurig, and Tony Rudy, Greenberg Traurig (GTG–E000089523) (July 10, 2002). 232 Id. 233 Email from Neil Volz, Greenberg Traurig, to Tony Rudy, Greenberg Traurig, copied to Jack Abramoff, Greenberg Traurig (GTG–E000206101) (July 11, 2002). 234Marc Schwartz document production (no Bates number) (July 18, 2002) (Memorandum from Marc Schwartz, Partners Group Consultants, to Tribal Council, Ysleta del Sur Pueblo). 

told Shackelford that no new provisions were going to make it into 

the legislation.226

H. THINGS BEGIN TO UNRAVEL

On June 5, 2002, Schwartz provided the Tigua Governor, Lt. 

Governor, and Tribal Council with an update on Abramoff and 

Scanlon’s efforts in Washington, D.C., saying, ‘‘the conference committee staffs [were] meeting everyday to negotiate the issues in the 

bill.’’ 227 Schwartz further advised, ‘‘Our portion is still agreed to 

and as you can see from the [Abramoff’s] e-mail, there is no problem with our part being kept on the bill.’’ 228

Meanwhile, Abramoff instructed Volz to give him regular updates 

on Election Reform.229

Volz reported, ‘‘I talked to Paul yesterday and keep hearing the 

same thing’’, and assured Abramoff ‘‘I am keeping in daily contact 

with Paul and Chet in Ney’s office on this.’’ 230

The following month, however, Volz reported to Abramoff and 

Rudy, ‘‘Election Reform negotiations have slowed. Ney, Paul, and 

Chet all think it is possible to finish negotiations before August, 

but now not likely until later.’’ 231 Furthermore, according to Volz, 

‘‘With that being said, Ney and Paul have said things are moving 

and would like to get all our specifics in line, so I am working to 

get a meeting with Tony and Paul and Bob this week to exchange 

specifics—since Paul was not in original meeting.’’ 232

The next day, Volz reported to Abramoff and Rudy: 

I just talked with Ney, [sic] He is all set to meet you Tony 

at 2:00 at 1309 Longworth HOB today. He said he would 

meet with you first and then bring Paul [Vinovich] in for 

the meeting. ... The question is, should Tony bring in the 

Tigua and the Alabama Coushatta language or just the 

specific Tigua language. ... Please do not forward this, but 

you need to know I get the sense Bob is still a little jumpy 

on letting Paul in on the entire situation here, but knows 

he is the guy to place this language in the bill ...233

Abramoff continued his reports to the Tribe, as reflected in contemporaneous memoranda prepared by Schwartz. In mid-July, 

Schwartz reported that the conference report on the election reform 

legislation had been reported and was ‘‘eligible for consideration’’: 

‘‘The two Chairmen (Congressman Ney and Senator Dodd) have requested floor time [for the bill] from their respective bodies for this 

week.’’ 234
121 

235 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000076719) (July 25, 2001). 236 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. 

(February 22, 2005). 237Marc Schwartz document production (no Bates number) (July 26, 2002) (Memorandum 

from Marc Schwartz, Partners Group Consultants, to Governor Albert Alvidrez, Lt. Governor 

Carlos Hisa, and Tribal Council, Ysleta del Sur Pueblo). 238 Id. 239 Id. 240 Email between Jack Abramoff, Greenberg Traurig, and Ralph Reed, Century Strategies (GTG–E000019854) (May 15, 2002). 241 Id. 242 Email from Tony Rudy, Greenberg Traurig, to Jack Abramoff, Greenberg Traurig (GTG– E000089721) (May 23, 2002). 

In late July, Congressman Ney apparently approached Senator 

Dodd about the Tigua provision. Scanlon’s failure to get a commitment from Senator Dodd then became evident. On July 25, 2002, 

Abramoff sent Scanlon an urgent email: 

I just spoke with Ney who met today with Dodd on the bill 

and raised our provision. Dodd looked at him like a ‘‘deer 

in headlights’’ and said he has never made such a commitment and that, with the problems of new casinos in Connecticut, it is a problem!!! Mike, please call me immediately to tell me how we wired this, or were supposed to 

wire it. Ney feels we left him out to dry. Please call 

me!!! 235

Neither Scanlon nor Abramoff ever advised the Tigua about the 

problems they were having in the Senate. To the contrary, 

Abramoff and Scanlon both said that it was moving along well.236

Indeed, the day after Abramoff’s urgent e-mail to Scanlon, 

Abramoff reported that ‘‘Senate Democrats and House Republicans 

are at odds over one issue that cropped up. The issue is whether 

the Justice Department (Democrats favor) or individual state’s 

Election Departments (Republicans favor) will have jurisdiction 

over precinct approval, ballot design, etc.’’ 237

Schwartz reported that ‘‘it doesn’t appear that the conference report will make it to the floor before recess.’’ 238 Consequently, 

Abramoff sought a meeting between the Tigua and Congressman 

Ney.239

I. ABRAMOFF ASKS THE TIGUA TO FINANCE A GOLFING JUNKET TO

SCOTLAND

Although Abramoff and Scanlon’s efforts on the Tigua’s behalf 

were failing, it apparently did not stop Abramoff from soliciting 

funds from Tigua for a golfing junket to Scotland. 

On May 15, 2002, Abramoff advised his close friend Ralph Reed 

that ‘‘[t]he package on the ground is $4K per person. that [sic] covers rooms, tee times and ground transportation. One idea is that 

we could use one of my foundations for the trip—Capital Athletic 

Foundation—and get and make contributions so this is easier. 

OK?’’ 240

Reed responded, ‘‘OK but we need to discuss. It is an election 

year.’’ 241

About a week later, Rudy informed Abramoff that ‘‘Ney may 

want to do Scotland.’’ 242
122 

243 Email from Jack Abramoff, Greenberg Traurig, to Tony Rudy, Greenberg Traurig (GTG– 

E000089736–37) (June 4, 2002). 244 Id. 245 Email from Jack Abramoff, Greenberg Traurig, to Marc Schwartz, Partners Group Consultants (GTG–E000076582) (June 7, 2001). 246 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 240 (November 17, 2004) (statement of Marc Schwartz, president, Partners Group Consultants). 247 Id. 248 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 249 Id. 

Almost two weeks later, as details of the trip were coming together, Abramoff told Rudy, ‘‘We need to lock. Try to nail 2 stars 

to go with us: ney [sic] for sure!’’ 243

When Rudy confirmed that he was trying, Abramoff asked him 

to ‘‘stay on this feverishly.’’ 244

Abramoff asked the Tigua to finance the trip. In an email to 

Schwartz entitled ‘‘our friend’’, Abramoff wrote: 

asked if we could help (as in cover) a Scotland golf trip for 

him and some staff (his committee chief of staff) and members for August. The trip will be quite expensive (we did 

this for another member—you know who) 2 years ago. I 

anticipate that the total cost—if he brings 3–4 members 

and wives—would be around $100K or more. I can probably get another one of my tribes to cover some of it. let 

[sic] me know if you guys could do $50K and I’ll get them 

to do the other $50K, though I’ll have to get him to bring 

someone who has relevance to their matters—our friend 

does not as you can imagine. They would probably do the 

trip through the Capital Athletic Foundation as an educational mission. I have to start planning this now to make 

sure they can get tee times. Can you let me know if this 

would be OK, and possibly start to process it as a donation 

to Capital Athletic Foundation? Thanks.245

Schwartz testified before the Committee that he spoke with 

Abramoff about his request. During a telephone conversation before 

Abramoff sent the email, Abramoff told Schwartz that ‘‘our friend’’ 

referred to Congressman Bob Ney.246 Based on that same conversation, Schwartz understood that Representative Tom DeLay was the 

‘‘you know who’’ who attended a trip two years before to Scotland.247 Abramoff never mentioned that CAF was a private charity 

or that he was involved in CAF.248 Abramoff described CAF as a 

group that arranged educational trips, junkets, and further described CAF as ‘‘a group that paid for golf outings.’’ 249

In a July 10, 2002 memorandum to Hisa, Schwartz wrote about 

Abramoff’s request: 

The Chairman of the committee handling our issue, and 

several of his Congressional colleagues have had an opportunity presented to travel to Scotland for a fact-finding 

mission during the August recess. You will recall that he 

and his colleagues have committed themselves to a solution to the dilemma faced by the Tigua Tribe and Alabama-Coushatta Tribe. 
123 

250Marc Schwartz document production (no Bates number) (July 10, 2002) (Memorandum 

from Marc Schwartz, Partners Group Consultants, to Lt. Governor Carlos Hisa, Ysleta del Sur 

Pueblo). 251Marc Schwartz document production (no Bates number) (July 18, 2002) (Memorandum 

from Marc Schwartz, Partners Group Consultants, to Chairman Kevin Battise, AlabamaCoushatta Tribe of Texas). 252 Capital Athletic Foundation, 2002 Return of Private Foundations Form 990PF. 253See Email from Jack Abramoff, Greenberg Traurig, to Marc Schwartz, Partners Group Consultants (GTG–E000076845) (August 2, 2002); Email from Jack Abramoff, Greenberg Traurig, 

to Marc Schwartz, Partners Group Consultants (GTG–E000076899) (September 12, 2002). 254 Interview of Honorable Robert W. Ney, Member, United States House of Representatives, in Washington, D.C. (November 12, 2004). 255 Id. 256 Id. 257 Id. 

Toward this end, I have determined that the cost of the 

delegation, their wives, and senior staff will be $100,000. 

Neither the Tiguas nor the Alabama-Coushattas has been 

solicited to underwrite this educational trip abroad, but I 

would strongly recommend that both Tribes consider a donation towards this effort. 

The chairman is the one person who has taken on our 

issue and has single-handedly carried the effort to this 

point. I believe it would be a very powerful vote of confidence if this contribution were made. There is an educational foundation that will actually be sending the delegation abroad and if you and the Alabama-Coushatta Tribe 

were to divide this cost, it would send a very strong message to a very powerful member of the Congressional leadership team.250

Schwartz successfully convinced the Alabama-Coushatta to do- nate to the trip. Thanking the Alabama-Coushatta for their donation, Schwartz wrote: ‘‘Thanks to you and your Council for agreeing 

to assist in the effort. Your $50,000 check should be made payable 

to the Capital Athletic Foundation.’’ 251 Because language favorably affecting the Alabama-Coushatta was supposed to be included 

along with the Tigua’s provision, the Alabama Coushatta donated 

$50,000 to the Capital Athletic Foundation, a private foundation 

established and operated by Jack Abramoff.252

The check was not forthcoming, however. Abramoff asked Schwartz about the status of the CAF money on August 2 and 

again on September 12.253 That Abramoff knew that his and Scanlon’s efforts on Election Reform were essentially dead in the water 

did not stop Abramoff from soliciting and accepting the money for 

the golf trip. In an interview with Committee staff, Congressman Ney said he never requested Abramoff to ask the Tigua to finance his trip to 

Scotland.254 Of the trip, Congressman Ney said the CAF sponsored it, and that Abramoff did not tell him CAF was his private foundation.255 Congressman Ney said the purpose of the trip was to raise money for underprivileged kids in Scotland and Washington, 

D.C.256 The itinerary consisted of golfing, meeting two parliamentarians, and watching the Marine Band.257

J. THE TRIBE MEETS WITH CONGRESSMAN NEY

At the Committee’s November 17, 2004, hearing, Schwartz testified, ‘‘As the election reform measure languished throughout the 
124 

258 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 229 (November 17, 2004) (statement of Marc Schwartz, president, Partners Group Consultants). 259 Id. 260 Id. 261Marc Schwartz document production (no Bates number) (August 2, 2002) (Memorandum 

from Marc Schwartz, Partners Group Consultants, to Chairman Kevin Battise, AlabamaCoushatta Tribe of Texas). 262 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 240–41 (November 17, 2004) (statement of Marc Schwartz, president, Partners Group Consultants); Id. at 231 (statement of Carlos Hisa, Lieutenant Governor, Ysleta del Sur Pueblo). 263 Id. at 241 (statement of Marc Schwartz, president, Partners Group Consultants). 264 Id. 265 Id. 266 Id. 267 Interview of Carlos Hisa, Lieutenant Governor, Ysleta del Sur Pueblo, in El Paso, Texas 

(October 28, 2004). Schwartz recalled that Congressman Ney’s chief of staff was also present 

but stayed for ten minutes. Interview of Marc Schwartz, president, Partners Group Consultants, 

in Washington, D.C. (November 10, 2004). 268 Interview of Carlos Hisa, Lieutenant Governor, Ysleta del Sur Pueblo, in El Paso, Texas 

(October 28, 2004). 269 Id. 270 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. 

(November 10, 2004). 

summer, Abramoff and Scanlon continued to report on substantial 

progress and a virtual guarantee of success. During that time, I requested a meeting between tribal representatives and Congressman Ney.’’ 258 Abramoff set up the meeting for early August 

2002.259

According to Schwartz, Abramoff claimed that ‘‘Congressman 

Ney did not want his trip to Scotland brought up, as he would 

show his appreciation for the Tribe later.’’ 260

On August 14, 2002, representatives of the Tigua and AlabamaCoushatta met with Congressman Ney in Washington, D.C.261

Both Schwartz and Hisa recalled that the meeting lasted approximately one-and-a-half hours.262 In testimony before the Committee, 

Schwartz described Congressman Ney as ‘‘extremely animated 

about Mr. Abramoff and his ability as a representative lobbyist in 

the city.’’ 263 According to Schwartz, Congressman Ney spoke about 

his district, the Tigua’s plight, the political ramifications for Republicans of the Tigua casino closing, and the federal legislative process, especially the process by which committee reports are done.264

Schwartz also told the Committee that Congressman Ney gave 

them assurances that he was working to help the Tigua.265 Thereafter, Schwartz recalled Congressman Ney giving Lt. Governor 

Hisa and another tribal council member a tour of his hearing 

room.266 According to Lt. Governor Hisa, at that meeting (which 

was attended by not only Hisa but also Schwartz, Tribal Council 

Member Raul Gutierrez, Abramoff and Congressman Ney) Congressman Ney said that ‘‘everyone who needs to be involved, is on 

board.’’ 267 Congressman Ney said that he and Senator Dodd were 

committed to getting the language in the bill and that he did not 

foresee any problem with the Tigua-related provision, Hisa recalled.268 Hisa also remembered that, about Abramoff, Congressman Ney said that he was a ‘‘good friend’’; ‘‘you’re working with the 

right guy’’; and ‘‘this is the man to work with for changes in Washington.’’ 269

According to Schwartz, Congressman Ney’s chief of staff gave 

Abramoff a huge bear hug.270 Schwartz recalled that Congressman 
125 

271 Id. 272 Interview of Honorable Robert W. Ney, Member, United States House of Representatives, in Washington, D.C. (November 12, 2004). 273 Id. 274 Id. 275 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 229 (November 17, 2004) (statement of Marc Schwartz, president, Partners Group Consultants). 276 Id. at 252 (prepared statement of Hon. Christopher J. Dodd, U.S. Senator from Connecticut). 277Marc Schwartz document production (no Bates number) (September 19, 2002) (Memorandum from Marc Schwartz, Partners Group Consultants, to Governor Albert Alvidrez, Lt. 

Governor Carlos Hisa, and Tribal Council, Ysleta del Sur Pueblo). 278 Id. 279 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 230 (November 17, 2004) (statement of Marc Schwartz, president, Partners Group Consultants). 280 Interview of Sheryl Cohen, chief of staff, Senator Christopher J. Dodd, in Washington, D.C. (November 16, 2004). 281 Interview of Honorable Robert W. Ney, Member, United States House of Representatives, 

in Washington, D.C. (November 12, 2004). 

Ney went out of his way to say he would take care of the Tigua’s 

problems and kept calling the Tigua ‘‘deserving.’’ 271

During his interview with Committee staff, Congressman Ney 

said he was not familiar with the Tigua.272 He could not recall ever 

meeting with any member of the Tigua.273 When asked about a 

possible two-hour meeting, Congressman Ney said he ‘‘wouldn’t 

even meet with the President for two hours.’’ 274 After the interview, counsel to Congressman Ney, who was present during the 

interview, indicated that, according to an internal email describing 

Congressman Ney’s calendar for the relevant period, a meeting was 

scheduled in Congressman Ney’s office with the ‘‘Taqua,’’ from 

11:00–11:30 a.m. 

K. ELECTION REFORM PASSES WITHOUT THE TIGUA PROVISION

From August through October, Abramoff and Scanlon continued 

to report that the Senate would not be a problem, because Senator 

Dodd had allegedly agreed to include the Tigua language through 

his side.275 According to Senator Dodd and his staff, although Congressman Ney’s staff and Lottie Shackleford approached Senator 

Dodd’s office about including a provision that Senator Dodd termed 

‘‘recognition,’’ Senator Dodd never agreed to include the Tigua provision in the Election Reform bill.276

A little over one month later, Schwartz reported to the Tribal 

Council on another conversation that he had with Abramoff.277

Schwartz was under the impression that ‘‘our language is in the report. We were asked by Chairman Ney to step up the support for 

the measure and, as I reported on Tuesday, Scanlon/Gould has 

achieved that.’’ 278

Weeks later, however, the Tigua’s efforts were dead in the water. 

The Tigua language was not included in the final Election Reform 

legislation or accompanying report. Abramoff told Schwartz that 

‘‘Congressman Ney had reported Senator Dodd had gone back on 

his word and stripped the measure from the committee report.’’ 279

However, there was never any language helping the Tigua in any 

draft that came across the desk of Senator Dodd’s staff.280 Congressman Ney confirmed that no such language was ever inserted.281
126 

282 Interview of Shawn Maher, legislative director, Senator Christopher J. Dodd, in Wash- ington, D.C. (November 16, 2004). 283 Id. 284 Id. 285 Id. 286 Email between Marc Schwartz, Partners Group Consultants, to Jack Abramoff, Greenberg Traurig (no Bates number) (October 7, 2002). 287 Id. 288 Id. 289 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 290 Id. 291 Id. See also ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 230 (November 17, 2004) (Statement of Marc Schwartz, president, Partners 

Group Consultants). 292 Id. 293 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 294 Id. 295 Id. 296 Id. 

Shawn Maher, who worked for Senator Dodd during the relevant 

period, recalled that in the waning hours of the conference on election reform, Congressman Ney’s staff approached him about getting 

the Tigua fix into the report accompanying the bill.282 Maher said 

Paul Vinovich, former Staff Director to the House Committee on 

Administration, raised the issue, describing it as ‘‘a fix’’ to help a 

Southwestern tribe’s gaming.283 Maher recalled telling Vinovich 

that ‘‘that was not where his boss was.’’ 284 According to Maher, 

Vinovich did not press the issue further.285

In the waning moments of election reform, Schwartz wrote to 

Abramoff: ‘‘Jack: Ney’s phone call tomorrow? Did we have a miracle 

and get back on? What’s next?’’ 286

Abramoff responded: ‘‘We did not get back on. We are 

strategizing on the Hill with Ney’s guys and other friends (recipients of contributions from the tribe included) at 1 PM today. Call 

is on for tomorrow, but I don’t have the precise time yet. I’ll get 

it to you shortly.’’ 287 Later that day, Abramoff wrote ‘‘Bob Ney will 

be available at 11 am East Coast time tomorrow, Tuesday. We will 

use our conference call facility.’’ 288

Schwartz told Committee staff that on October 8, the Tribe had 

a conference call with Congressman Ney that lasted 20–30 minutes.289 During that teleconference, Congressman Ney blamed Senator Dodd for the demise of the Tigua’s provision.290

On October 8, the Tigua Tribal Council had a conference call 

with Congressman Ney, Jack Abramoff, Tom Diamond and Marc 

Schwartz.291 During that telephone conference, Schwartz testified, 

Congressman Ney expressed ‘‘disbelief that Senator Dodd had gone 

back on his word’’ and ‘‘further reported that he would continue to 

work on the issue and believed that the tribe was entitled to their 

gaming operation.’’ 292 During the call, according to Schwartz, Congressman Ney apologized for the Tigua provision not making it in 

the bill.293 Schwartz also recalled that Congressman Ney complained about Senator Dodd and expressed outrage over his alleged 

last-minute withdrawal of support.294 Congressman Ney said he 

would not give up and he would work to get the Tigua language 

on other measures in 2003, Schwartz recollected.295 And, according 

to Schwartz, he also thanked the Tribe for its support and contributions.296
127 

297See Email from Jack Abramoff, Greenberg Traurig, to Marc Schwartz, Partners Group Consultants (no Bates number) (March 26, 2003). 298 Id. 299 Interview of Duane Gibson, Greenberg Traurig, in Washington, D.C. (March 17, 2006). 300 Id. 301 Id. 302 Id.; see also Email between Jack Abramoff, Greenberg Traurig, and Ralph Reed, Century 

Strategies (GTG–E000018092–93) (July 22, 2003) (wherein Reed writes ‘‘yes, it looks interesting. 

I assume you’ll set up a meeting in DC as a next step, or whatever we should do next, let me 

know.’’). 303 Interview of Duane Gibson, Greenberg Traurig, in Washington, D.C. (March 17, 2006). 304 Id. 305 Id. 306 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. 

at 235 (November 17, 2004) (statement of Carlos Hisa, Lieutenant Governor, Ysleta del Sur 

Pueblo). 307 Id. at 236. 

L. THE ELDER LEGACY PROJECT

After the failed effort on Election Reform, Abramoff continued 

hounding the Tigua for more money. He proposed that the Tribe 

take out life insurance policies on its elders, with the proceeds to 

be paid to the Eshkol Academy, the all boys Jewish school that 

Abramoff had established. Abramoff intended the program, which 

he called the Elder Legacy Program, to generate lobbying funds to 

pay for Abramoff’s continued representation of the Tribe and provide funding for Eshkol.297 When Duane Gibson, an Abramoff associate at Greenberg Traurig working on the Project, reminded 

Abramoff that he could not use the insurance proceeds to lobby, 

Abramoff’s solution was to have the school use other funds to pay 

the lobbying fees.298

Gibson told the Committee that the Elder Legacy Program was 

trying to leverage funds for Indian tribes, but mostly charities, by 

acquiring life insurance policies for the tribe or charity.299 The 

original pool of insureds were Indian tribes, Alaskan Natives, and 

black church elders.300

Abramoff told Gibson that Ralph Reed was going to be the entree 

for the black churches, because Reed ‘‘knows the Southern Black 

Christian community.’’ 301 Apparently, Abramoff pitched the idea to 

Reed, who thought it was viable.302

According to Gibson, Abramoff said that the Tigua were ‘‘indebted to him because I [Abramoff] saved their asses and they 

want to do this for me.’’ 303 Gibson believed ‘‘the whole Tigua thing 

was a perversion of the original purpose.’’ 304 Although he was 

scheduled to meet with Schwartz in El Paso about the program, the 

meeting never took place.305 The reason: after initially, internally 

approving the idea, the Tribal Council decided not to move forward 

on it.306 Lt. Governor Hisa met with the Tribal elders, who rejected 

it.307

M. ABRAMOFF AND SCANLON ATTEMPT TO OBSTRUCT THE

INVESTIGATION

When The Washington Post articles about Abramoff and Scanlon 

were published in February 2004, Abramoff tried to downplay 

them: ‘‘The piece was the usual hit bullshit, but what’s new. Funny 

part (for me, not Mike) was that 60% of the over 300 emails I got 
128 

308 Email from Jack Abramoff, Greenberg Traurig, to Marc Schwartz, Partners Group Consult- ants (GTG–E000075963) (February 23, 2004). 309 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 236 (November 17, 2004) (statement of Marc Schwartz, president, Partners Group Consultants). 310 Id. 311 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 247 (November 17, 2004); see also Interview of Marc Schwartz, president, Partners Group 

Consultants, in Washington, D.C. (November 10, 2004). 312 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 247 (November 17, 2004). 313 Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 314 Id. 315 Interview of Carlos Hisa, Lieutenant Governor, Ysleta del Sur Pueblo, in El Paso, Texas 

(October 28, 2004). 316 Id. 317 Id. 318 Id. 319 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. 

at 244 (November 17, 2004). 

thought it was a puff piece. Thank G-D for ADD!’’ 308 In a telephone call, Abramoff assured Schwartz ‘‘that there was nothing to 

the articles, that it was certainly more of a witch hunt that a reporter had done.’’ 309 Of the Committee’s proposed hearings, 

Abramoff said they ‘‘were nothing more than political payback.’’ 310

After the second article ran in The Washington Post about the relationship between Abramoff and Scanlon, Abramoff called 

Schwartz to say that the Tribe did not have to cooperate in the 

Committee’s investigation.311 In the event that Committee counsel 

or investigators called the Tribe, Abramoff wanted the Tribe to 

speak with his lawyers first.312 Abramoff said that the Tribe had 

tribal sovereignty and that the Tribe did not need to cooperate with 

the Committee.313 Abramoff said that the Mississippi Band of 

Choctaw Indians were not cooperating with the investigation, and 

suggested that the Tigua not cooperate as well.314

N. CONCLUSION

The $4.2 million that the Tribe regrettably paid Scanlon could 

have lasted the Tribe for another year.315 At a minimum, some of 

that money could have been used to hire lobbyists who could have 

represented the Tribe better in the legislative process.316 The Tribe 

would have dedicated much of the money to education and health 

care.317 As a result of the $4.2 million payout to Scanlon, and the 

casino’s closure, key programs, namely an insurance program for 

the Tribal members, had to be cut back or eliminated.318

During the Committee’s November 17, 2004, hearing, when 

asked how he felt upon learning that the Tribe had paid for a golf 

outing for the man who had worked to shut down the Tigua casino, 

Lt. Governor Hisa replied, ‘‘A rattlesnake will warn you before it 

strikes. We had no warning. They did everything behind our 

back.’’ 319
(129) 

1 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000003033) (March 7, 2002). 2Sandia Pueblo Mountain Claim, (visited May 11, 2006) <http://www.sandiapueblo.nsn.us/ 

mountain/mtnlclaim.html>; Interview of Stuwart Paisano, former Governor, Pueblo of Sandia 

of New Mexico, in Washington, D.C. (April 18, 2006). 3Sandia Pueblo Mountain Claim, (visited May 11, 2006) <http://www.sandiapueblo.nsn.us/ 

mountain/mtnlclaim.html>. 4 Id. 

CHAPTER VI 

PUEBLO OF SANDIA OF NEW MEXICO 

A. INTRODUCTION

The experience of the Pueblo of Sandia with Jack Abramoff and 

his partner Michael Scanlon is a microcosm of the larger scandal 

that has been exposed by the Committee during its investigation 

of lobbying activities associated with six Indian Tribes. The characters and the elements of deception are much the same. However, 

the financial loss to the Pueblo of Sandia and the subsequent financial gain to Abramoff and Scanlon were, relatively speaking, on a 

scale considerably smaller than what the other Tribes experienced. 

This fact was not lost on Abramoff and Scanlon early in their relationship with the Pueblo of Sandia, as evidenced by the following 

email exchange on March 7, 2002, that was titled ‘‘Sandia’’: 

SCANLON: ‘‘[$]2.75 [million] is chump change!!! What [t]he 

hell were we thinking?’’ 

ABRAMOFF: ‘‘No kidding. [then-Abramoff associate Kevin] 

Ring brought us down! Next time one of these guys brings 

us something we are not going to listen to their fucking 

whining.’’ 

SCANLON: ‘‘Hey—its still a W—[sic] and I will take the W 

[sic] any way we can—now a [$]4.5 [million] W [sic] would 

be nicer—but wait till Thursday when [Coushatta] comes 

to town!’’ 1

B. BACKGROUND ON THE TRIBE

In February 2002, the Pueblo of Sandia, a Tribe located on the 

northern boundary of Albuquerque, was facing perhaps the most 

significant legal challenge of its 700-year existence in New Mexico.2

In the late 1980s, with development beginning to encroach on the 

sacred Sandia Mountain, the Tribe appealed to the Department of 

the Interior to correct a survey conducted in 1859.3 The correction 

would designate the main ridge of the Sandia Mountain as the 

Pueblo’s eastern boundary.4 Years of litigation ensued that involved the Pueblo of Sandia, government agencies, and area residents, culminating in a settlement agreement on April 4, 2000 
130 

5 Id.; Greenberg Traurig document production (GTG–E000002775–76) (undated). 6Sandia Pueblo Mountain Claim, (visited May 11, 2006) <http://www.sandiapueblo.nsn.us/ 

mountain/mtnlclaim.html>. 7 Id. 

8Why is the Mountain So Important to the People of Sandia? (visited May 11, 2006) <http:// 

www.sandiapueblo.nsn.us/mountain/whatlchanges.html#whylimportant>. 9 Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006). 10 Id. 11 Id. 12 Id. 13 Id. 14 Interview of David Mielke, outside counsel, Pueblo of Sandia of New Mexico, in Washington, 

D.C. (April 18, 2006). 15 Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006). 

that, by its terms, required Congressional ratification by November 

15, 2002.5

The settlement agreement was of monumental importance to the Tribe.6 Having the Sandia Mountain as its boundary signified more than a property settlement.7 The Mountain’s significance is de- scribed on the Tribe’s web site: 

For centuries, the people of Sandia Pueblo have lived in 

the shadow of the mountain. The mountain has served as 

our church and our spiritual sustenance for hundreds of 

years. The mountain is the highest priority of the people 

of Sandia Pueblo, a sacred responsibility of every generation. This is not a question of ownership for the Pueblo, it 

is a question of preservation and protection of the mountain, and the ability to practice religious and culture traditions unrestricted by government edict.8

According to the former Governor of the Tribe, Stuart Paisano, the Pueblo of Sandia have 481 enrolled members.9 They have a tra- ditional government structure in which their religious leaders play 

an important role in selecting the Tribe’s governor and other leadership positions.10 The Tribe has 23,000 acres and their native language is Tigua.11 Their economy has transitioned in the last thirty years from mining and federal assistance to Class III gaming.12

C. THE SEARCH FOR A NEW LOBBYIST

The Pueblo of Sandia had considerable experience with legal counsel through their years of litigation and retained a local law 

firm that was trusted by the Tribe.13 They were also not unsophis- ticated in the ways of the lobbying world and had, over time, retained several firms in Washington, D.C. to help them on various 

matters.14 However, securing Congressional approval of a major lands settlement thrust them into a different political sphere, particularly at a time when the federal political landscape had 

changed considerably. There was a new Republican administration 

and a new set of political appointees at the Department of the Interior. The Pueblo of Sandia were uncertain about whether the New 

Mexico Delegation would support ratification of the settlement.15

The stakes were high and the clock was ticking. It was against this backdrop of urgency that David Mielke, a longtime and trusted counsel to the Pueblo of Sandia, suggested 

that the Tribe consider hiring a lobbyist with Republican connections. 
131 

16 Id. 17 Interview of David Mielke, outside counsel, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006). 18 Id. 19 Id. 20 Id.; Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in 

Washington, D.C. (April 18, 2006). 21 Interview of David Mielke, outside counsel, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006). 22 Id. 23 Id. 24 Id. 25 Id. 26 Id. 27 Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006). 28 Interview of David Mielke, outside counsel, Pueblo of Sandia of New Mexico, in Washington, 

D.C. (April 18, 2006). 

Late in 2001, Governor Paisano, Lieutenant Governor Alex 

Lujan, and Tribal council member Frank Chaves and Lawrence 

Avila were tasked with vetting several firms for the job.16 Ultimately, the search team interviewed several top Washington lobbyists that Mielke identified for the Tribe, including the firm of 

Quinn Gillespie & Associates and former Senator Bob Dole.17

One of the Washington lobbyists who was of particular interest 

to the Tribe was Kevin Ring.18 Several of Mielke’s partners were 

familiar and impressed with Ring’s work for other Tribes.19 In February 2002, arrangements were made for the Tribal leaders to meet 

with Ring who was accompanied by his boss, Jack Abramoff. Michael Scanlon was an unexpected participant at the meeting.20 In 

pitching his services, Abramoff stressed his Republican connections, going back to his days working on grassroots activities for 

President Reagan.21 Scanlon was described as DeLay’s former communications director and someone who helped with elections in 

competitive Congressional districts.22

Scanlon’s price tag for the task was $2,875,000, most of which, 

he said, would be the cost of a database to conduct the grassroots 

effort.23 In an interview with Committee staff, Mielke recalled that 

while this amount seemed high, Abramoff said that almost the entire price was costs and that the profits were actually less than 

10% of the total proposed price.24

Mielke also recalled that, during these sessions, Scanlon pitched 

the database as ‘‘a key component’’ of the program.25 Mielke said 

that Scanlon specifically characterized ‘‘the software [as] the army, 

which would mean 10,000 soldiers who could be counted on.’’ 26

Paisano remembered Scanlon describing the database as ‘‘customized’’ and necessary ‘‘to effectively do public relations [for the 

proposed project].’’ 27

Abramoff was intent on having the Tribe sign Scanlon as part of 

the arrangement, according to both Mielke and Governor Paisano, 

Abramoff insisted that Scanlon was a sine qua non of the federal 

lobbying efforts Abramoff intended to undertake on the Tribe’s behalf. He characterized Scanlon as ‘‘part of the package’’ and an indispensable part of his proposal, if he was to achieve success.28

Abramoff also offered to halve Greenberg Traurig’s $125,000 per 

month retainer if the Tribe hired Scanlon. And, finally, he proposed, on Scanlon’s behalf, a ‘‘slight’’ reduction from how much 

Scanlon originally wanted to charge the Tribe, plus a success fee. 
132 

29 Id.; Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in 

Washington, D.C. (April 18, 2006). The evidence set forth in Part 2, Chapter 1, entitled ‘‘Capitol 

Campaign Strategies,’’ of this Report reflects Abramoff’s admission in the plea agreement in his 

criminal case that Scanlon’s profit margin on his contracts with the Tribes was closer to 80%. 

See Plea Agreement, Factual Basis for the Plea at para. 22, U.S. v. Jack A. Abramoff (Dist. D.C., 

January 3, 2006) (CR–06–001); see also Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign Strategies (GTG–E000003054) (March 20–21, 2002) (‘‘I told 

[Ring] that he would split the profit (what I told him was 10%) with you 50–50.’’). 30 Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006). 31 Id. 32 Interview of David Mielke, outside counsel, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006). 33 Id. 34 Id. 35 Id. 36 Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006). 37 Id.; Interview of David Mielke, outside counsel, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006); Pueblo of Sandia document production (SP–S 00046–48) (March 

14, 2002) (letter of agreement between Scanlon Gould Public Affairs and Pueblo of Sandia of 

New Mexico for $2,750,000). 38Pueblo of Sandia document production (SP–S 00046–48) (March 14, 2002) (letter of agree- ment between Scanlon Gould Public Affairs and Pueblo of Sandia of New Mexico for $2,750,000). 39 Id. 40 Id. 

But, Abramoff cautioned, he could not go lower because Scanlon’s 

‘‘10% profit margin is locked [into that reduced figure].’’ 29

Governor Paisano recalled in his interview with Committee staff 

that Abramoff impressed the Tribal leaders with his aggressive approach, specifically recalling Abramoff ‘‘talk[ing] about breaking 

bones and busting kneecaps.’’ 30 Paisano said he was left with the 

impression that Scanlon worked for Greenberg Traurig.31

The Pueblo of Sandia and their counsel chafed at the cost of the 

Scanlon proposal, but they wanted Abramoff and, particularly, 

Ring on their side.32 According to Mielke, the Tribe’s view was that adequate representation was the most important issue for the 

Tribe and that cost should not be an issue.33 The Tribe considered 

which prospective lobbyist gave it the greatest assurances: ‘‘That 

was a question: ‘can you guarantee this?’ ’’ 34 ‘‘Abramoff and Scanlon had the most bravado and said that while they couldn’t guarantee that, they’ve never lost,’’ Mielke observed.35

So, after several rounds of interviews, Tribal leaders were nearly unanimous in thier decision to hire Greenberg Traurig, with only 

Governor Paisano and Council Member Frank Chaves expressing 

some concerns.36 Ultimately, the Tribe selected Abramoff and Ring at Greenberg Traurig, and entered into a separate contract with 

Scanlon to conduct the grassroots effort.37

D. IMPLEMENTING THE PLAN

On March 19, 2002, Governor Paisano signed a letter of agree- ment with Scanlon in which the Tribe committed to pay $2,750,000 

for public affairs services.38 The total payment was due ten days later.39 As described more thoroughly in Part 2, Chapter 1, of this Report, these funds were wired to an account controlled by Capitol 

Campaign Strategies, one of Scanlon’s companies, from which 

countless withdrawals were subsequently made to Abramoff (or entities owned or controlled by him). It is notable that, given that 

part of Scanlon’s proposal was to conduct several letter writing 

campaigns, the letter of agreement, which he drafted, included numerous typographical errors and misspellings.40
133 

41 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign Strategies (GTG–E000003054) (March 20–21, 2002). 42 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. 

at 23 (November 2, 2005) (testimony of Fred Baggett, Chair, National Governmental Affairs 

Practice, Greenberg Traurig). 43 Id. 44 Id. 45 Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006); Interview of David Mielke, outside counsel, Pueblo of Sandia of 

New Mexico, in Washington, D.C. (April 18, 2006). 

Ring’s activities focused on the federal legislative effort. On March 20–21, within a few days of the contract being signed, Scanlon and Abramoff had occasion to reflect on their arrangement with 

him: 

SCANLON: [Ring] asked if we got the wire yet in an email. I have no problem telling him yes—what do we owe him 

again? 10% of profit? 

ABRAMOFF: No, 5% of gross. I told him that he would split the profit (which I told him was 10%) with you 50–50. 

SCANLON: So we owe him 135k? 

ABRAMOFF: Damn I guess so. [sic] Shit, that sucks. 

SCANLON: I forgot to tie that amoun tin [sic] to the sandia [sic] figures—so our numbers are going to come down a little bit. 

ABRAMOFF: Finders [sic] fee I guess. ...41

Ring’s ‘‘finder’s fee’’ was apparently in violation of an outside in- come policy at his firm Greenberg Traurig.42 In testimony before the Committee on November 2, 2005, Fred Baggett, Managing 

Shareholder and Chairman of the National Government Affairs 

Practice at Greenberg Traurig, said that the firm’s internal investigation ‘‘has found, and as we have informed Federal authorities 

and I believe this committee, we found a number of other instances 

where members of Mr. Abramoff’s team had received compensation 

outside of the firm.’’ 43 One of those Baggett named was Kevin 

Ring.44 Of course, the most egregious offender of the policy was Abramoff who had plotted with Scanlon to split the Pueblo of 

Sandia profit as part of their ‘‘gimme five’’ scheme. It should also 

be noted that Kevin Ring, who the Tribe trusted and respected, did 

not disclose his financial arrangement with Scanlon to the Tribe 

until 2004, months after the publication of the Washington Post article that initially exposed the Abramoff and Scanlon lobbying scandal.45

After spending at least a month hiring their lobbying and grass- roots team, the Tribe was eager to start seeing some results. They 

quickly realized that there was a disconnect between the bravado 

of the pitch they had received and the quality of Scanlon’s work of 

what was done. As Mielke explained to Committee staff: 

Their pitch is that things are sliding quickly. Hire us soon 

or we are not going to do it. ... The Tribe acted quickly, 

[and] wired the money to Scanlon. A couple of weeks 

lapsed and Scanlon sends out three people to New Mexico. 

They sent me draft letters that were poorly written. It was 

Chris Cathcart, [CCS associate,] a fairly young woman 

who turned out to be Scanlon’s sister, and another woman. 

... These people weren’t high dollar, high quality folks. I 
134 

46 Interview of David Mielke, outside counsel, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006). 47 Id. 48Pueblo of Sandia document production (SP–S 00046) (March 14, 2002) (letter of agreement 

between Scanlon Gould Public Affairs and Pueblo of Sandia of New Mexico). 49 Id. 50 Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006); Interview of David Mielke, outside counsel, Pueblo of Sandia of 

New Mexico, in Washington, D.C. (April 18, 2006). 51 Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006); Interview of David Mielke, outside counsel, Pueblo of Sandia of 

New Mexico, in Washington, D.C. (April 18, 2006). 52 Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006); Interview of David Mielke, outside counsel, Pueblo of Sandia of 

New Mexico, in Washington, D.C. (April 18, 2006). 

took the Governor to dinner to express concerns. It didn’t 

take long to question the value of Scanlon. Once these letters started coming in, they were obviously form letters 

with small variations. One letter went to the Albuquerque 

Journal. Someone from the paper called me and asked 

what were we [sic] doing. Word circulated. There was no 

variation in who they would send the letters to, including 

typos in letters. The Tribe was happy with Ring[;] he 

would get back to them[,] seemed on top of things. 

Abramoff and Scanlon dropped off as soon as the deal was 

signed. Even the polls I saw weren’t works of art.46

E. THE DATABASE

As with other Tribal clients, Scanlon’s sales pitch centered on the 

customized database, which he said would be the heart of the 

grassroots effort. Mielke, in his interview with Committee staff, recalled the following: 

... [a] big part of the fee was the software and time and 

personnel that they would spend in compiling this database ... they said it was going to cost between $2 and $3 

million for the whole effort and that the database would be 

a big part. This was just Scanlon. ... Scanlon had a staff 

of 16 people, talking about 10,000 FedEx packages. This 

was going to be a sprint, [sic] this money was going to go 

out immediately for vendors and software.47

In fact, in the contract between Scanlon and the Tribe, 

$1,857,000 is specifically identified for ‘‘Building of National Political Organization.’’ 48 The scope of work ‘‘include[d] acquisition and 

design of hardware and software, data matching, grassroots development, online applications and political modifications.’’ 49

However, according to Mielke and Paisano, the database was significantly less than what had been promised.50 It appeared to be 

a simplistic regurgitation of the data that the Tribe had provided 

to Scanlon.51 Paisano described the database as ‘‘pathetic’’ and 

Mielke said it was the ‘‘same info that the Tribe gave them; no 

magic in it.’’ 52

As more fully discussed in Part 2, Chapter 1, of this Report, it 

appears that Scanlon copied (in violation of licensing agreements to 

which he was a party) elements of a database created by Democracy Data Communications (‘‘DDC’’). Scanlon had originally subcontracted DDC to build political databases for other Tribes. The ac-
135 

53 Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). 54 Interview of David Mielke, outside counsel, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006). 55 Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006); Interview of David Mielke, outside counsel, Pueblo of Sandia of 

New Mexico, in Washington, D.C. (April 18, 2006). 56 Email between Jack Abramoff, Greenberg Traurig, Kevin Ring, Greenberg Traurig, and Michael Scanlon, Capitol Campaign Strategies (GTG–E000003258–59) (June 25, 2002). 

tual cost of a database developed for the Tribe by another vendor, 

which was apparently designed to mimic DDC’s far more functional 

database, was nowhere near the $1,875,000 that the Tribe was 

charged by Scanlon.53

Understanding the urgency of the situation and acknowledging 

the fact that Scanlon’s grassroots campaign was a failure and an 

embarrassment—‘‘amateurish’’ in Mielke’s words—Mielke and the 

Tribe began their own grassroots effort, independent of Scanlon’s.54

The Tribe also hired a local public relations firm to assist in their 

efforts. 

Mielke and Paisano continued to express concern and criticism of 

Scanlon’s work product.55 As an indication of how out of touch he 

appeared to be, Scanlon actually entertained the idea of asking the 

Tribe for more money, as evidenced in the following June 25, 2002, 

email exchange with Kevin Ring and Jack Abramoff: 

SCANLON: Hey—I have a few thoughts—1) The land exchange concept was a huge tactical blunder that is going 

to haunt the tribe for years to come. 2) We need another 

3 mil to win this thing now. 3) They should Take [sic] 

Bingaman and be happy. Wow [,] we are in a pickle now. 

RING: Are you on drugs? 

SCANLON: Really good ones! 

ABRAMOFF: Tell him to recommend some for us to take! 

RING: I know. All kidding aside, if he even thinks of asking 

for more money, they are going to hunt him down and kill 

him. And then come after us. 

ABRAMOFF: Ha ha ha 

SCANLON: I’m gonna go for it—Im [sic] gonna schedule a 

conference cal [sic] and ask for 2 more mil! 

ABRAMOFF: I love it!!!!! 56

Several months later, when the Tribe was renegotiating its contract with Greenberg Traurig, the lighthearted mood was noticeably absent, as evidenced by the following March 4, 2003 email exchange between Ring and Abramoff: 

RING: ... Once again for Sandia, the issue was Scanlon. 

They said we did a great lobbying job, but since we insisted that they hire him, we bore responsibility for his 

lack of performance ... 

ABRAMOFF: Kevin, this excuse about Scanlon from them is 

bullshit. I don’t care how much they hate him, they paid 

for a result and they got it. whether [sic] he did what they 

wanted or not, they got their fucking mountain. And for 

them to be telling you they won’t rehire us because of him 

is also fucking bullshit. I know that not getting them will 

be a big hit on you and I am sorry about that, and I sup-
136 

57 Email between Jack Abramoff, Greenberg Traurig, and Kevin Ring, Greenberg Traurig, 

(GTG–E000003763) (March 4, 2003). 58 Interview of David Mielke, outside counsel, Pueblo of Sandia of New Mexico, in Washington, 

D.C. (April 18, 2006). 59 Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006); Interview of David Mielke, outside counsel, Pueblo of Sandia of 

New Mexico, in Washington, D.C. (April 18, 2006). 60 Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006); Interview of David Mielke, outside counsel, Pueblo of Sandia of 

New Mexico, in Washington, D.C. (April 18, 2006). 61 Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006); Interview of David Mielke, outside counsel, Pueblo of Sandia of 

New Mexico, in Washington, D.C. (April 18, 2006). 

port whatever you want to do on this, but I think they’re 

already gone and they are using that Scanlon excuse because they are cheap mother fuckers who don’t want to 

pay our fees. I say fuck them and let’s go get you a different tribe which appreciates hard work.57

As it turned out, the Pueblo of Sandia extended their contract, 

at a reduced rate, with Greenberg Traurig until the revelations of 

the Washington Post were published in 2004.58

F. A HAPPY ENDING, IN SPITE OF ... 

The Committee finds that deception was a consistent theme in 

the Pueblo of Sandia’s relationship with Abramoff and Scanlon: the 

exorbitant fee for a ‘‘pathetic’’ database; the secret financial arrangement between Abramoff and Scanlon; the undisclosed ‘‘finder’s fee’’ to Kevin Ring; and the overwhelming incompetency of the 

grassroots effort. 

The Tribe’s experience with Scanlon gave new meaning to the 

phrase ‘‘take the money and run.’’ Mielke and Governor Paisano 

agreed that the Tribe received little of the intended benefit of the 

millions that the Tribe paid Scanlon.59 They also felt that the Tribe 

was aggrieved by Abramoff and Scanlon’s failure to disclose their 

financial arrangement.60 And, they were frustrated by the poor 

quality of Scanlon’s grassroots activities and felt that Scanlon’s status reports were inadequate.61

As the concerns of local citizens were addressed and neutralized 

by the Tribe and its counsel, the uncertainty about how some members of the New Mexico Delegation felt about the settlement began 

to fade. The settlement legislation was considered favorably by the 

Senate Committee on Energy and Natural Resources and the Senate Committee on Indian Affairs. In the end, the combination of 

support from the New Mexico Delegation and a homegrown grassroots effort was the key to Congressional approval. Success was 

achieved, but for reasons wholly unrelated to the extraordinarily 

expensive pretensions of Abramoff and Scanlon. 
(137) 

1 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. at 

5–9 (September 29, 2004) (opening Statement of Ranking Majority Member John McCain). 

PART TWO—‘‘GIMME FIVE’’—ANALYSIS BY ENTITY 

INTRODUCTION 

[W]e really need mo money. but [sic] you and I must meet 

and work out a strategy to get things moving. We are 

missing the boat. There are a ton of potential opportunities 

out there. there [sic] are 27 tribes which make over $100M 

a year ... can you have your guys do the research and find 

out which tribes these may be? We need to get moving on 

them ... 

Email from Jack Abramoff to Michael Scanlon, December 7, 2002 

SCANLON: Hey—good day all around—we wrapped up the 

Sag Chip crap—We hit Coush—I think for 3 mil—and we 

are working [on] Acaliente [sic] presentation—should be 

tight. 

ABRAMOFF: Thanks so much! You are a great partner. 

What I love about our partnership is that, when one of us 

is down, the other is there. We’re gonna make $ for years 

together! 

SCANLON: Amen! You got it boss—we have many years 

ahead! 

Email between Michael Scanlon and Jack Abramoff, June 20, 2002 

The Committee held its first hearing on allegations of misconduct 

made by several Indian Tribes against Jack Abramoff and Michael 

Scanlon on September 29, 2004. At that hearing, the Committee 

preliminarily concluded that Scanlon collected about $66 million 

from six tribes over a three-year period, and secretly paid about 

one-third of that amount to Abramoff.1 Since then, the Committee 

has held a series of hearings and released scores of documents that 

describe how Abramoff and Scanlon executed their scheme. 

In the course of its hearings, the Committee laid out how 

Abramoff and Scanlon agreed that Abramoff would work to ensure 

that these Tribes would hire a grassroots/public relations specialist 

to support Abramoff’s lobbying activities. In furtherance of their 

scheme, Abramoff pushed for Scanlon as that specialist. 

Having violated these Tribes’ trust by not disclosing the resulting 

conflict of interest, Abramoff secretly collected from Scanlon about 

50 percent of Scanlon’s net proceeds—from contracts that Scanlon 

or Abramoff promoted to the Tribes. 

The prices that Scanlon charged for his services (well in excess 

of his costs) were set deliberately high so as to allow him to pay 

Abramoff about 50 percent of his net proceeds from those Tribes— 
138 

2Plea Agreement, Factual Basis for Plea, U.S. v. Michael P.S. Scanlon (Dist. D.C., November 

11, 2005) (CR–05–411); Plea Agreement, Factual Basis for Plea, U.S. v. Jack A. Abramoff (Dist. 

D.C., January 3, 2006) (CR 06–001). 3See Email from Jack Abramoff, Greenberg Traurig, to Kathryn Van Hoof, Coushatta Tribe 

of Louisiana, ‘‘Coushatta political program’’ (COUSH–MiscFin–0000371) (April 12, 2001) (‘‘I still 

do not have the budget for the complete effort, but Mike believes we cannot wait any longer 

for the ground effort, so I need to get this to you for approval. ... Please let me know if I can 

give Mike the go ahead.’’); Email from Michael Scanlon, Capitol Campaign Strategies, to Kathryn Van Hoof, Coushatta Tribe of Louisiana, ‘‘Re: Political Program funding’’ (COUSH–MiscFin– 

0000368) (April 18, 2001) (‘‘The total for the program is $539,000. In order to get started the 

tribe will need to pay $200k up front to cover the organizational program. ... If thre [sic] is any 

way to get the initial money out today it would be great!’’). 4Diehl & Company document production (D00411–512) (undated) (General Ledger, Capitol 

Campaign Strategies). 5Diehl & Company document production (D00411–512) (undated) (General Ledger, Capitol 

Campaign Strategies). 6 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E0001321307) (May 2, 2001). Abramoff and Scanlon, both of whom were apparently 

avid golfers, even came up with a name for their new business arrangement: ‘‘Gimme [or give 

me] five.’’ The Committee speculates that ‘‘gimme five’’ is a double entendre for the golf term 

‘‘gimme,’’ which refers to a putt that is certain to be made on the next shot, which will most 

likely be conceded by an opponent. Where Abramoff valued his interest in CCS, at ‘‘$5M revenue/year,’’ see Email between Jack Abramoff and Rodney Lane, ‘‘FW: Personal financial statement’’ (GTG–E000011577) (March 15, 2002), the term also appears to reflect Abramoff and 

Scanlon’s original agreement to acquire at least $5 million each per year. 7 Email between Michael Scanlon, Capitol Campaign Strategies, and Jack Abramoff, Greenberg Traurig (GTG–E000011945) (June 18, 2001). 

with much of the money paid by the Tribes not going for purposes 

the Tribes intended. 

Admitting to the foregoing, on November 11, 2005, and January 

3, 2006, respectively, Scanlon and Abramoff pled guilty in federal 

court to, among other things, defrauding some of their Tribal clients.2

On a small scale, Abramoff and Scanlon apparently set their 

scheme in motion in April 2001, when they urged the Coushatta 

Tribe of Louisiana (‘‘Louisiana Coushatta’’) to pay $200,000 for a 

grassroots program regarding its gaming compact.3 On or about 

April 26, 2001, the Tribe paid a Scanlon-controlled entity called 

Capitol Campaign Strategies (‘‘CCS’’) $200,000, as requested.4 But, 

soon thereafter, CCS paid Abramoff $75,000—itemized in the company’s accounting ledger on April 30, 2001, as a ‘‘referral expense.’’ 5

Abramoff and Scanlon’s secret fee-splitting arrangement is likewise reflected in a May 2, 2001, email, where they agreed to split 

proceeds from the Mississippi Band of Choctaw Indians (‘‘Choctaw’’) that were intended to be passed through a Scanlon-controlled 

entity called the American International Center (‘‘AIC’’) to former 

Christian Coalition executive director Ralph Reed for grassroots activities. According to Abramoff, ‘‘I am going to try to get us $175K. 

$100 to Ralph; $25K to contributions ($5K immediately to Conservative Caucus); rest gimme five.’’ 6

The scheme would soon soar to new heights. On June 18, 2001, 

Scanlon suggested to Abramoff, ‘‘A few weeks ago you mentioned 

something to me—I took the concept and have put together a plan 

that will make serious money. We also talked briefly about it in the 

beginning of the year but I think we can really move it now.’’ 7

Scanlon continued: ‘‘I have been making contacts with some larger Public Affairs companies in town for a few months. I have two 

solid relationships that will seriously consider acquiring Capitol 
139 

8 Id. 

9 Id. 

10 Id. 11 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000011951) (June 29, 2001). 12 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign 

Strategies, ‘‘RE: Nell’’ (Bates number 1109861) (August 16, 2001). 13 Email between Michael Scanlon, Capitol Campaign Strategies, and Jack Abramoff, Greenberg Traurig, ‘‘RE: [REDACTED]’’ (1118666) (September 2, 2001). 14 Brody Mullins, Breakup of Ex-Aides Shook Group Tied to Abramoff—The Prosecutors Move 

In; Ms. Miller’s Tearful Apology, Wall Street Journal, March 31, 2006 at A1. 15 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E0000113995) (September 10, 2001). 16 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg 

Traurig (GTG–E0000113847) (September 10, 2001). 

Campaign Strategies. The problem is that there is not much in 

CCS right now.’’ 8

‘‘However,’’ he observed, ‘‘if we build up Capitol Campaign Strategies enough I can get it acquired by a large firm by the end of 

next year at 3x the firm revenue. Bottom line: If you help me get 

CCS a client base of $3 million a year, I will get the clients served, 

and the firm acquired at $9 million. We can then split the [sic] up 

the profits. What do you think?’’ 9

Abramoff’s response was brief: ‘‘Sounds like a plan, but let’s discuss when we are together.’’ 10

Abramoff apparently agreed. Just a few days later, referring to 

a ‘‘project [that Abramoff] need[ed] to run trhough [sic] [a Scanlon 

company],’’ Abramoff wrote Scanlon, ‘‘Apparently it’s a huge 

project. ... It’ll give us $500K to start to pass through CCS and as 

much as $4 million over the year. This should really help us get 

the sales price up.’’ 11

Thus began Abramoff and Scanlon’s now-infamous financial relationship—a relationship that would enable the two to wrongfully 

extract tens of millions of dollars from tribes around the country 

over the next two years. 

By August 2001, what started as a seemingly innocuous partnership soon degenerated into an all-out frenzy for money—money at 

any cost. In response to Scanlon’s informing him that ‘‘[the Choctaw] really liked [a particular] plan ... [and] asked if I could do a 

quick poll for them on the [REDACTED] overall political issues 

they face,’’ Abramoff reminded Scanlon, ‘‘Don’t forget the gimme 

five aspects!’’ 12

On September 2, 2001, Scanlon was ecstatic about how they were 

doing so far: ‘‘I’m having a great time running the give me fives!’’ 13

There was good reason for Scanlon’s elation. Later that month, he 

reportedly bought, likely with the Tribes’ money, two houses in 

Washington, D.C. for $1.2 million.14

With his share of those proceeds, Abramoff apparently intended 

to float his private Jewish boys’ school. On September 10, 2001, he 

asked Scanlon, ‘‘Can you let me know how much more (than the 

current +/¥ 660K) we would each score should Coushatta come 

through for this phase, and Choctaw continue to make the transfers. I need to assess where I am at for the school’s sake.’’ 15

Ultimately, Scanlon reported that Abramoff would get ‘‘a total of 

2.1 [million].’’ 16
140 

17 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E0000113847) (September 10, 2001) (emphasis added). 18 Id. 19 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign 

Strategies, ‘‘RE: [REDACTED]’’ (Bates numbers 1131487–88) (October 17, 2001). 20 Id. 21 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000024563) (January 16, 2002). 22 In Abramoff’s plea agreement, the total figure is $23,109,695, which includes not only indirect payments by Tribes to Abramoff or Abramoff-controlled entities through entities controlled 

by Scanlon but also direct payments by several companies, including Foxcom Wireless, S.P.I. 

Spirits, and Tyco International, to entities controlled by Abramoff, including Grassroots Interactive. See Plea Agreement, Factual Basis for Plea at para 1–31, U.S. v. Jack A. Abramoff (Dist. 

D.C., January 3, 2006) (CR 06–001). In Scanlon’s plea agreement, the figure is $19,698,644, 

which captures about 50% of the net profit Scanlon received from at least four tribes that had 

already hired Abramoff ‘‘to provide professional services to develop programs to limit market 

competition or to assist in opening casinos that were vital to the profitability of [the] clients.’’ 

See Plea Agreement, Factual Basis for Plea at para. 8, U.S. v. Michael P.S. Scanlon (Dist. D.C., 

November 11, 2005) (CR 05–411). In other words, it appears to exclude payments made by the 

Agua Caliente, which had not hired Abramoff before hiring Scanlon. 

Abramoff heaped praise on his partner, ‘‘How can I say this 

strongly enough: YOU IZ DA MAN.’’ 17

Not content with the $2.1 million, Scanlon exhorted, ‘‘[L]et’s grow 

that 2.1 to 5!! We need the true give me five!’’ 18

Abramoff conveyed enthusiasm about their arrangement on October 16, 2001: ‘‘I love life!! We need to get you down there to get 

[the Mississippi Band of Choctaw Indians] moving on the political 

phase. How about if we both try to go soon.’’ 19

Scanlon agreed, ‘‘Any time—any time—any time!!! We usually 

come back from these trips rich men!’’ 20

From late 2001 through 2003, ‘‘running [their] give me fives’’ was 

Abramoff and Scanlon’s top priority. In a January 16, 2002, email 

from Abramoff to Scanlon, entitled ‘‘sagchips,’’ Abramoff wrote, 

‘‘Don’t forget to get to [Saginaw Chippewa Sub-Chief David] Otto 

and set up a meeting asap. We need that moolah. We have to hit 

$50M this year (our cut!).’’ 21

As a result of their ‘‘gimme five’’ scheme, Abramoff and Scanlon 

collected about $66 million from six tribes from 2001 through 2003. 

By the Committee’s reckoning, each Tribe paid Scanlon as follows: 

the Mississippi Band of Choctaw Indians (‘‘Choctaw’’), $14,745,650; 

the Coushatta Tribe of Louisiana (‘‘Louisiana Coushatta’’), 

$26,695,500; the Saginaw Chippewa Indian Tribe of Michigan 

(‘‘Saginaw Chippewa’’), $10,007,000; the Agua Caliente Band of 

Cahuilla Indians (‘‘Agua Caliente’’), $7,200,000; the Ysleta del Sur 

Pueblo of Texas (‘‘Tigua’’), $4,200,000; and the Pueblo of Sandia of 

New Mexico (‘‘Pueblo of Sandia’’), $2,750,000. 

Also by the Committee’s accounting, Abramoff or entities owned 

or controlled by Abramoff, including Kaygold and the Capital Athletic Foundation (‘‘CAF’’), received payments totaling about 

$24,524,421 from Scanlon or entities owned or controlled by Scanlon, including Capitol Campaign Strategies (‘‘CCS’’) (which also did 

business as Scanlon Gould Public Affairs and Scanlon Public Affairs), the American International Center (‘‘AIC’’), and Atlantic Research and Analysis (‘‘ARA’’).22 That seems to constitute about half 

of Scanlon’s total profit from the Tribes. The following lays out the 

basis for the Committee’s finding. 
141 

‘‘GIMME FIVE’’ PROCEEDS TO ABRAMOFF AND ABRAMOFF-CONTROLLED ENTITIES 2001–2003 

Date Payee Amount Payor 

4/30/01 ........................................... Abramoff ....................................... $75,000 CCS 

5/20/01 ........................................... CAF ................................................ 182,000 CCS 

6/10/01 ........................................... Abramoff ....................................... 50,000 CCS 

10/4/01 ........................................... Abramoff ....................................... 100,000 CCS 

10/25/01 ......................................... Abramoff ....................................... 428,000 CCS 

11/7/01 ........................................... CAF ................................................ 1,000,000 Coushatta through Greenberg 

Traurig 

12/19/01 ......................................... Abramoff ....................................... 300,000 CCS 

12/31/01 ......................................... Abramoff ....................................... 1,718,125 CCS 

1/1/02 ............................................. CAF ................................................ 500,000 Choctaw 

2/22//02 .......................................... Kaygold .......................................... 2,779,925 CCS 

3/21/02 ........................................... Abramoff ....................................... 4,080,997 CCS 

4/8/02 ............................................. Kaygold .......................................... 2,138,025 CCS 

5/30/02 ........................................... Abramoff ....................................... 16,397 CCS 

6/12/02 ........................................... Kaygold .......................................... 150,000 CCS 

7/12/02 ........................................... Kaygold .......................................... 800,000 CCS 

7/12/02 ........................................... Kaygold .......................................... 20,000 CCS 

7/12/02 ........................................... Kaygold .......................................... 44,000 CCS 

8/6/02 ............................................. CAF ................................................ 500,000 Choctaw 

9/16/02 ........................................... Kaygold .......................................... 2,266,250 CCS 

10/17/02 ......................................... CAF & Nurnberger ......................... 500,000 Choctaw through NCPPR 

11/11/02 ......................................... Kaygold .......................................... 1,078,649 CCS 

12/03/02 ......................................... Kaygold .......................................... 87,907 CCS 

12/31/02 ......................................... Kaygold .......................................... 1,000,146 CCS 

12/31/02 ......................................... Kaygold .......................................... 53,000 CCS 

2/19/03 ........................................... Kaygold .......................................... 1,965,000 CCS 

4/13/03 ........................................... Kaygold .......................................... 991,000 AIC 

5/7/03 ............................................. CAF ................................................ 950,000 Atlantic Research & Analysis 

10/27/03 ......................................... Kaygold .......................................... 750,000 CCS 

Total $24,524,421 

In the sections that follow, this Report will discuss how Abramoff 

and Scanlon ran their ‘‘gimme five’’ scheme on six of their tribal 

clients: the Mississippi Band of Choctaw Indians (‘‘Choctaw’’), the 

Coushatta Tribe of Louisiana (‘‘Louisiana Coushatta’’), the Saginaw 

Chippewa Indian Tribe of Michigan (‘‘Saginaw Chippewa’’), the 

Agua Caliente Tribe of the Cauhilla Indians (‘‘Agua Caliente’’), the 

Ysleta del Sur Pueblo of Texas (‘‘Tigua’’) and the Pueblo of Sandia 

of New Mexico (‘‘Pueblo of Sandia’’) (collectively, ‘‘the Tribes’’ and 

individually, ‘‘the Tribe’’). Although this Report will mention other 

vehicles owned or controlled by Abramoff or Scanlon, this Section 

will focus on how they did so by using primarily three: Capitol 

Campaign Strategies (‘‘CCS’’), the American International Center 

(‘‘AIC’’), and the Capital Athletic Foundation (‘‘CAF’’). 

CHAPTER I 

CAPITOL CAMPAIGN STRATEGIES 

[W]e should not reveal [valuing my share in Capitol Campaign Strategies (‘‘CCS’’) at $5 million per year] to anyone 

but [my tax advisor], though, since no one knows the CCS 

stuff. 

Email from Jack Abramoff to business associate Rodney Lane, March 15, 2002 

ABRAMOFF: Thanks so much! You are a great partner. 

What I love about our partnership is that, when one of us 
142 

23The Committee finds and, in court filings Scanlon has admitted, that Scanlon Gould Public 

Affairs was largely used to receive funds in the performance of business activities of CCS. See 

Plea Agreement, Factual Basis for Plea at para. 2, U.S. v. Michael P.S. Scanlon (Dist. D.C., November 11, 2005) (CR 05–411). Therefore, this Report will refer to CCS, Scanlon Gould Public 

Affairs, and Scanlon Public Affairs interchangeably as ‘‘CCS’’ or ‘‘Scanlon.’’ 24 Interview of Christopher Cathcart, former associate, Capitol Campaign Strategies, in Washington, D.C. (October 6, 2004). 25Plea Agreement, Factual Basis for Plea at para.1, U.S. v. Jack A. Abramoff (S.D. Fla. January 4, 2006) (CR 05–60204). 

is down, the other is there. [w]e’re gonna make $ for years 

together!’’ 

SCANLON: Amen! You got it boss—we have many years 

ahead! 

Email between Jack Abramoff and Michael Scanlon, June 20, 2002 

SCHMIDT: Do you have an ownership stake in Capitol Campaign Strategies or Scanlon Gould or any of Mike Scanlon’s ventures? 

ABRAMOFF: No. No, I don’t. 

Exchange between Jack Abramoff and Washington Post reporter Susan Schmidt, 

on February 4, 2004, as transcribed in a Greenberg Traurig email 

A. BACKGROUND

Of all the entities that Michael Scanlon owned or controlled, the 

one that he and Jack Abramoff used most extensively in carrying 

out their ‘‘gimme five’’ scheme was Capitol Campaign Strategies 

(‘‘CCS’’), which also did business as Scanlon Gould Public Affairs 

and Scanlon Public Affairs.23 CCS was first started up ‘‘to help 

Scanlon collect [consulting] fees.’’ 24 During the first quarter of 

2001, CCS’ only client appears to have been SunCruz Casinos, a 

Florida-based casino cruise-ship company that Abramoff and a 

former business partner, Adam Kidan, have admitted to defrauding.25

From 2001 through 2003, CCS secretly paid Abramoff, and entities owned or controlled by Abramoff, including an entity called 

Kaygold, about $20,083,421. In total, those payments, set forth 

below, constitute about half of Scanlon’s net profit from the Tribes. 

SECRET PAYMENTS BY CCS TO ABRAMOFF FROM 2001–2004 

4/30/01 ............................................................ Abramoff .......................................................... $75,000 

5/20/01 ............................................................ CAF .................................................................. 182,000 

6/10/01 ............................................................ Abramoff .......................................................... 50,000 

10/4/01 ............................................................ Abramoff .......................................................... 100,000 

10/25/01 .......................................................... Abramoff .......................................................... 428,000 

12/19/01 .......................................................... Abramoff .......................................................... 300,000 

12/31/01 .......................................................... Abramoff .......................................................... 1,718,125 

2/22/02 ............................................................ Kaygold ............................................................ 2,779,925 

3/21/02 ............................................................ Abramoff .......................................................... 4,080,997 

4/8/02 .............................................................. Kaygold ............................................................ 2,138,025 

5/30/02 ............................................................ Abramoff .......................................................... 16,397 

6/12/02 ............................................................ Kaygold ............................................................ 150,000 

7/12/02 ............................................................ Kaygold ............................................................ 800,000 

7/12/02 ............................................................ Kaygold ............................................................ 20,000 

7/12/02 ............................................................ Kaygold ............................................................ 44,000 

9/16/02 ............................................................ Kaygold ............................................................ 2,266,250 

11/11/02 .......................................................... Kaygold ............................................................ 1,078,649 
143 

26Plea Agreement, Factual Basis for Plea at para. 9, U.S. v. Jack A. Abramoff (Dist. D.C., 

January 3, 2006) (CR 06–001). 27 Id. 28 Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe of Michigan, in 

Washington, D.C. (September 13, 2004). 29 Id. 30 Interview with Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. 

(November 10, 2004). 31 Id. 32 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 108th Cong. 

at 239 (September 29, 2004) (statement of Marc Schwartz, president, Partners Group Consultants). 33 Interview with Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. 

(November 10, 2004). 

SECRET PAYMENTS BY CCS TO ABRAMOFF FROM 2001–2004—Continued 

12/03/02 .......................................................... Kaygold ............................................................ 87,907 

12/31/02 .......................................................... Kaygold ............................................................ 1,000,146 

12/31/02 .......................................................... Kaygold ............................................................ 53,000 

2/19/03 ............................................................ Kaygold ............................................................ 1,965,000 

10/27/03 .......................................................... Kaygold ............................................................ 750,000 

Total ........................................................ .......................................................................... 20,083,421 

In the sections that follow, this Chapter will describe how 

Abramoff and Scanlon used CCS to further their ‘‘gimme five’’ 

scheme. In particular, it will describe how most of the money that 

the Tribes paid Scanlon was used for purposes unintended by the 

Tribes and how, in most cases, the Tribes received little of the intended benefit for the vast sums that they paid CCS. 

B. ABRAMOFF CONCEALS HIS FINANCIAL RELATIONSHIP WITH SCANLON

For Abramoff and Scanlon’s ‘‘gimme five’’ scheme to succeed, secrecy was key. In furtherance of that ‘‘gimme five’’ scheme, 

Abramoff and Scanlon agreed that Scanlon’s payments to Abramoff 

would not be disclosed to Abramoff and Scanlon’s Tribal clients.26

They understood that disclosing their arrangement to those clients 

would likely jeopardize the contracts for services, CCS’ profit margin, or both.27

Committee staff asked Saginaw Chippewa tribal Sub-Chief Bernie Sprague what, if anything, the Tribe knew about Abramoff and 

Scanlon’s financial arrangement. In response, Sprague recalled 

that, as the Tribe was considering in December 2003 whether to retain Abramoff, he specifically asked Abramoff about his relationship with Scanlon.28 Sprague remembered that Abramoff only answered that he knew him and his relationship with Scanlon was 

professional.29

Likewise, in testimony before the Committee, Tigua tribal representative Marc Schwartz recalled that a couple of days or so before Abramoff and Scanlon’s presentation to that Tribe, he specifically asked Abramoff whether Scanlon was connected to 

Abramoff.30 Schwartz recalled that Abramoff answered ‘‘no.’’ 31 In 

fact, telling Schwartz that Scanlon had ‘‘his own’’ company, 

Abramoff referred to Scanlon as merely ‘‘an associate.’’ 32 Schwartz 

also recalled asking Abramoff whether he used Scanlon exclusively.33 Without bringing up his financial arrangement with Scan-
144 

34 Id. 35 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, Choctaw, Mis- sissippi (April 27–29, 2005). 36See Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe of Michigan, in Washington, D.C. (September 13, 2004); Interview of Chairman Richard Milanovich, Agua 

Caliente Band of Cahullia Indians, in Washington, D.C. (September 16, 2004); Interview of Lieutenant Governor Carlos Hisa, Ysleta del Sur Pueblo, in El Paso, Texas (October 28, 2004); Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 

10, 2004); Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, 

Mississippi (April 27–29, 2005); Interview of Chief Phillip Martin, Mississippi Band of Choctaw 

Indians, in Washington, D.C. (May 17, 2005); Interview of William Worfel, former tribal councilmember, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13, 2005); Interview of 

Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 

18, 2006). 37 Interview of Fred Baggett, Chair, National Government Affairs Practice, Greenberg Traurig, in Washington, D.C. (September 29, 2005). 38 Id. But see James Grimaldi and Susan Schmidt, The Fast Rise and Steep Fall of Jack 

Abramoff, Washington Post, December 29, 2005 (reporting that Greenberg Traurig discovered Abramoff’s outside sources of income earlier when it examined his tax records in connection with 

the SunCruz bankruptcy matter). 39 Interview of Fred Baggett, Chair, National Government Affairs Practice, Greenberg Traurig, in Washington, D.C. (September 29, 2005). 40 Id. 41 Id. Despite these plaudits, Greenberg Traurig decided not to hire Scanlon full-time because 

he ‘‘wanted to pursue other outside engagements on his own, and we ... weren’t going to have 

somebody who could do that.’’ Id. Ultimately, the firm brought in Scanlon as a consultant. Id. 

That engagement, for which Scanlon was paid $10,000 per month from Abramoff’s overhead, 

lasted for only about a year. Id. Other than having decided that ‘‘we didn’t have use for him,’’ 

Baggett does not know why the firm stopped paying Scanlon. Id. 

lon, Abramoff answered non-responsively: he liked to use Scanlon 

for the tough fights because ‘‘[h]e always [got] results.’’ 34

Similarly, when Abramoff and Scanlon gave their presentation at the Agua Caliente Tribal Council, Abramoff only represented that 

Scanlon ‘‘work[ed] very closely with our firm [Greenberg Traurig].’’ 

And, when Abramoff originally recommended Scanlon to the Choctaw, he introduced Scanlon as an independent consultant.35

While it is unclear whether Abramoff or Scanlon similarly misled the remaining Tribes, the Committee finds the following: no Tribe 

that ultimately hired Abramoff and Scanlon during the relevant period knew about their financial relationship.36

In his deposition with Committee staff, the head of the Greenberg Traurig’s national lobbying practice Fred Baggett testified 

that, until Abramoff’s meeting with the firm’s partners about the 

seminal The Washington Post article in February 2004, Abramoff never disclosed that he was receiving payments from Scanlon out 

of money that the Tribes were paying Scanlon.37 In fact, during a meeting about a tribal newsletter in 2003, Abramoff denied that he 

had any financial relationship with Scanlon and tried to explain 

the article away as politically driven by competitors of the firm.38

When Abramoff first discussed hiring Scanlon with Baggett, Abramoff merely described Scanlon as ‘‘the best as far as public relations and grassroots ... that he had ever dealt with’’ who provided 

‘‘value added’’ in helping the his clients with ‘‘Washington media 

and public relations efforts as well.’’ 39 In that context, Abramoff indicated, Scanlon had been ‘‘extremely helpful to [him] and his clients.’’ 40 Baggett also remembered that Abramoff indicated ‘‘[h]ow valuable [Scanlon] was, that he was essential to being able to provide services to his clients.’’ 41

In what appears to be an effort to ensure that his Tribal clients 

did not know about his financial arrangement with Scanlon, 

Abramoff demanded secrecy of his business associates and advisors. For example, in a March 15, 2002, email, Abramoff directed 
145 

42 Email from Jack Abramoff, Greenberg Traurig, to Rodney Lane (GTG–E000011577) (March 15, 2002). 43 Id. 44 Email from Gail Halpern, May & Barnhard, to Jack Abramoff, Greenberg Traurig (GTG– E000012116) (February 19, 2003). 45 Id. 46 Email from Jack Abramoff, Greenberg Traurig, to Gail Halpern, May & Barnhard (GTG– E000012115) (February 20, 2003). Whether Halpern came to know or should have known that 

Abramoff was Scanlon’s partner and, with that knowledge, furthered their scheme to bilk their 

tribal clients is a question beyond the scope of this investigation. 47Plea Agreement, Factual Basis for Plea, U.S. v. Jack A. Abramoff (Dist. D.C., January 3, 2006) (CR 06–001). See Interview of Bernie Sprague, Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (September 13, 2004); Interview of Chairman Richard Milanovich, 

Agua Caliente Band of Cahullia Indians, in Washington, D.C. (September 16, 2004); Interview 

of Lieutenant Governor Carlos Hisa, Ysleta del Sur Pueblo of Texas (October 28, 2004); Interview of Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 

10, 2004); Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, 

Mississippi (April 27–29, 2005); Interview of Chief Phillip Martin, Mississippi Band of Choctaw 

Indians, in Washington, D.C. (May 17, 2005); Interview of William Worfel, former Vice-President, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13, 2005); Interview of 

Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 

18, 2006). 48 Interview of Christopher Cathcart, former associate, Capitol Campaign Strategies, in Wash- ington, D.C. (October 6, 2004). 49 Email from Kevin Ring, Greenberg Traurig, to Matt DeMazza (GTG–E000257509) (February 22, 2004). 

Rodney Lane, apparently a partner in his restaurant ventures, to 

value his share in his partnership with Scanlon at $5 million per 

year, ‘‘valued as $30M (multiple of 6 [years]).’’ 42 In so doing, he 

also directed that ‘‘we should not reveal this to anyone but [my tax 

advisor], though, since no one knows the CCS stuff.’’ 43

Similarly, in a February 19 and 20, 2003, email, in which 

Abramoff’s tax advisor, Gail Halpern, suggested to Abramoff how 

he could minimize Scanlon’s withholding money from CCS’ payments to Abramoff. Halpern recommended, ‘‘[m]aybe you should 

work thinks [sic] so that the folks you are cutting these business 

deals with pay Mike [Scanlon’s] LLC called CCS $x dollars, and 

pay your LLC called KayGold $y dollars. then [sic] DC doesn’t get 

a chunk of your take.’’ 44

She elaborated, ‘‘[g]etting your own check from the client would 

resolve that over the long run would save big bucks.’’ 45

Abramoff responded, ‘‘It’s just not going to happen.’’ 46

C. ABRAMOFF INDUCES THE TRIBES INTO HIRING AND PAYING

SCANLON

Having concealed his financial arrangement with Scanlon from 

his Tribal clients, Abramoff urged them to hire a grassroots political consultant.47 Then, Abramoff convinced them into hiring Scanlon as that consultant. According to Scanlon’s highly compensated 

right-hand man, Christopher Cathcart, Scanlon said that ‘‘the larger fee [that CCS paid Abramoff] keeps ... Abramoff remembering 

CCS when he meets clients around the country.’’ 48 Likewise, in 

support of the proposition that ‘‘the truth is worse’’ than the facts 

set forth in the February 2004 Post article, former Abramoff associate Kevin Ring disclosed to a colleague that Abramoff ‘‘talk[ed] 

tribes into hiring Scanlon.’’ 49

On October 5, 2001, Abramoff told Scanlon how he ran this part 

of the scheme on the legislative director of the Saginaw Chippewa: 

I had dinner tonight with Chris Petras of Sag Chip. He 

was salivating at the $4–5 million program I described to 
146 

50 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000028079) (October 5, 2001). (emphasis in original). 51 Id. (emphasis in original). 52 Id. 53 Email between Michael Scanlon, Capitol Campaign Strategies, and Jack Abramoff, Greenberg Traurig (GTG–E000011983) (February 28, 2003). 54 Id. (emphasis in original). 55 Id. 56 Id. 57 Id. 

him (is that enough? Probably not). They have their primary for tribal council on Tuesday, which should determine if they are going to take over (general elections in 

November). I told him that you are the greatest campaign 

expert since ... (actually, I told him that there was no one 

like you in history!). He is going to come in after the primary with the guy who will be chief if they win (a big fan 

of ours already) and we are going to help him win. If he 

wins, they take over in January, and we have millions. I 

told him that you are already in national demand and we 

need to secure you for them. He is very excited. GIMME 

FIVE lives.50

Scanlon responded, ‘‘THE PRICE HAS JUST GONE UP TO 

10MIL!! Sounds good on the strategy—We should be wrapped up 

with the other camapaigns [sic] soon, so I could run his general 

election to make sure we get or [sic] give me five!!’’ 51

Abramoff concurred, ‘‘Great.’’ 52

Documents suggest that Abramoff and Scanlon ran this part of 

the scheme on the Saginaw Chippewa well into 2003. On February 

28, 2003, Scanlon complained to Abramoff that ‘‘[o]ur shop is not 

under contract with [the Saginaw Chippewa] for PR—we have done 

it for them as part of programs in the past—but we aren’t doing 

any work for them—and we will not until they hire us as their PR 

firm of Record.’’ 53

He noted, ‘‘To tell you the truth—we would rather not work for 

them any more—but if we get the retainer gig—that wil [sic] do. 

NO CASH—NO INK BABY!’’ 54

Abramoff responded, ‘‘I am not sure this is the right strategy 

here ... I think we might be able to get some more big sums from 

these guys.’’ 55

He explained, ‘‘[T]he trick right now should be to get their shit 

work done as quickly and painlessly as we can and set up a plan 

right now for future efforts. That way we know there is a pot of 

gold at the end of the rainbow.’’ 56

In that context, Abramoff informed Scanlon that he ‘‘told [Saginaw Chippewa legislative director Chris Petras] that this was the 

only way to get you involved because you have just too many other 

clients putting $10M deals in front of you. he [sic] said they would 

do this.’’ 57 The Committee has seen no evidence that any other clients were putting $10 million deals before Scanlon previously or at 

that time. 

On or about July 9, 2002, Abramoff promoted Scanlon to the 

Agua Caliente, describing Scanlon as ‘‘[formerly] with the U.S. 

Congress, a communications director for the leadership of the 

House of Representatives and subsequently has gone on to become 
147 

58 Agua Caliente document production (no Bates number) (‘‘Verbatim Transcript—Tribal Council Meeting of Tuesday, July 9, 2002’’) (July 20, 2004) (excerpt only). 59 Interview of William Worfel, former Vice-President, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13, 2005). 60 Id. 61 Interview with Tom Diamond, Esq., Diamond, Rash, Gordon & Jackson, outside counsel, 

Ysleta del Sur Pueblo, in El Paso, Texas (October 28, 2004). 62 Interview with Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 63 Id. Plea Agreement, Factual Basis for Plea at para. 6, U.S. v. Jack A. Abramoff (Dist. D.C., 

January 3, 2006) (CR–06–001); Plea Agreement, Factual Basis for Plea at 2, U.S. v. Michael 

P.S. Scanlon (Dist. D.C., November 11, 2005) (CR 05–411). 64 Interview with Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 65 Id. 66 Id. 67 Id. 68 Interview with Tom Diamond, Esq., Diamond, Rash, Gordon & Jackson, outside counsel, 

Ysleta del Sur Pueblo of Texas, in El Paso, Texas (October 28, 2004). 

one of the top political and grassroots public affairs people in the 

United States.’’ For his part, Scanlon said at the meeting, ‘‘My firm 

is in strategic alliance with Jack and Greenberg [Traurig,] meaning 

we only provide services to the clients of Greenberg Traurig. No 

other law or lobbying firms in Washington, DC. We work exclusively for his clients and provide our services to Jack exclusively.’’ 58

Former Louisiana Coushatta councilman William Worfel recalled 

in his interview with staff that Abramoff continuously pressed his 

Tribe to pay Scanlon the millions he charged, quickly and completely. In particular, Worfel remembered that, according to 

Abramoff, the need to pay Scanlon was ‘‘always a crisis, ASAP’’: 

‘‘[I]t was just 100 miles per hour, boom, boom, boom, boom. Oh, 

yes. But, I ain’t never seen this.’’ 59 Worfel elaborated, ‘‘[Scanlon 

would always say,] ‘We got to have it, man.’ ‘We’re getting hammered.’ ‘We need it.’ ‘We’ve got to turn the phone banks on.’ ‘We’ve 

got to get the blitz going.’ It was always a crisis.’’ 60

Abramoff’s approach with the Tigua was equally aggressive. A 

tribal representative observed that Abramoff pushed Scanlon 

‘‘hotly.’’ 61 With that Tribe, Abramoff said that he and Greenberg 

Traurig would provide representation on a pro bono basis—at least 

until the Tribe’s casino was up and running.62 But, he insisted that 

the Tribe hire Scanlon as their political consultant.63 In that context, he described Scanlon as ‘‘tenacious’’ and a ‘‘bulldog.’’ 64 He also 

noted that Scanlon was ‘‘DeLay’s attack dog ... one of the reasons 

that Delay was so successful’’ and that ‘‘people [were] afraid of 

him.’’ 65 Abramoff promoted Scanlon as the person who did the 

groundwork on his projects and that, on tough fights especially, 

‘‘[h]e always gets results.’’ 66

Having told the Tigua how he planned anonymously to slip language into a legislative vehicle that would allow the Tigua to reopen its casino, Abramoff stressed ‘‘once the law is printed, someone’s going to know it and that’s where Mike [Scanlon] comes in.’’ 67

In particular, Abramoff laid out a strategic concept whereby Scanlon would serve as ‘‘a submarine’’—rising from under the radar and 

blanketing the telephones of offices of Members of Congress that 

have discovered the remedial language that Abramoff had sneaked 

into his legislative vehicle.68 Abramoff noted, ‘‘you better have the 
148 

69 Interview with Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. 

(November 10, 2004). 70 Id. 71 Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006); Interview of David Mielke, outside counsel, Pueblo of Sandia of 

New Mexico, in Washington, D.C. (April 18, 2006). 72 Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006). 73 Id.; Interview of David Mielke, outside counsel, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006). 74 Id. As described above, Scanlon deliberately set his prices to accommodate his secret payments to Abramoff. That required Scanlon to maintain a profit margin closer to 80 percent. See 

Transcript of Plea Agreement at 22, U.S. v. Jack Abramoff (Dist. D.C., January 3, 2006) (CR– 

06–001). 75 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, Choctaw, Mississippi (April 27–29, 2005). 76 Id. 77 Email from Todd Boulanger, Greenberg Traurig, to Jack Abramoff, Greenberg Traurig 

(GTG–E000025046) (February 14, 2002). 

best, because they will come after you.’’ 69 And, referring to Scanlon 

and his political database, Abramoff insisted, ‘‘If you are going to 

do this, you need this guy.’’ 70

Abramoff’s interest in having the Pueblo of Sandia hire Scanlon 

was particularly keen. Both then-Tribal Governor Stuwart Paisano 

and Tribal lawyer David Mielke recalled that, during a meeting 

with Abramoff at Greenberg Traurig in February 2002, Abramoff 

characterized Scanlon as indispensable to his federal lobbying practice and a sine qua non for success on the Tribe’s project.71 In laying out to the tribal representatives his plan to ‘‘break bones’’ and 

‘‘bust kneecaps,’’ Abramoff told them that he would only represent 

the Tribe if it hired Scanlon.72

So intent was Abramoff in having the Pueblo of Sandia hire 

Scanlon that he negotiated with the Tribe on Scanlon’s behalf and, 

in fact, offered several inducements to have the Tribe hire Scanlon. 

According to Paisano and Mielke, in the face of an unusually high 

contract price to hire Scanlon, Abramoff offered to further reduce 

Greenberg Traurig’s monthly retainer in exchange for or in contemplation of the Tribe’s hiring Scanlon.73 Mielke also recalled that 

Abramoff offered to reduce Scanlon’s asking price to $2,750,000, 

but said that he could not go further because the lower amount had 

‘‘Scanlon’s 10% profit margin locked in.’’ 74 Likewise, when the 

Choctaw were experiencing cash flow problems and budget shortfalls, Abramoff offered to defer payments to Greenberg Traurig to 

ensure that the Tribe could pay Scanlon in full.75 Also, when the 

Choctaw were late in paying Scanlon, more often than not 

Abramoff inquired about the status of the payments to Scanlon.76

Another way that Abramoff appears to have had some of the 

Tribes hire Scanlon for further projects was through alarming 

them, perhaps falsely, about threats to their sovereignty or gaming 

interests. For example, on or about February 11, 2002, Abramoff 

approved a ‘‘draft [Conservative Action Team’s] letter to the president [sic] and [Interior Secretary Gale] Norton saying ‘no more Indian gaming expansion’ ... [sic] [and] light a fire under [Deputy Interior Secretary Steven] Griles’s ass.’’ 77 Abramoff observed that 

‘‘[t]his will help us get [then-Louisiana Coushatta Tribal Council 

member] William [Worfel] scared about Blue Lake [in California], 
149 

78 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000025046) (February 14, 2002). 79See Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in 

Washington, D.C. (September 13–14, 2005). 80 Email between Michael Scanlon, Capitol Campaign Strategies, and Jack Abramoff, Greenberg Traurig (GTG–E000001244) (October 10, 2002). 81 Id. 82 Email from Jack Abramoff, Greenberg Traurig, to Christopher Petras, Saginaw Chippewa 

Indian Tribe (GTG–E000010716) (December 2, 2002). A ‘‘racino’’ is a racetrack that also offers 

casino gaming. 83 Id. 84 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg Traurig (GTG–E000010716) (December 2, 2002). 85 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Captiol Campaign Strategies (GTG–E000010716) (December 2, 2002). 

hopefully increasing our budget.’’ 78 During this period, the Lou- isiana Coushatta were interested in doing business there.79

Similarly, on October 10, 2002, Scanlon conveyed to Abramoff: ‘‘Lawmakers may consider a package of bills that would allow 

horse tracks to better compete with the casinos that have cut into 

their business the past several years. Tracks could be allowed to 

have video lottery terminals, card rooms, satellite betting sites and 

possibly other gambling to renew interest in attending horse 

races.’’ 80

Abramoff responded, ‘‘Here we go! This could kill Saginaw! [Sagi- naw Chippewa legislative director] Chris [Petras] thinks this is not 

going anywhere. Can you call him and scare him?’’ 81

Likewise, on December 2, 2002, Abramoff discussed the prospect 

of racinos in Michigan with Petras.82 In that email, on which he 

apparently blind-copied Scanlon, Abramoff noted the following: 

Chris, I am getting worried about this. Last night we 

opened Stacks and there were some WH guys there (who 

are also Michigan guys—worked for Spence). They told me 

that there is a hearing coming up on this immediately, and 

that they have heard that this is going to happen!!! The 

enemy is moving fast and we are not on the field. where 

[sic] is Scanlon on this? What is he doing? Have you guys 

pushed the button? We need to get him firing missiles. 

How do we move it faster? Please get the council focused 

on this as soon as you can. Every day [sic] we lose now is 

going to hurt.83

A few minutes later, Scanlon chimed in, ‘‘I love you.’’ 84

And, Abramoff replied, ‘‘I’ll follow up with him in a day.’’ 85

Once Abramoff succeeded in having the Tribes hire Scanlon, having kept his financial arrangement with Scanlon secret from the 

Tribes, Scanlon (for the benefit of Abramoff and himself) charged 

the Tribes a massive premium for his services. In total, the Tribes 

paid Scanlon about $66 million from 2001 through 2003. But, what 

really happened to the Tribes’ money? The following section attempts to shed light on this question. 

D. WHAT HAPPENED TO THE MONEY THAT THE TRIBES PAID SCANLON?

1. Snapshots of CCS’ Representation of the Tribes 

In connection with its first hearing on these matters, the Committee established that about 1⁄3 of Scanlon’s net proceeds went to 

Scanlon; about another 1⁄3 went to Abramoff; and the remaining 1⁄3
150 

86Plea Agreement, Factual Basis for Plea at para. 6, U.S. v. Michael P.S. Scanlon (Dist. D.C., 

November 11, 2005) (CR–05–411); Plea Agreement, Factual Basis for Plea, U.S. v. Jack A. 

Abramoff at para. 8–9 (Dist. D.C., January 3, 2006) (CR 06–001). 87Plea Agreement, Factual Basis for Plea at para. 6, U.S. v. Michael P.S. Scanlon (Dist. D.C., 

November 11, 2005) (CR–05–411); Plea Agreement, Factual Basis for Plea, U.S. v. Jack A. 

Abramoff at para. 8–9 (Dist. D.C., January 3, 2006) (CR 06–001). 88 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘02 CCS 

Project Break Downs’’) (undated). 89 Id. 90 Id. 

went to the underlying grassroots efforts Scanlon promised the 

Tribes. However, only an in-depth explication of this issue can 

allow one to apprehend the true extent and brazen nature of 

Abramoff and Scanlon’s deception of the Tribes. 

While a forensic analysis of what happened to the Tribes’ money lies well beyond the scope of the Committee’s investigation, the 

overwhelming weight of evidence that the Committee has obtained, 

as described below, indicates that, in most cases, the Tribes did not 

receive the intended benefit of the millions of dollars that they paid 

Scanlon. What follows are descriptions of certain representative 

transactions that the Committee was able to reconstruct that best 

support that proposition. 

a. Transaction #1 (Miscellaneous)—Huge Profit Margins 

In their plea agreements, Abramoff and Scanlon admitted to charging the Tribes grossly inflated prices for CCS’ services—prices 

that incorporated the undisclosed fees that Scanlon paid 

Abramoff.86 As noted throughout, those fees constituted about 50% of CCS’ net profit.87 Examples of how this worked, follow. 

Among the documents that the Committee discovered is what ap- pears to be the draft of a letter or other communication from Scanlon to Nell Rogers, the planner of the Mississippi Band of Choctaw 

Indians (‘‘Choctaw’’). Although the Committee has been unable to 

determine whether this record, probably drafted late in 2001, was 

actually transmitted, the representations contained within it are 

compelling. In that document, Scanlon said, ‘‘I think the following 

is the best way to prioritize our efforts [this year] and make them 

budget friendly ...’’ 

He explained, ‘‘[A] good chunk ... for [Project A] wont [sic] be 

needed until the general election is in full swing later in the year. 

That said: the overall figures are 4,850,000 for [Project A], and 

1,750,000 for [Project B], for a total of 6.6.’’ But, he added, ‘‘We will 

need the 1.75 for [Project B] and 1.85 for [Project A] ASAP.’’ Scanlon concluded: ‘‘On [Project A] we will need another 1m in about 

45 days or so—and the balance we can defer till October 2nd to 

meet your FY issues ... Does this help?’’ 

A second document, also recently discovered by the Committee, 

describes Scanlon’s expected margins on those, and other, 

projects.88 According to that document, entitled ‘‘02 CCS Project 

Break Down,’’ on the $4,850,000 Scanlon sought on ‘‘Project A,’’ he 

projected actual costs to come in at about $850,000—for a projected 

net profit for him and Abramoff of $4,000,000.89 Likewise, on the 

$1,750,000 Scanlon sought on ‘‘Project B,’’ he projected costs at only 

$100,000—for a projected net profit for him and Abramoff of 

$1,650,000.90 The other projects, undertaken for Choctaw and other 

Tribes, are broken out below: 
151 

91 Id. 92 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘2002 GMF 

Breakdowns’’) (undated). 93 Id. 94Plea Agreement, Factual Basis for Plea at para. 20, U.S. v. Jack A. Abramoff (Dist. D.C., 

January 3, 2006) (CR–06–001). 95 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Saginaw Wave Two’’) (undated) 96 Id. 97 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘02 CCS Project Break Downs’’) (undated). 

02 CCS PROJECT BREAK DOWNS 

Project Total Projected expenditures Net 

Delta Downs ............................................................................................................ $3,300,000 $300,000 $3,000,000 

Jena Band ............................................................................................................... 1,505,000 100,000 1,405,000 

[PROJECT A] ............................................................................................................ 4,850,000 850,000 4,000,000 

[PROJECT B] ............................................................................................................ 1,750,000 100,000 1,650,000 

Totals ............................................................................................................. 11,405,000 1,350,000 10,055,000 

Aggregating the costs and profits for all the projects listed above, 

the foregoing describes an expected net profit of about 88 percent.91

Other breakdowns, attached in the appendix of this Report, suggest 

that CCS’ actual net return consistently hovered at about 70–80 

percent. 

In the case of CCS’ representation of the Tigua, the margins 

were equally lucrative. According to a document entitled ‘‘2002 

GMF Breakdowns,’’ Scanlon projected that the ‘‘total campaign 

cost’’ of the Tigua’s project, for which he and his secret partner 

Abramoff received $4.2 million, would be only $400,000.92 This document also suggests that Scanlon originally projected his ‘‘partner 

dollar share’’ here to be $2,400,000.93 In his plea agreement, 

Abramoff ultimately admitted to collecting from Scanlon 

$1,850,000, about 50 percent of CCS’ actual net profit on this 

project.94 Likewise, according to a document referring to ‘‘Saginaw 

Wave Two,’’ Scanlon apparently intended to set aside only $50,000 

for the program—a program for which he apparently obtained 

$500,000 from the Saginaw Chippewa.95 With CCS’ netting 

$450,000 on that project, Abramoff’s cut was $225,000.96 Finally, 

according to another document, entitled ‘‘02 CCS Project Break 

Downs’’ Scanlon projected that his pre-tax share of the $10,055,000 

net from all the projects listed there, would equal $5,027,000.97

What happened above is typical of scores of other transactions 

that the Committee has reviewed, where Scanlon or Abramoff dramatically overcharged the Tribes for grassroots activities; paid 

themselves a percentage of what the Tribes paid at a grossly inflated rate wholly unrelated to the actual cost of services provided; 

and used the remaining fraction to reimburse scores of vendors 

that could help them maintain vis-a-vis the Tribes a continuing appearance of competence. It is almost inconceivable that Scanlon believed that the most ambitious of his programs, like the Louisiana 

Political Program (with which Scanlon claimed that he could ‘‘control both houses and the governor’s mansion’’), could be accomplished successfully for the amount he apparently intended to allocate for their completion. 
152 

98 Capitol Campaign Strategies document production (BB/LC 007285) (July 26, 2002). 99 Id. 100Diehl & Company document production (D00411–512) (undated) (General Ledger, Capitol 

Campaign Strategies). 101 Id. 102 Id. 103 Id. 

b. Transaction #2 (August 2002)—Louisiana Coushatta and Agua Caliente pay CCS a total of $5,000,000 

An example of such a program relates to the payment of almost $5,000,000 by the Louisiana Coushatta and, for an unrelated matter, the Agua Caliente to CCS in August 2002. Weeks before, on 

July 26, 2002, Scanlon asked then-Louisiana Coushatta councilman 

William Worfel for authorization to execute a program that he said 

would ‘‘eliminate the Jena threat ... to ensure that the Jena go 

away for good, and ... permanently eliminate them as a threat to 

the tribe.’’ 98 He described what he would do with this additional 

money as follows: 

We would like to continue the effort against the Jena tribe 

and launch a new effort against the governor as payback. 

On the Jena front we would like to go to each possible 

town where they could conceivably land a casino and destroy that option politically. Simply put—we want them 

out of the state and out of the gaming business all together [sic]. We would like to go from town to town and 

systematically wipe out all possible locations. Our recommendation is to finish them off now ... We believe that 

this campaign will run about 8 weeks, and we would like 

to start immediately while the iron is hot. We will need a 

budget of roughly $2,100,000 to execute this properly.99

On or about August 1, 2002, the Louisiana Coushatta paid CCS $2,100,000, as Scanlon requested.100 And, on or about August 27, 2002, the Agua Caliente paid CCS $2,720,000 (and another 

$935,000 on or about September 17, 2002), for a similarly ambitious project apparently related to the Tribe’s compact renegotiations with the State of California.101

However, CCS’ ledger reflects no expenditures commensurate with Scanlon’s ambitious representations. During an eight-week period, which began and closed with a balance at just under 

$1,000,000, the ledger reflects payments totaling about $40,700 to 

the Weber Company and almost $290,000 to Lunde & Berger for 

‘‘professional campaign services’’ for several tribes; payments totaling about $14,700 to Matthew Stetter for work on an ‘‘environmental impact statement’’ and a total of about $1,270 to Anton Design for ‘‘professional campaign services’’—both of which are probably attributable to the Saginaw Chippewa; payments of $14,000 

and about $1,500 to Democracy Data and Communications for 

‘‘databases’’ and ‘‘telematch services,’’ respectively; a payment of 

$7,803 to Baum Communications for ‘‘Cali ID’’; and a payment of 

$2,890 to Harold Grosh for work by ‘‘subcontractors’’ apparently attributable to the Louisiana Coushatta.102 All of those expenditures, 

which capture vendor expenses that are either $25,000 or more or 

traceable to a grassroots campaigns conducted for any tribe, 

amounted to a mere $370,000.103
153 

104 Id. 105 Id. 106 Capitol Campaign Strategies document production (no Bates number) (undated) (entitled 

‘‘JA Nets–Coush Jena Aug’’). 107 Id. 108 Capitol Campaign Strategies document production (no Bates number) (undated) (entitled 

‘‘AC Wave One’’). Scanlon also set aside another $38,000 as a ‘‘plane expense.’’ See Id. 109 Id. 

During this period, the ledger also reflects a few incidental payments that probably provided little value to the Louisiana 

Coushatta or the Agua Caliente, for example, a payment of 

$250,000 to the Republican Governors Association; a payment of 

$100,000 to an individual named Michael Chapman, likely for referring the Agua Caliente to Abramoff and Scanlon; a $60,000 donation to the ‘‘Scanlon Foundation for Kids’’ for ‘‘backpacks’’; and 

a number of payments apparently made to contractors for work on 

some of Scanlon’s properties.104

Other than the foregoing, the ledger reflects no vendor expenses 

that are either $25,000 or more or traceable to grassroots campaigns conducted for any Tribe. However, with a total of $4,820,000 

having been paid by the Louisiana Coushatta and the Agua 

Caliente near the beginning of this period, the ledger does show 

Scanlon’s paying Abramoff a ‘‘referral expense’’ of $2,266,250 on or 

about September 16, 2002, and Scanlon’s paying himself $2,200,000 

on or about October 10, 2002.105

Newly discovered evidence suggests what Scanlon intended to do 

with these Tribes’ money from the start. According to a recently 

discovered financial record, Scanlon apparently intended to set 

aside no more than $350,000 for the Jena-related program—a program for which he sought and obtained $2,100,000 from the Louisiana Coushatta.106 According to that same document, Scanlon 

projected a net $1,732,000 on that project and estimated Abramoff’s 

cut at $866,250.107 Similarly, according to another document referring to ‘‘AC Wave One,’’ Scanlon apparently intended to set aside 

only $400,000 for that program—a program for which he sought 

and received $2,700,000 from the Agua Caliente Tribe.108 With 

CCS’ projecting to net $2,235,000 on that project, he estimated 

Abramoff’s cut here at $1,117,500.109 It is unlikely that Scanlon believed that he could ‘‘finish [the Jena] off now’’ for only $350,000. 

The foregoing reflects that the Louisiana Coushatta received little 

of the intended benefit for the $2,100,000 it paid CCS, and that the 

$2,700,000 that Scanlon charged the Agua Caliente for ‘‘AC Wave 

One’’ was wholly unrelated to his actual costs. 

c. Transaction #3 (October 2001–January 2002)—Louisiana 

Coushatta pays CCS $2,170,000 

By August 27, 2001, Scanlon had successfully helped the Louisiana Coushatta with its compact renegotiations with the State of 

Louisiana. In furtherance of his new partnership with Abramoff, 

which the two kept secret from the Louisiana Coushatta, Scanlon 

was now prepared to proceed with a much broader scope of work. 

In that context, Scanlon put forward a ‘‘comprehensive political 

program,’’ which he described as ‘‘much larger than the one we de-
154 

110Memorandum from Michael Scanlon, Capitol Campaign Strategies, to Kathryn Van Hoof, Coushatta Tribe of Louisiana, ‘‘Coushatta Political Program’’ (August 27, 2001) (carbon-copying 

Abramoff). 111 Id. 112 Id. 113 Id. 114See generally id.; Capitol Campaign Strategies document production (BB/LC 017923) (Octo- ber 23, 2001) (carbon-copying Abramoff). 115 Email from Jack Abramoff, Greenberg Traurig, to Gail Halpern, May & Barnhard (GTG– E000011965) (August 28, 2001). Intent on funneling his share of the Louisiana Coushatta’s 

money to his restaurant without it being taxed as personal income, Abramoff asked Halpern, 

‘‘I was wondering if we could structure this transaction the following way: Livsar invoices CCS 

for services in the amount they are transferring. The services can be of any nature ... CCS is 

a political, lobbying, campaign company, certainly one which uses fine dining etc. Livsar would 

take that money as income and spend it in the course of business, on the restaurant. If at the 

end of the year Livsar has expended that money, is there a tax event?’’ Id. See also Email from 

Jack Abramoff, Greenberg Traurig, to Gail Halpern, May & Barnhard (GTG–E000011965) (August 28, 2001) (Abramoff describing Livsar Enterprises). 116 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign Strategies (GTG–E0000113995) (September 10, 2001). 117 Id. 118 Id. 

veloped for the compact fight[, but] includes many of the same tactics and follows the same development process.’’ 110

In an August 27, 2001, memorandum to Kathryn Van Hoof, outside counsel for the Louisiana Coushatta, which Scanlon carboncopied to his new partner Abramoff, Scanlon described this program as designed to ‘‘make sure that under no circumstances 

would the tribe find itself behind the political eight ball ever again’’ 

and ‘‘make [the Tribe] a politician’s best friend—or worse [sic] political nightmare.’’ 111 Scanlon continued, ‘‘[This strategy is] built to 

put you in a position to impose your political will on virtually any 

issue or candidate, and not just in SW Louisiana, but statewide, 

and across stateliness [sic] as well.’’ 112 Scanlon offered, ‘‘In my 

opinion if you execute this program, you will be in position to 

achieve all of your political objectives.’’ 113 Accordingly, Scanlon laid 

out his Louisiana and Texas ‘‘political program.’’ 114

What the Tribe did not know at the time was that much of the 

money that Scanlon proposed that it pay for this political program 

would go directly to Abramoff. On the day after Scanlon apparently 

sent the foregoing memo to Van Hoof, Abramoff wrote his tax advisor about where he intended his share of the Louisiana Coushatta’s 

money to go: ‘‘A company called Capital Campaign Services [sic] 

has several hundred thousand which they are going to put into the 

restaurant for me (they owe me money, though there is no written 

arrangement—they have already transferred the money to [Livsar 

Enterprises, which owned one of Abramoff’s restaurants] so the 

trust issue is not a problem).’’ 115

On September 10, 2001, having been assured that money from 

the Tribe was on the way, Abramoff asked Scanlon, ‘‘Can you let 

me know how much more (than the current +/¥ 660K) we would 

each score should Coushatta come through for this phase, and 

Choctaw continue to make the transfers. I need to assess where I 

am at for the school’s sake.’’ 116

Scanlon replied, ‘‘Coushatta is an absolute cake walk. Your cut 

on the project as proposed is at least 800k.’’ 117

All in all, Scanlon reported that Abramoff would get at that time 

‘‘1.5. mil on top of the 660. For a toal [sic] of 2.1.’’ 118
155 

119 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E0000113847) (September 10, 2001) (emphasis in original). 120 Id. 121 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg Traurig (GTG–E0000113927) (October 5, 2001). 122 Id. 123 Id. 124 Id. 125See Memorandum from Michael Scanlon, Capitol Campaign Strategies, to Kathryn Van Hoof, Coushatta Tribe of Louisiana, ‘‘Louisiana Political Budget Outline’’ (BB/LC 017923) (October 23, 2001) (carbon-copying Abramoff). 126See id. 127Diehl & Company document production (D00411–512) (undated) (General Ledger, Capitol Campaign Strategies). In an apparent scheme to fraudulently induce the Tribe to ‘‘donate’’ to 

Abramoff’s private charity, the Capital Athletic Foundation (‘‘CAF’’), Scanlon directed the Tribe 

to send the remaining $1,000,000 for the Program to Greenberg Traurig; and, at Abramoff’s direction, the firm sent this $1,000,000 to the CAF, on November 13, 2001. For a full explication 

of this transaction, refer infra to Part 2, Chapter 3, ‘‘Capital Athletic Foundation,’’ Section D, 

‘‘Abramoff and Scanlon Misappropriate Tribal Funds for CAF Seed Money in 2001.’’ 128Diehl & Company document production (D00411–512) (undated) (General Ledger, Capitol 

Campaign Strategies). 129 Id. Weeks before, on October 8, 2001, Reed had agreed to help Scanlon and Abramoff 

‘‘block the Alabama Coushatta tribe [sic] from securing a gaming facility by proactively pushing 

a political or legislative vehicle making approval of Indian gaming in Texas next to impossible’’, 

for $100,000. Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, 

Greenberg Traurig (GTG–E000023050–51) (October 5, 2001). On October 5, 2001, Scanlon explained to Abramoff, ‘‘We have drafts of the language, But [sic] we are still batting around the 

final documents. What we need now is for the Gov [sic], Lt Gov [sic] and AG to issue the vehicle 

and publicly support it. Here are our ideas, and if Ralph can slam it home it would be great.’’ 

Continued 

Abramoff heaped praise on his partner, ‘‘How can I say this strongly enough: YOU IZ DA MAN.’’ 119

Not content with the $2.1 million and using the phrase the two had coined to describe their secret partnership, Scanlon exhorted, 

‘‘Let’s grow that 2.1 to 5!!! We need the true give me five!’’ 120

On October 6, 2001, Scanlon picked up that email stream to revisit the issue with Abramoff: ‘‘800k was your cut of the combined 

[Louisiana] and [Texas] projects. But they did not go for the [Louisiana] project so your cut shrunk to 400K from texas [sic] 

alone.’’ 121 However, Scanlon assured Abramoff: ‘‘But we came in 

way under budget bumping your total on the texas [sic] project up 

to 600k.’’ 122

He continued, ‘‘If they go for the [Louisiana] project, tack another 400 onto your end ... Long story short, you made an additional 

200k on the texas [sic] project.’’ 123

Abramoff responded, ‘‘We have to get that [Louisiana] project moving. Let’s discuss how to make that happen.’’ 124

Ultimately, on or about October 23, 2001, the Tribal Council ap- parently approved a modified version of the political program that 

Scanlon proposed to fight a couple of Louisiana gaming expansion 

initiatives. Cumulatively, it was called the ‘‘Battleground Program.’’ 125 In a memorandum outlining the program’s costs, Scanlon wrote, ‘‘[W]e have already begun our operations on all fronts. As we 

expressed to the council two battles, plus implementing the already 

proposed program would be costly.’’ 126 The total cost, $3,170,000. 

According to CCS’ accounting ledger, on October 31, 2001, the Louisiana Coushatta ultimately paid CCS $2,170,000 in one lump 

sum.127 But, how did CCS spend this money? CCS’ own records in- dicate that a small part was paid to outside vendors for actual 

work.128 For example, on or about November 8, 2001, CCS paid 

Capitol Media, a company owned or controlled by Ralph Reed, 

$100,000 for work on the Texas component of the program.129
156 

Id. After Abramoff referred Reed to Scanlon to ‘‘get it moving,’’ Abramoff reached out to Scanlon, 

apparently elated at the prospect of minimizing costs, ‘‘Call Ralph and get him moving. He’ll 

do it for the $100K. we’z in the money!!!’’ Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000023050) (October 8, 2001). Later that 

month, Scanlon wrote Abramoff, ‘‘Once [the Tribe] pay[s] we let Ralph loose, and bring Texas 

home.’’ Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg 

Traurig, L.L.P (GTG–E000012181) (October 15, 2001). Abramoff responded, ‘‘U da[ ] man!’’ 

Email from Jack Abramoff, Greenberg Traurig and Michael Scanlon, Capitol Campaign Strategies (GTG–E000012181) (October 15, 2001). 130Diehl & Company document production (D00411–512) (undated) (General Ledger, Capitol Campaign Strategies). 131 Brody Mullins, Breakup of Ex-Aides Shook Group Tied to Abramoff—The Prosecutors Move 

In; Ms. Miller’s Tearful Apology, Wall Street Journal, March 31, 2006 at A1. 132The entries in the following tables, and similar tables throughout this Report, are taken 

from CCS’ accounting ledger and cross-referenced with other information in the possession of 

the Committee for verification. To determine whether the Tribes received fair value for what 

they paid CCS, wholly incidental expenses were excluded from the source ledger, and presented 

here. Of all vendor transactions reflected in the source ledger, only those greater than or equal 

to $25,000 or traceable to any Tribe have been included here and other similar spreadsheets 

presented in this Report. 

While Scanlon was paying vendors only a modest fraction of 

what the Tribe paid CCS, it seems that he put much of the balance 

to personal use. On November 2, 2001, he took $1.4 million as a 

shareholder draw.130 That month, Scanlon reportedly bought a $1.6 

million beach house in Rehoboth Beach, which he completely renovated.131

Later entries in the CCS ledger reflect very significant draws 

going to Scanlon’s wedding, which never occurred. Ultimately, after 

additional payments came in from the Choctaw, Scanlon paid 

Abramoff about $2,000,000. These payments are set forth below: 132

CAPITOL CAMPAIGN STRATEGIES ACCOUNT SNAPSHOT 

Date Description To/from Amount 

10/30/2001 ...... Balance ...................................................... .................................................................... $83,249.00 

10/31/2001 ...... Consulting Fees ......................................... Coushatta ................................................... 700,000.00 

10/31/2001 ...... Consulting Fees ......................................... Coushatta ................................................... 2,170,000.00 

10/31/2001 ...... Balance ...................................................... .................................................................... 2,953,249.04 

11/2/2001 ........ Professional Campaign; Alabama; 1278 ... Lunde & Berger .......................................... (25,000.00) 

11/2/2001 ........ Professional Campaign; 1279 ................... Red Sea ...................................................... (11,236.02) 

11/2/2001 ........ Professional Campaign; 1280 ................... Basswood Research ................................... (11,270.00) 

11/2/2001 ........ Shareholder Draw; 1289 ............................ Michael Scanlon ......................................... (1,400,000.00) 

11/8/2001 ........ Professional Campaign; Coushatta TX 

Program; 1301.

Capitol Media ............................................. (100,000.00) 

11/8/2001 ........ Professional Campaign; 1304 ................... Capitol Media ............................................. (350,000.00) 

11/9/2001 ........ Shareholder Draw/Wedding ........................ Michael Scanlon ......................................... (50,000.00) 

11/15/2001 ...... Consulting Fees ......................................... Choctaw ..................................................... 2,350,000.00 

11/15/2001 ...... Shareholder Draw/Wedding ........................ Michael Scanlon ......................................... (1,563,740.39) 

11/26/2001 ...... Shareholder Draw/Bama Race ................... Michael Scanlon ......................................... (75,000.00) 

11/26/2001 ...... Professional Campaign/Texas .................... Lunde & Berger .......................................... (13,000.00) 

11/26/2001 ...... Professional Campaign/Alabama ............... Lunde & Berger .......................................... (130,000.00) 

11/27/2001 ...... Money Market ............................................. .................................................................... (2,923,485.08) 

11/27/2001 ...... Shareholder Draw/Wedding ........................ Michael Scanlon ......................................... (5,000.00) 

11/27/2001 ...... Shareholder Draw; Michael Wedding ......... Michael Scanlon ......................................... (60,000.00) 

11/27/2001 ...... Balance ...................................................... .................................................................... 174,560.77 

11/30/2001 ...... Balance ...................................................... .................................................................... 68,995.57 

12/12/2001 ...... Shareholder Draw; Preferred Account ........ Legg Mason Wood ...................................... (50,000.00) 

12/19/2001 ...... Referral Expense; 1396 .............................. Jack Abramoff ............................................ (300,000.00) 

12/31/2001 ...... Referral Expense; 1398 .............................. Jack Abramoff ............................................ (1,718,125.00) 

12/31/2001 ...... Professional Campaign .............................. Capitol Media ............................................. (250,000.00) 

12/31/2001 ...... Balance ...................................................... .................................................................... (2,392,137.00) 

1/2/2002 .......... Deposit ....................................................... Money Market ............................................. 2,754,942.00 

1/2/2002 .......... Balance ...................................................... .................................................................... 362,804.86 
157 

133 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg 

Traurig (GTG–E000012278) (November 7, 2001). 134 Capitol Campaign Strategies document production (BB/LC 015391) (January 6, 2002). 135 Capitol Campaign Strategies document production (BB/LC 015410) (January 27, 2002). 136 Id. 137 Id. 138 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000075999) (January 28, 2002). 

In a November 6, 2001, email, Scanlon provides Abramoff with 

‘‘a breakdown (Political Nets) of where you are currently -and [sic] 

[a] distribution [s]chedule for 2001 that shows what you made or 

directed to other parties—Not bad!!!!!!’’ 133

With only a fraction of what the Tribe paid CCS going to the intended effort, it appears that the Louisiana Coushatta received little of the intended benefit for the money it paid CCS during this 

period. Unfortunately, this would not be the only time the Tribe 

would be short-changed by Abramoff and Scanlon. 

d. Transaction #4 (January–April 2002)—Several Tribes Pay 

CCS Over $22,000,000 

As described in the Chapter of this Report addressing Abramoff 

and Scanlon’s representation of the Tigua, late in 2001, the State 

of Texas filed suit seeking to shut down the casino of the Alabama 

Coushatta Tribe. Operating near Houston, in Livingston, Texas, 

that casino ostensibly presented competition to the Louisiana 

Coushatta’s facility, across the state line. As reflected above, Scanlon used only a fraction of the Louisiana Coushatta’s payments to 

CCS late in the year to fund Ralph Reed’s anti-gaming grassroots 

activities in Texas, which Reed ran through his firm Capitol Media. 

However, with the casino’s closure imminent, Scanlon was quick to 

take credit. On January 6, 2002, he wrote Louisiana Coushatta 

Tribal Councilman William Worfel, carbon-copying Abramoff, ‘‘Victory is ours. As a result of our political pressure, the Texas Attorney General filed a lawsuit in federal court on Friday to shut down 

the Alabama Coushatta’s ‘entertainment center’ in Livingston.’’ 134

On January 27, 2002, Scanlon wrote Worfel again, ‘‘It looks as 

though the Jena [Jena Band of Choctaw Indians] are attempting 

again to put a facility in Mississippi at the same time they are continuing their efforts in Louisiana.’’ 135

He continued, ‘‘On that note—I would like to speak with you tomorrow about our conversation on Friday regarding Patrick Martin 

and the Jena [Band of Choctaw Indians]. I think it’s imperative 

that we make a large statement with our efforts given what has 

unfolded.’’ 136

Accordingly, he asked for ‘‘a larger budget to deal with the Jena 

and make our muscle felt ... a significant increase (an additional 

1.2 mil to make our point).’’ 137

On the next day, Abramoff forwarded an article to Scanlon, 

which had been provided to him by Reed, about the Tigua’s casino 

in Texas, and wrote, ‘‘Get this to William [Worfel]. War.’’ 138

According to CCS’ accounting records, this began a particularly 

active payment period, during which the Louisiana Coushatta in 

particular made a series of very substantial payments to CCS’ operating account. In January 2002, which began this period, the 

starting balance in this account was about $500,000. By April 2002, 
158 

139 According to CCS’s accounting ledger, an unspecified client(s) paid CCS $3,102,750 during this period. Diehl & Company document production (D00411–512) (undated) (General Ledger, 

Capitol Campaign Strategies). This figure is not included in this tally. 140Diehl & Company document production (D00411–512) (undated) (General Ledger, Capitol 

Campaign Strategies). 141Diehl & Company document production (D00411–512) (undated) (General Ledger, Capitol 

Campaign Strategies). 142The entries in the following tables, and similar tables throughout this Report, are taken 

from CCS’ accounting ledger and cross-referenced with other information in the possession of 

the Committee for verification. To determine whether the Tribes received fair value for what 

they paid CCS, wholly incidental expenses were excluded from the source ledger, and presented 

here. Of all vendor transactions reflected in the source ledger, only those greater than or equal 

to $25,000 or traceable to any Tribe have been included here and other similar spreadsheets 

presented in this Report. 

after considerable payment activity, the balance went back down to 

about $500,000. In the interim, the Louisiana Coushatta paid CCS 

$11,510,000. Additionally, substantial payments were made by several other tribes: Saginaw Chippewa, $3,069,831; Choctaw, 

$1,605,000; Tigua Tribe of El Paso, $2,122,680; and the Sandia 

Pueblo, $2,750,000. So, during this period, all of these Tribes paid 

CCS a total of $21,057,561.139

What did Scanlon do with these Tribes’ money during this period? According to information obtained by the Committee, Scanlon 

paid only $826,452.79 to vendors for expenses greater than or equal 

to $25,000 or discernable as funding for work done for any Tribe 

and about $155,000 to Abramoff lobbying associates Jon van Horne 

and Kevin Ring.140 By contrast, Scanlon withdrew $15,078,108.94 

as ‘‘shareholder draws’’ and paid Abramoff, or his corporate alter 

ego Kaygold, $8,998,947.60 as ‘‘referral expenses.’’ 141 The relevant 

portion of CCS’ ledger, which reflects this activity, is set out 

below.142

CAPITOL CAMPAIGN STRATEGIES ACCOUNT SNAPSHOT 

Date Description To/from Amount 

1/2/2002 .......... Balance ...................................................... .................................................................... $362,804.86 

1/7/2002 .......... Balance ...................................................... .................................................................... 505,356.94 

1/18/2002 ........ Consulting Fees ......................................... Coushatta ................................................... 1,505,000.00 

1/18/2002 ........ Consulting Fees ......................................... Coushatta ................................................... 1,500,000.00 

1/18/2002 ........ Consulting Fees ......................................... Coushatta ................................................... 1,000,000.00 

1/24/2002 ........ Professional Campaign; LA; 1452 ............. Lunde & Berger .......................................... (25,000.00) 

1/30/2002 ........ Shareholder Draw ....................................... .................................................................... (1,000,000.00) 

1/30/2002 ........ Shareholder Draw ....................................... .................................................................... (950,000.00) 

2/1/2002 .......... Balance ...................................................... .................................................................... 3,207,343.96 

2/7/2002 .......... Legal/Professional; Legal Work; 1476 ....... Jon Van Horne ............................................ (20,000.00) 

2/12/2002 ........ Professional Campaign; LA–Jena; 1489 .... Lunde & Berger .......................................... (30,000.00) 

2/14/2002 ........ Professional Campaign .............................. Alexander Strategies .................................. (120,000.00) 

2/19/2002 ........ Consulting Fees ......................................... Saginaw Chippewa .................................... 1,869,831.00 

2/19/2002 ........ Professional Campaign; 1492 ................... Capitol Media ............................................. (51,679.00) 

2/20/2002 ........ Professional Campaign; Final Payment; 

1494.

Glover Associates ....................................... (34,291.16) 

2/21/2002 ........ Professional Campaign; LA; 1495 ............. Lunde & Berger .......................................... (75,000.00) 

2/22/2002 ........ Transfer ...................................................... Money Market ............................................. (2,000,000.00) 

2/22/2002 ........ Referral Expense; 1496 .............................. Kaygold ....................................................... (2,779,925.60) 

2/22/2002 ........ Balance ...................................................... .................................................................... 1,075,164.69 

2/25/2002 ........ Professional Campaign; Radio Buy; LA; 

1498.

Capitol Media ............................................. (60,000.00) 

2/25/2002 ........ Professional Campaign; LA Project; 1499 Capitol Media ............................................. (100,000.00) 

2/28/2002 ........ Consulting Fees ......................................... Choctaw ..................................................... 1,605,000.00 

2/28/2002 ........ Shareholder Draw ....................................... .................................................................... (50,000.00) 

3/1/2002 .......... Balance ...................................................... .................................................................... 4,343,157.00 

3/1/2002 .......... Professional Campaign; MS Bonus; 1526 Lunde & Berger .......................................... (50,000.00) 

3/4/2002 .......... Consulting Fees; Deposit ........................... .................................................................... 1,002,750.00 
159 

143 Email between Michael Scanlon, Capitol Campaign Strategies, and Jack Abramoff, Greenberg Traurig (GTG–E000010889) (January 6, 2002). 144 Id. 145Diehl & Company document production (D00411–512) (undated) (General Ledger, Capitol 

Campaign Strategies). 146 Id. 147 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000011535) (March 8, 2002). 148 Brody Mullins, Breakup of Ex-Aides Shook Group Tied to Abramoff—The Prosecutors Move 

In; Ms. Miller’s Tearful Apology, Wall Street Journal, March 31, 2006 at A1. 149 Id. 

CAPITOL CAMPAIGN STRATEGIES ACCOUNT SNAPSHOT—Continued 

Date Description To/from Amount 

3/5/2002 .......... Deposit ....................................................... Money Market ............................................. 2,000,000.00 

3/5/2002 .......... Consulting Fees; Deposit ........................... .................................................................... 2,100,000.00 

3/5/2002 .......... Shareholder Draw ....................................... Michael Scanlon ......................................... (4,753,108.94) 

3/14/2002 ........ Shareholder Draw ....................................... .................................................................... (150,000.00) 

3/15/2002 ........ Consulting Fees ......................................... Coushatta ................................................... 3,405,000.00 

3/15/2002 ........ Consulting Fees ......................................... Sandia Pueblo ............................................ 1,875,000.00 

3/21/2002 ........ Referral Expense; 1557 .............................. Jack Abramoff ............................................ (4,080,997.00) 

3/21/2002 ........ Referral Expense; 1558 .............................. Kevin Ring .................................................. (67,500.00) 

3/22/2002 ........ Shareholder Draw ....................................... Michael Scanlon ......................................... (1,000,000.00) 

3/25/2002 ........ Shareholder Draw ....................................... Michael Scanlon ......................................... (300,000.00) 

3/25/2002 ........ Shareholder Draw ....................................... Michael Scanlon ......................................... (25,000.00) 

3/27/2002 ........ Professional Campaign; Media .................. Red Sea ...................................................... (33,600.00) 

3/28/2002 ........ Professional Campaign; Media .................. Red Sea ...................................................... (116,680.00) 

4/1/2002 .......... Consulting Fees ......................................... Saginaw Chippewa .................................... 1,200,000.00 

4/1/2002 .......... Balance ...................................................... .................................................................... 5,730,488.93 

4/2/2002 .......... Shareholder Draw; 1573 ............................ Michael Scanlon ......................................... (4,350,000.00) 

4/2/2002 .......... Shareholder Draw; 1574 ............................ Michael Scanlon ......................................... (500,000.00) 

4/4/2002 .......... Consulting Fees ......................................... Tigua .......................................................... 1,293,180.00 

4/4/2002 .......... Consulting Fees ......................................... Coushatta ................................................... 2,100,000.00 

4/8/2002 .......... Referral Expense; 1580 .............................. Kaygold ....................................................... (2,138,025.00) 

4/10/2002 ........ Consulting Fees ......................................... Sandia Pueblo ............................................ 875,000.00 

4/10/2002 ........ Professional Campaign; NM Poll 2; 1586 Frabrizio and McLaughlin .......................... (10,000.00) 

4/11/2002 ........ Professional Campaign; Prof Services; 

1593.

Weber Company ......................................... (41,634.96) 

4/11/2002 ........ Professional Campaign; LA Survey; 1597 Basswood Research ................................... (28,567.67) 

4/15/2002 ........ Professional Campaign; Tigua; 1615 ........ Lunde & Berger .......................................... (50,000.00) 

4/15/2002 ........ Referral Expense; 1616 .............................. Kevin Ring .................................................. (67,500.00) 

4/16/2002 ........ Shareholder Draw ....................................... Michael Scanlon ......................................... (2,000,000.00) 

4/16/2002 ........ Balance ...................................................... .................................................................... 471,009.87 

Near the beginning of the period captured by this snapshot, after 

the State of Texas filed suit to shut down the Alabama Coushatta’s 

casino, Scanlon observed, ‘‘Yeah baby! The timing couldn’t be better!’’ 143

Ultimately, Abramoff responded, ‘‘Wez [sic] gonna be rich!’’ 144

And, about a week-and-a-half later, the Louisiana Coushatta, on 

whose behalf Abramoff and Scanlon opposed the Alabama 

Coushatta, paid CCS more than $4,000,000.145

A few weeks later, on March 8, 2002, CCS received an additional 

$1,869,831 from the Saginaw Chippewa and $1,605,000 from the 

Choctaw.146 Writing Scanlon, Abramoff celebrated, ‘‘We’re gonna be 

rich. What am I saying?! We ARE rich!!!’’ 147

What did Scanlon do with his share? In March 2002, Scanlon reportedly paid $4.7 million in cash for a house for himself and thenfiancee, Emily Miller.148 This beachfront mansion reportedly had a 

weight room, sauna and a three-bedroom guest house.149 Scanlon 

mounted lights on the deck so he could hold parties on the beach 
160 

150 Id. 151 Id. 152 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000011588) (March 12, 2002). 153 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000252622–23) (April 8, 2002). 154 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000026246) (March 13, 2002). 155 Id. 156 Id. 

at night, his surfing friends have reportedly said.150 He also bought 

vacation homes on the Caribbean island of St. Barts, including one 

villa he reportedly rented out for $50,000 a week.151

But that was not enough. In reacting to a proposal by Scanlon 

to fight attempts by the Jena Band of Choctaw Indians to open a 

casino in Louisiana, on March 12, 2002, Abramoff admonished his 

partner, ‘‘It’s great, but don’t give the option of shaving costs. Of 

course they should do them all at once, and there are no savings!!! 

Otherwise, we’ll sacrifice $2M that they would otherwise gladly 

pay. OK?’’ 152

Referring to the Louisiana Coushatta, on April 8, 2002, Abramoff 

observed, ‘‘They are ripe for more pickings. We have to figure out 

how.’’ 153

In an email, dated March 13, 2002, entitled ‘‘those f—ing 

SagChips,’’ Abramoff and Scanlon discussed the Saginaw Chippewa’s participation of an Abramoff venture to have them help underwrite the cost of maintaining sky boxes at premium sporting 

venues in the DC area: ‘‘[then-Saginaw Chippewa Sub-Chief] Dave 

Otto just told me that they are not going to do the sports suites. 

He said they are under fire and are worried that they are spending 

too much money. I really am worried that they are not seeing results from us up there, so they are starting to rethink doing stuff 

with us. can [sic] you PLEASE get someone up there asap?’’ 154

Scanlon responded, ‘‘Jack—the fact that they are not doing sports 

suites has nothing to do with them not seeing [sic] results on my 

end—they are just friggin cheap—and losers—I very seriously 

doubt we will ever see another penny from them—and there was 

no chance that they were ever going to do the sports suites. We 

really have to watch these guys.’’ 155

Abramoff replied: 

Let’s chat about these guys. I agree about the sports 

suites, but we need to energize this. we [sic] spent the time 

and won the [Tribal Council] election, and now have a 

great contract with them. they [sic] are not happy with the 

service they are getting. We need to step up and save this 

(a lot less work to turn this into a winner than to find another rich tribe and bring them to this point). they are apparently unhappy that you are not there. I am seeing 

[Saginaw Chippewa legislative director] Chris Petras tomorrow and will get a temperature and we’ll find a way 

to fix it. we [sic] need a beautiful girl to send up there to 

do our work. I am really not kidding. This deal is a big 

part of our financial life and we cannot let it slip away.156

On June 18, 2002, Scanlon described an agreement to Abramoff 

with the ‘‘Saginaw’s lawyers’’ whereby the tribe will ‘‘pay 1.9 up 
161 

157 Email between Michael Scanlon, Capitol Campaign Strategies, and Jack Abramoff, Green- berg Traurig (GTG–E000011737) (June 18, 2002). 158 Id. 159 Email between Michael Scanlon, Capitol Campaign Strategies, and Jack Abramoff, Greenberg Traurig (GTG–E000057329) (June 20, 2002). 160 Id. 161 Id. 162 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg Traurig (GTG–E000011746) (July 9, 2002). 163Diehl & Company document production (D00411–512) (undated) (General Ledger, Capitol Campaign Strategies). 164 Capitol Campaign Strategies document production (BB/LC 007288) (October 9, 2002) (car- bon-copying Abramoff). 165 Id. (emphasis added). 

front then 500k and 500k ... We should have the cash by the end 

of the week.’’ 157

In response, Abramoff instructed Scanlon to direct his CCS income to his purported charity, the Capital Athletic Foundation 

(‘‘CAF’’), ‘‘Great. can [sic] you get to [REDACTED] and get that $ 

for CAF? I really need it. also, [sic] might need you to direct one 

of the $500K’s coming to CAF. can [sic] you do that?’’ 158

On the next day, Scanlon updated Abramoff, ‘‘Hey—good day all 

around—we wrapped up the Sag Chip crap—We hit Coush—I 

think for 3 mil—and we are working gon [sic] Acaliente [sic] presentation—should be tight.’’ 159

Abramoff answered, ‘‘Thanks so much! You are a great partner. 

What I love about our partnership is that, when one of us is down, 

the other is there. We’re gonna make $ for years together!’’ 160

Scanlon replied, ‘‘Amen! You got it boss—we have many years 

ahead!’’ 161

On or about July 9, 2002, the two discussed the payment of 

$1,900,000 from the Saginaw Chippewa, Scanlon assuring 

Abramoff, ‘‘800 for you[,] 800 for me[,] 250 for the effort the other 

50 went to the plane and misc expenses. We both have an additional 500 coming when they pay the next phasesm [sic].’’ 162 Indeed, on July 12, 2002, after that payment arrived, CCS made 

three payments to Kaygold, of $800,000; $20,000; and $44,000.163

e. Transaction #5 (October 16, 2002)—Louisiana Coushatta 

Pays $950,000 and the Agua Caliente Pays $1,745,000 to 

CCS 

In its brazenness, what apparently happened with a payment of 

$950,000 by the Louisiana Coushatta, and $1,745,000 by the Agua 

Caliente, to CCS is notable. On October 9, 2002, carbon-copying 

Abramoff, Scanlon wrote Worfel, ‘‘[R]ecently the [Jena] have received an enormous amount of funding to back there [sic] political/ 

on the ground [sic] operations and in addition [sic] have beefed up 

their lobbying team in D.C. as well.’’ 164

Scanlon continued, ‘‘Given these facts I strongly believe that we 

need more budget authority to achieve our objectives. I would like 

an addition [sic] $950,000.00 to beef up our field team for the petition drives, add more staff to our opposition research team, and to 

increase the level of letters and call [sic] we generate to Secretary 

Norton over the next few weeks.’’ 165

Scanlon underscored, ‘‘In all of our time working together we 

have never come back to you with a request for additional budg-
162 

166 Id. 167 Id. 168Diehl & Company document production (D00411–512) (undated) (General Ledger, Capitol 

Campaign Strategies). 169See id. 170 Id. 171 Id. 172 Id. 173 Id. 174 Id. 175 Id. 176 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign Strategies (GTG–E000056775) (December 17, 2002). 177 Id. 

eting, so please know that we would not being [sic] making this request unless it were absolutely necessary.’’ 166

Scanlon concluded, ‘‘We believe that we will have the campaign 

wrapped up within three weeks, and these additional funds will 

contribute greatly to our success.’’ 167

What happened subsequently is best reflected in CCS’ general 

ledger. According to this document, on or about October 15, 2002, 

the starting balance in CCS’ operating account was about 

$2,000,000.168 About a day later, the Louisiana Coushatta paid 

CCS $950,000, as Scanlon requested.169 And, at about that same 

time, the Agua Caliente made another payment of $1,745,000.170

The original $2,000,000 balance was restored in that account on or 

about October 25, 2002.171

So, in the interim, what happened to the Tribes’ money? Accounting records show that very little of the Tribe’s money was used for 

purposes intended by the Tribe. Between October 15th and October 

25th, 2002, CCS’ general ledger fails to reflect any payments for 

‘‘beef[ing] up [a] field team for ... petition drives’’ or the ‘‘add[ition 

of] more staff to [an] opposition research team.’’ Quite the contrary, 

during this period, the general ledger indicates, CCS made only one 

payment to any vendor for work traceable to any Tribe—$50,000 to 

Ayers, McHenry & Associates, Inc. for ‘‘professional campaign services.’’ 172 It also reflects a payment of $250,000 to the Republican 

Governors Association and several payments on credit card bills 

and charter airfare.173 Otherwise, the only notable activity that is 

reflected on the ledger during this period are three ‘‘shareholder 

draws’’ taken by Scanlon, totaling $2,200,000.174 After Scanlon 

made those withdrawals, he allowed the account to be drawn down 

until early-December 2002—at which point the Choctaw made several payments.175 In other words, apparently Scanlon never replenished the account with the Louisiana Coushatta’s and the Agua 

Caliente’s money, after he took it out in the first instance. The foregoing allows the Committee to find that those Tribes never received 

the intended benefit for the money that they paid CCS on or about 

October 15, 2002. 

It is unclear whether Scanlon told Abramoff about these payments when they first arrived. On December 17, 2002, Abramoff 

asked Scanlon, ‘‘can you get me the check for the money which 

came from the Agua asap? I’m actually in a bad cash position.’’ 176

Scanlon answered, ‘‘No money in yet—still waiting on the wire— 

ill [sic] send it over as sson [sic] as it comes in—Its cool—all approved and everything—just not been executed yet.’’ 177
163 

178 Id. 179 Id. 180 Capitol Campaign Strategies document production (no Bates number) (undated) (entitled 

‘‘Scanlon NW 02’’). 181 Id. 182 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000252878) (January 21, 2003). 183 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000252882) (February 17, 2003). 184 Id. 185 Id. 186 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg 

Traurig (GTG–E000027864) (February 18, 2003). 187Diehl & Company document production (D00411–512) (undated) (General Ledger, Capitol 

Campaign Strategies). 188 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000027864) (February 18, 2003). 

Abramoff replied, ‘‘Other than the AC, what [sic] next on the 

money train?’’ 178

Scanlon answered, ‘‘The next big money we have coming our way 

is Coushatta, and that will be in early January—the exact amounts 

I’m still hammering out.’’ 179

A recently discovered financial record suggests what Scanlon did 

with the money that he absconded from the Tribes in 2002. This 

document, which apparently sets forth Scanlon’s net worth for the 

year ending 2002, reflects that for his own benefit Scanlon put 

most of the money he received from the Tribes into real estate and 

investment accounts.180 According to this document, entitled ‘‘Scanlon NW 02,’’ those investments were valued at about $5,460,000, 

and $7,520,000 in expected retainers, returns on investments, and 

net returns on outstanding projects ‘‘on board.’’ 181

f. Transaction #6 (January–March 2003)—Louisiana 

Coushatta Pays CCS $5,000,000 

The Louisiana Coushatta’s payment to CCS of $5,000,000 on or 

about February 12, 2003, also reflects Abramoff and Scanlon’s 

‘‘gimme five’’ scheme. In an email, dated January 21, 2003, and entitled ‘‘Coushatta,’’ Abramoff wrote Scanlon, ‘‘Give me a call asap. 

I have some thoughts in this which I need to share. It means more 

$$$$ for us!’’ 182 Exactly what Abramoff had in mind here is unclear. 

On February 17, 2003, Abramoff reached out to Scanlon ‘‘when 

are we getting Coushatta $?’’ 183

Scanlon responded, ‘‘Was supposed to be in Friday—but did not 

come through ...’’ 184

Abramoff replied, ‘‘Let me know as soon as it gets in, you fucking 

beach bum! :) [sic]’’ 185

On the next day, Scanlon reported, ‘‘Coush Cash is in. Ill [sic] 

process ASAP.’’ 186 The Louisiana Coushatta paid CCS $5,000,000. 

Soon thereafter, on February 19, 2003, Scanlon paid Abramoff’s 

alter ego Kaygold $1,965,000 as a ‘‘referral expense.’’ 187

Abramoff described what he intended to do with this money: ‘‘I 

am actually at rock bottom and have a payroll to meet on Thursday 

for the restaurant. Can you get this to me today or tomorrow?’’ 188
164 

189 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000012123) (February 19, 2003) (emphasis in original). 190 Id. 191 Email from Jack Abramoff, Greenberg Traurig, to Gail Halpern, May & Bernhard (GTG– 

E000012115) (February 20, 2003). 192The entries in the following tables, and similar tables throughout this Report, are taken 

from CCS’ accounting ledger and cross-referenced with other information in the possession of 

the Committee for verification. To determine whether the Tribes received fair value for what 

they paid CCS, wholly incidental expenses were excluded from the source ledger, and presented 

here. Of all vendor transactions reflected in the source ledger, only those greater than or equal 

to $25,000 or traceable to any Tribe have been included here and other similar spreadsheets 

presented in this Report. 

After he did not immediately get his share of the Louisiana 

Coushatta payment, Abramoff implored Scanlon: ‘‘Mike!!! I need 

the money TODAY! I AM BOUNCING CHECKS!!!’’ 189

Abramoff later apologized, ‘‘Sorry I got nuts, but it’s a little crazy 

for me right now. I am not kidding that I was literally on the verge 

of collapse. I hate all the shit I’m into. I need to be on the 

Carribean with you!’’ 190

On February 20, 2003, Abramoff explained to his tax advisor, ‘‘I 

think I understand what he did. We received $5M into CCS ... He 

divided the $5M into three piles: $1M for actual expense, and $2M 

for each of us.’’ 191 The payment to Abramoff, made to his entity 

Kaygold, and a series of substantial ‘‘shareholder draws’’ taken out 

by Scanlon, are reflected in the portion of CCS’ ledger set forth 

below.192 It appears that those draws funded purely personal expenses. 

CAPITOL CAMPAIGN STRATEGIES ACCOUNT SNAPSHOT 

Date Description To/from Amount 

1/31/2003 ........ Balance ...................................................... .................................................................... $934,962.28 

2/3/2003 .......... Professional Campaign; CA Mailer; 2176 Red Sea ...................................................... (40,154.96) 

2/3/2003 .......... Shareholder Draw; SCM; 2177 ................... Phillip Brun ................................................ (44,500.00) 

2/12/2003 ........ Consulting Fees ......................................... Coushatta ................................................... 5,000,000.00 

2/12/2003 ........ Shareholder Draw ....................................... Aviation Group ........................................... (44,400.00) 

2/19/2003 ........ Professional Campaign; Databases; 2201 DDC ............................................................ (14,000.00) 

2/19/2003 ........ Professional Campaign; CA; 2203 ............. Basswood Research ................................... (15,425.00) 

2/19/2003 ........ Referral Expense ........................................ Kaygold, LLC .............................................. (1,965,000.00) 

2/26/2003 ........ Shareholder Draw ....................................... Michael Scanlon ......................................... (1,000,000.00) 

2/26/2003 ........ Shareholder Draw ....................................... Michael Scanlon ......................................... (965,000.00) 

2/28/2003 ........ Balance ...................................................... .................................................................... 1,701,290.87 

3/3/2003 .......... Shareholder Draw ....................................... Michael Scanlon ......................................... (20,000.00) 

3/7/2003 .......... Travel: Airfare ............................................ .................................................................... (89,537.18) 

3/7/2003 .......... Shareholder Draw ....................................... Michael Scanlon ......................................... (20,000.00) 

3/7/2003 .......... Shareholder Draw ....................................... Michael Scanlon ......................................... (20,000.00) 

3/10/2003 ........ Shareholder Draw; 2235 ............................ Beach Pigs, LLC ......................................... (100,000.00) 

3/11/2003 ........ Shareholder Draw; Deposit ........................ .................................................................... 20,000.00 

3/11/2003 ........ Shareholder Draw; Deposit ........................ .................................................................... 20,000.00 

3/12/2003 ........ Shareholder Draw ....................................... .................................................................... (10,000.00) 

3/18/2003 ........ Shareholder Draw ....................................... Michael Scanlon ......................................... (100,000.00) 

3/31/2003 ........ Balance ...................................................... .................................................................... 1,100,413.45 

To add insult to injury, according to at least one contemporaneous email, some of the money that the Agua Caliente and the 

Louisiana Coushatta paid CCS was actually used for conducting 

public relations activities for other Tribes, on matters wholly unrelated to either. Complaining that CCS was not under contract with 

the Saginaw Chippewa for public relations, on February 28, 2003, 

Scanlon admitted, ‘‘For the past 4 months we have spent out of 

pocket to cover their PR—or used agua [sic] or Coushatta money 
165 

193 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg 

Traurig (GTG–E000011983) (February 28, 2003). 194 Email from Jack Abramoff, Greenberg Traurig, to Gail Halpern, May & Bernhard (GTG– 

000012166) (March 28, 2003). 195 Agua Caliente document production (no Bates number) (entitled ‘‘Verbatim Excerpt-Tribal 

Council Meeting of Tuesday, July 9, 2002’’) (July 20, 2004) (excerpt only). 196 Id. 

to cover the cost of every little thing that comes down their pike, 

[sic] We sent them a letter saying we will do no more PR work 

until we establish a retainer arrangement in late December.’’ 193

Abramoff and Scanlon’s requests for payments by, for example, 

the Louisiana Coushatta to CCS (as reflected above) appear to have 

related more to the exigencies of their personal business interests 

than to that Tribe’s grassroots needs. This is evidenced in, for example, an email from Abramoff to his tax advisor, dated March 28, 

2003, in which he wrote, ‘‘I have $1M coming in (I hope directly 

to CAF or Eshkol) probably next week, and $1M due within the 

next 2 weeks to Kaygold. Both from CCS. How long will this money 

last both for the school and the restaurants?’’ 194 Given the foregoing, it appears that the Louisiana Coushatta received little of the 

intended benefit for the money it paid CCS during this period. 

2. The ‘‘Database’’ 

The fact that most of the Tribes received little of the intended 

benefit for the millions they paid CCS is perhaps best illustrated 

by the political databases that Scanlon promised them. As described below, the Tribes received something far less than the customized, state-of-the-art databases that Abramoff and Scanlon told 

them Scanlon would design, build, and use for them as part of their 

grassroots campaigns. 

a. The Pitch 

In pitching Scanlon’s program to the Agua Caliente Tribal Council, Abramoff described what Scanlon allegedly did for the Mississippi Band of Choctaw Indians (‘‘Choctaw’’): 

So we decided ... to implement a system that Mike [Scanlon] developed[,] which we successfully implemented a couple of other times and it’s actually what we’re here in part 

to talk [to] you about today. To organize the tribe so that 

even though the Choctaws were politically powerful in the 

sense of their local area[,] we decided to implement a program to make them the most powerful political machine in 

the State of Mississippi[,] so that if a threat did come up 

... they would be in a position to respond to it.195

He continued: 

And in fact that threat did come up. And what we did was 

organize their assets, their political assets. They had a 

bunch of vendors and a bunch of customers, they had eight 

thousand members of the tribe ... and we organized them 

all. We developed a, a, Mike did, a certain matrix, a certain way to do it so that we could have instant access to 

people who were directly impacted by the business of the 

tribe.196
166 

197 Capitol Campaign Strategies document production (BB/LC 017923) (October 23, 2001) (car- bon-copying Abramoff). 198 Email from Jack Abramoff, Greenberg Traurig, to Kathryn Van Hoof, Coushatta Tribe of Louisiana (COUSH–MiscFin–0000371) (April 12, 2001). 199Memorandum from Michael Scanlon, Capitol Campaign Strategies, to Kathryn Van Hoof, Coushatta Tribe of Louisiana, ‘‘Louisiana Political Budget Outline’’ (October 23, 2001) (carboncopying Abramoff). 200 Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in 

Washington, D.C. (September 14, 2005). 201 Id. 202 Id. 203 Id. 204 Id. 205 Id. 206 Id. 207 Id. 208 Id. 

In an October 2001, memorandum to the Louisiana Coushatta’s 

outside counsel Kathryn Van Hoof, Scanlon described the database 

this way: ‘‘[W]e are taking what you built for the compact fight and 

extend[ing] its reach even further. Our ultimate political objective 

is to control both houses of the state legislature and the governor’s 

mansion.’’ 197 Originally, Abramoff had assured the Tribe that the database that it first paid CCS for in connection with its compact 

renegotiations with the State of Louisiana ‘‘can be used for any political effort deemed appropriate by the tribal decision makers.’’ 198

But, now, Scanlon maintained that ‘‘[i]n order [for the Tribe to 

achieve its political goals], we need to modify your political database into a statewide format.’’ 199

In his interview with Committee staff, then-Louisiana Coushatta 

Vice-Chairman William Worfel recalled having discussed this database with Scanlon and Cathcart during a meeting at Scanlon’s office in Washington, D.C., well after the date of that memorandum.200 During that meeting in 2003, Scanlon and Cathcart 

showed Worfel a list of vendors and their contact information, 

which the Tribe had provided to Scanlon.201 According to Worfel, 

Scanlon and Cathcart said that the database also contained information about other companies with which these vendors did business; those companies’ political connections, in particular, ‘‘whether 

they were Republican or Democrat’’; and information about the 

vendors’ ‘‘friends’’ in various state legislatures.202 Worfel also recalled that the two said that, with respect to the vendors’ employees, the databases contained contact, voter registration, and political affiliation information.203

Worfel also testified that Scanlon and Cathcart said that the 

database included data regarding past State races: each candidate’s 

name, district, party affiliation, results of previous races, and the 

length of service in the State legislature.204 Yet, the only information that they showed him was the election results in the district.205 Worfel also remembers that Scanlon and Cathcart told him 

that they could pull up opposition research data, but didn’t do 

so.206 Having presented their database to Worfel, Scanlon said he 

could beat any candidate with ‘‘anybody.’’ 207 Worfel testified that 

both Scanlon and Cathcart told him that, with this database, ‘‘you 

can control the destiny of the Coushatta Tribe and politics in Louisiana.’’ 208

Scanlon’s proposed use of elaborate databases was also prominent in political programs that he proposed to the Saginaw Chip-
167 

209 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Operation 

Redwing—A Strategy for making the Saginaw Chippewa Tribe the most dominant political entity in Michigan’’) (December 6, 2001). 210 Id. (emphasis in original). 211 Id. 212 Id. 213 A full description of relevant events relating to the Tigua is contained supra in Part 1, 

Chapter 5, ‘‘Ysleta del Sur Pueblo.’’ 214 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Operation 

Redwing—A Strategy for making the Saginaw Chippewa Tribe the most dominant political entity in Michigan’’) (December 6, 2001). 215 Email from Jack Abramoff, Greenberg Traurig, to Marc Schwartz, Partners Group Consult- ants (GTG–E000076138–150) (February 18, 2002) (attaching ‘‘Operation Open Doors’’ proposal); 

Capitol Campaign Strategies document production (no Bates number) (undated) (entitled ‘‘Tigua 

Action Plan—Cost Breakout—Talking Points’’). 

pewa, called ‘‘Operation Redwing.’’ According to drafts of this proposal that he likely presented to the Tribe, ‘‘Our first step [to developing a successful political strategy] is to tap into your natural political resources and integrate them into a custom-built political 

database.’’ 209 The proposal went on to describe a ‘‘grassroots data- base’’: 

[CCS] will gather lists of your vendors, employees, tribal 

members etc. (if you approve, customer lists), and we will 

import those lists into your new database. Our computer 

program will match the individuals or businesses with addresses, phone numbers, political registrations and e-mail 

addresses, and then sort them by election districts. The 

districts run from U.S. Senator down to school board and 

once completed, you can tap into this database and mobilize your supporters in ANY election, or on any issue of 

your choosing.210

Regarding a ‘‘Qualitative [that is, opposition] Research Data- base,’’ the proposal stated the following: 

This custom built database acts as the information center 

of Operation Red Wing. [sic] Over the next six weeks, our 

team will gather qualitative information on any entity who 

can be classified as opposition and enter it into this database. The research will include nearly every piece of information on the opposition as you can imagine. Once gathered, it is then sorted by subject matter and made retrievable by a phrase search. The information can then be instantly disseminated to any audience we choose such as 

our universe of supporters, the press, third party [sic] interest groups or other interested parties.211

According to the ‘‘Operation Redwing’’ proposal, ‘‘the [Saginaw Chippewa] tribe will have built a grassroots army of over 50,000 

real voters that it can call on for offensive or defensive political efforts.’’ 212

The language regarding the database set forth in a Scanlon pro- posal called ‘‘Operation Open Doors,’’ which he and Scanlon presented to the Tigua, is almost identical to what was proposed in 

‘‘Operation Redwing’’ for the Saginaw Chippewa.213 Scanlon’s asking price for ‘‘Operation Redwing’’ was $4,207,000 214 and for ‘‘Operation Open Doors,’’ $5,400,000.215

The foregoing accords with the recollection of former Saginaw 

Chippewa Sub-Chief David Otto, who told staff that Scanlon 
168 

216 Interview of David Otto, former Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (August 27, 2004). As described supra in Part 1, Chapter 3, ‘‘Saginaw Chippewa 

Indian Tribe,’’ Section D, ‘‘Slate of Eight—Abramoff and Scanlon’s Trojan Horse,’’ the Slate of 

Eight was a slate of candidates whose campaigns for the Saginaw Chippewa Tribal Council 

Scanlon and Abramoff supported, in contemplation of, or in exchange for, future business with 

the Tribe. 217 Interview of David Otto, former Sub-Chief, Saginaw Chippewa Indian Tribe, in Washington, D.C. (August 27, 2004). 218 Id. 219 Id. 220 Id. 221 Id. 222 Id. 223 Id. 224 Id. 225 Id. 226 Id. 227 Id. 228 Id. 229 Id. 230 Id. 231 Id. 232 Id. 233 Id. 

pitched that Tribe on his database about a week after the election 

of the Slate of Eight.216 Otto recalled that Abramoff was also in attendance.217 During his interview with staff, Otto recalled that 

Scanlon similarly insisted that the Tribe needed his database to assert influence on the state level, conduct writing campaigns, and to 

oppose competitors.218 Otto also remembered Scanlon’s saying that 

the database was ‘‘customized’’ and that the software would specifically be built for the Tribe.219 Additionally, Otto stated that Scanlon cited the need to do mass mailings to write to members of Congress to prevent gaming competition in the area.220 According to 

Otto, Scanlon represented that his company created and maintained the database.221 On or about January 4, 2002, the Tribal 

Council voted to hire Scanlon to create the database for about 

$1.85 million.222

Otto recalled working with Cathcart at CCS, to build up the 

database with lists of the Tribe’s employees and members.223 This 

was part of an ‘‘organizational phase,’’ for which all of the subject 

Tribes paid CCS millions. When Scanlon finally showed the program to the Saginaw Chippewa Tribal Council, he said it would 

start a massive campaign.224 All of the people on the lists provided 

by the Tribe would be contacted and told to write specific lawmakers, telling them they opposed legislation hostile to the Tribe’s 

interests.225 Otto recalls Scanlon saying that this database would 

generate massive phone call and letter campaigns.226

At a subsequent meeting, Otto was shown the database.227 Otto 

recalled that Cathcart did some talking, as did another CCS associate, David Flaherty.228 He remembered that another CCS associate named Amy Biederman was also in attendance but did not 

speak much during the meeting.229 When Otto saw the database, 

which was presented on a laptop, he thought ‘‘we spent millions of 

dollars for something a college kid could do.’’ 230 He did not think 

it was worth millions of dollars.231 Otto assumed that the Tribe 

had immediate access to the database.232 But, he later learned the 

Tribe needed to pay more money to CCS.233 In fact, Otto believes 
169 

234 Id. 235 Interview with Marc Schwartz, president, Partners Group Consultants, in Washington, 

D.C. (November 10, 2004). 236 Id. 237 Id. 238 Id. 239 Id. 240 Id. 241 Id. 242 Interview with Tom Diamond, Esq., Diamond, Rash, Gordon & Jackson, outside counsel, 

Ysleta del Sur Pueblo of Texas, in El Paso, Texas (October 28, 2004); Interview with Marc 

Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). 243See Interview with Marc Schwartz, president, Partners Group Consultants, in Washington, 

D.C. (November 10, 2004). 244 Id. 245 Id. 246 Id. 247 Id. 248 Id. 249 Id. 

that the Tribe ultimately spent about $4.1 million to build the 

database and another $3.5 million or so to use it.234

Likewise, when Abramoff and Scanlon first met with the Tigua, 

Scanlon explained grassroots campaigns and, in particular, how he 

could get thousands of telephone calls to flood ‘‘a senator’s office, 

or even the President’s office.’’ 235 Against that backdrop, he and 

Abramoff proposed a nationwide political campaign for the 

Tribe.236 To demonstrate what they had in mind, they brought a 

laptop with a database similar to what they were proposing to 

build for the Tigua.237

Abramoff noted, ‘‘my part is easy; the hard part is keeping this 

from being undone.’’ 238 He then explained how once the law (with 

the Tigua-related provision) is printed, ‘‘someone’s going to know it 

and that’s where Mike comes in.’’ 239 In that context, Abramoff described Scanlon’s role as a ‘‘submarine’’: once the bill passed, Scanlon’s ‘‘submarine’’ would emerge and ‘‘fire missiles’’ at opponents, 

who try to repeal the Tigua provision.240 With Abramoff having 

characterized Scanlon as ‘‘expensive but worth it,’’ 241 Scanlon explained that he would implement this ‘‘submarine strategy’’ 

through the database that he was supposedly going to build for the 

tribe.242

Scanlon apparently designated his ‘‘right-hand man,’’ Christopher Cathcart, to serve as his point of contract with the Tribe.243

Working with Cathcart on the Tribe’s behalf was Tribal spokesperson Marc Schwartz.244 Schwartz believed that he may have had 

as many as 20 to 25 conversations with Cathcart.245 In his interview with Committee staff, Schwartz recalled Cathcart had described the database as ‘‘very customized.’’ 246 He also recalled that 

Cathcart had said that Scanlon had ‘‘six people working day and 

night to get the system up and running’’ and a ‘‘stable’’ of graphic 

artists.247 Schwartz also remembered asking Cathcart how many 

people were working for Scanlon’s company.248 In response, 

Schwartz recalled, Cathcart said ‘‘dozens’’ and described Scanlon’s 

company to Schwartz as ‘‘absolute studs.’’ 249

From Cathcart’s presentation, which probably occurred sometime 

in Spring 2002, Schwartz came away thinking that Scanlon’s organization was huge and that his company had done a number of 
170 

250 Id. 251 Id. 252 Id. 253 Id. 254 Id. 255 Id. 256 Id. 257 Id. 258 Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006); Interview of David Mielke, counsel, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006). 259 Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006); Interview of David Mielke, counsel, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006). 260Louisiana Coushatta document production (no Bates number) (June 26, 2001) (entitled, 

‘‘The Coushatta Political Program,’’ by Michael Scanlon). 261 Id. 262 Agua Caliente document production (no Bates number) (entitled ‘‘Verbatim Excerpt—Tribal 

Council Meeting of Tuesday, July 9, 2002’’) (July 20, 2004) (excerpt only). 

these types of behind-the-scenes projects before.250 According to 

Schwartz, Cathcart never mentioned that Scanlon had, or planned 

to use, outside vendors.251 Given Abramoff’s ‘‘absolute, categorical’’ 

insistence on secrecy with the Tigua, Schwartz would have been 

very concerned about Scanlon’s using outside vendors on the database project.252

In hindsight, Schwartz believes that Cathcart lied about the following: (1) the database was not customized; (2) Scanlon did not 

have ‘‘dozens’’ of employees working on the database; and (3) Scanlon did not have a ‘‘stable’’ of graphic artists.253 Schwartz also believes that various representations that Cathcart made about the 

database’s functionality were false.254 After having seen the database subsequently, Schwartz considered it ‘‘extremely 

unremarkable.’’ 255 In his view, there was ‘‘no way’’ that the database required ‘‘six people working day-and-night’’ or that ‘‘the database was worth millions.’’ 256 But, the Tribe had already paid CCS 

$4,200,000.257

In October 2002, the Pueblo of Sandia met with Cathcart at CCS’ 

Washington office to view its database and was equally 

unimpressed: not only by the database’s functionality but also the 

fact that it appeared to capture only the employee and vendor lists 

that the Tribe provided CCS.258 The database was not, in the view 

of the tribal representatives who reviewed it at the time, worth 

anything close to the almost $2 million that the Tribe had paid for 

it.259

Oral representations made by Scanlon that he apparently made 

to Tribal representatives, in particular, Schwartz, Otto and Worfel, 

about having ‘‘built’’ the database is reflected in a document entitled ‘‘The Coushatta Political Program,’’ dated June 26, 2001.260 In 

a section entitled, ‘‘What We Have Built,’’ Scanlon stated, ‘‘We have 

constructed a state-of-the-art political database containing roughly 

20,000 individuals who will take action on behalf of the Tribe.’’ 261

It is also reflected in the minutes of an Agua Caliente Tribal Council meeting during which Scanlon and Abramoff pitched the database.262 There, Scanlon further stated, ‘‘Then my job is to have 

there [sic] voices ... heard[.] How do we do that[?] Several different 

ways[.] [O]ne [is to] start with [a] custom[-]built database which I 

designed myself[.] [W]hat this database does[—]it is a political 

database and takes raw data such as employees—takes raw data 
171 

263 Id. 264 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Agua Caliente Global Political Strategy’’) (undated). 265 Id. 266 Id. See Letter from Michael Scanlon, Scanlon Gould Public Affairs, to the Honorable Richard Milanovich, Agua Caliente Band of Cahuilla Indians (July 9, 2002). 267 Interview of B.R. McConnon, president, Democracy Data & Communications, in Wash- ington, D.C. (August 26, 2004); Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). 268 Interview of B.R. McConnon, president, Democracy Data & Communications, in Wash- ington, D.C. (August 26, 2004); Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). 269 Interview of B.R. McConnon, president, Democracy Data & Communications, in Wash- ington, D.C. (August 26, 2004); Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). 270 Interview of B.R. McConnon, president, Democracy Data & Communications, in Wash- ington, D.C. (August 26, 2004); Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). 271 Interview of B.R. McConnon, president, Democracy Data & Communications, in Wash- ington, D.C. (August 26, 2004); Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). 272 Interview of B.R. McConnon, president, Democracy Data & Communications, in Wash- ington, D.C. (August 26, 2004); Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). 273See, e.g., Agua Caliente document production (AC 0287) (July 24, 2002) (Letter from Michael P. Scanlon, Scanlon Gould Public Affairs, to Chairman Richard Milanovich, Agua Caliente 

Band of Cauhilla Indians, July 24, 2002) (describing organizational phase as ‘‘[i]nclud[ing] acquisition and design of hardware and software on behalf of the Tribe, data matching, grassroots 

development, online applications and political modifications’’). For this, Scanlon charged the 

Agua Caliente $1,875,000. Id. See also Email from Jack Abramoff, Greenberg Traurig, to Marc Schwartz, Ysleta del Sur Pueblo of Texas (GTG–E000076138–150) (February 18, 2002) (attaching ‘‘Operation Open Doors’’ and describing organizational phase similarly). For this, Scanlon 

charged the Tigua $1,875,000. Id. 

and we insert that data into our system soon to become your system if we work together ...’’ 263

Scanlon also described the grassroots database as ‘‘custom built’’ in a draft of the ‘‘Agua Caliente Global Political Strategy,’’ dated 

July 8, 2002.264 In fact, in that document, Scanlon told the Tribe 

that ‘‘[CCS] will immediately begin acquiring the computer hardware, software and design the computer that houses your database.’’ 265 To ‘‘organize’’ and implement this strategy, Scanlon sought from the Agua Caliente $5,400,000 and an additional setaside of $2,000,000.266

b. The Facts 

In truth, Scanlon’s company neither built nor designed these databases.267 In fact, Scanlon merely licensed a database actually created by a vendor named Democracy Data & Communications 

(‘‘DDC’’).268 In instances where CCS charged Tribes for DDC’s databases, DDC developed them to help CCS conduct grassroots 

campaigns on the Tribes’ behalf.269 In these cases, CCS supplied 

DDC with information, such as membership rosters and vendor information, that CCS obtained from its Tribal clients.270 Then, using its own proprietary software and network design, DDC helped CCS 

use that information for grassroots purposes—to create mass 

emails, letters, faxes, etc.271

In other words, DDC, rather than CCS, built, updated and maintained those databases, for which CCS charged its tribal clients 

millions of dollars.272 Typically, Scanlon charged each of the Tribes at least $1,000,000 just for putting the database together; this was 

called the ‘‘organizational phase.’’ 273 But, in truth, all the work 

that DDC did on each of the databases it developed, cost Scanlon 

a fraction of that amount. For example, all the work that DDC did 
172 

274 Interview of B.R. McConnon, president, Democracy Data & Communications, in Wash- ington, D.C. (August 26, 2004); Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). 275 Interview with Christopher Cathcart, former associate, Capitol Campaign Strategies, in Washington, D.C. (November 4, 2004). 276 Id. 277 Interview of B.R. McConnon, president, Democracy Data & Communications, in Wash- ington, D.C. (August 26, 2004); Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). 278 Interview of B.R. McConnon, president, Democracy Data & Communications, in Wash- ington, D.C. (August 26, 2004); Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). 279 Interview of B.R. McConnon, president, Democracy Data & Communications, in Wash- ington, D.C. (August 26, 2004); Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). 280 Interview of B.R. McConnon, president, Democracy Data & Communications, in Wash- ington, D.C. (August 26, 2004); Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). 281 Email between Charles Trout, Visual Impact Productions, and Christopher Cathcart, Capitol Campaign Strategies, ‘‘democracy direct feates [sic]/functionality’’ (no Bates number) (August 27, 2003). 282 Id. 

for the Louisiana Coushatta’s database (from May 2001 through 

December 2003) cost CCS only $104,000.274 Notably, in his interview with Committee staff on the Tigua, Scanlon’s right-hand man, 

Christopher Cathcart, admitted that the Tribe ‘‘got nowhere near 

[the] $1.8 million [it paid] for the organizational phase.’’ 275 He also 

conceded that the Tigua’s database was not customized.276

DDC President B.R. McConnon testified that, when compared 

with DDC’s other clients paying similar prices and using similar 

services, there was actually ‘‘a very low level of activity’’ on the 

CCS account that were maintained for CCS’ tribal clients.277 Generally, McConnon observed, customers who have such a low level 

of usage tend to shut off the account.278 McConnon recalled that 

CCS used DDC’s services so sparingly, ‘‘it got to be a running joke 

in the office.’’ 279

In cases not involving DDC databases, it appears that CCS took 

DDC’s proprietary network design; provided that design to another 

vendor, Visual Impact Productions (‘‘VIP’’); and directed VIP to develop databases designed to mimic DDC’s product. And, in those 

cases, it appears that CCS charged those Tribes millions of dollars 

for the development, maintenance, and use of those databases. 

One of those databases was used by CCS for the Pueblo of 

Sandia. Apparently, a version of this database was also used by 

CCS for the Louisiana Coushatta after December 2003. When 

shown these databases during his deposition, McConnon testified 

that CCS violated the terms of its licensing agreement when it took 

the design of the database that his company originally created for 

the Louisiana Coushatta and used it to develop another system 

that was meant to look like his company’s database.280 McConnon 

is correct: an email between VIP employee Charles Trout and CCS’ 

Cathcart, dated August 27, 2003, reflects that Trout ‘‘reviewed the 

Democracy Direct software’’ and analyzed the ‘‘Democracy Direct 

application.’’ 281 Having done so, Trout told Cathcart, ‘‘[F]or ease of 

use I have attempted to mimic the interface of the desktop app 

with the online app. For the most part, they will be the same so 

the user will be able to use both without re-learning the interface.’’ 282 Trout noted, ‘‘I remember that your goal was to buy a 
173 

283 Id. 284 Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (August 26, 2004); Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). 285 Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (August 26, 2004); Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). 286 Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (August 26, 2004); Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). 287 Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (August 26, 2004); Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). 288 Interview of Stuwart Paisano, former Governor, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006); Interview of David Mielke, counsel, Pueblo of Sandia of New Mexico, in Washington, D.C. (April 18, 2006). 289 Capitol Campaign Strategies document production (no Bates number) (March 14, 2002) (Draft Letter from Michael Scanlon, Scanlon Gould, to Governor Stuwart Paisano, Pueblo of 

Sandia of New Mexico). 290 Interview of B.R. McConnon, president, Democracy Data & Communications, in Wash- ington, D.C. (August 26, 2004); Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). 291Some may assert that the reference to a ‘‘database’’ referred to in, for example, the ‘‘The 

Coushatta Political Program’’ document described above, refers to lists derived from communications programs that CCS implemented for the Louisiana Coushatta. Nonetheless, if so, the document’s reference to that database as ‘‘state-of-the-art’’ would be false. And, if it refers to the 

database provided by DDC (or VIP), the statement would be false, where as of that particular 

document’s date, DDC had not yet provided CCS with a political database. Interview of B.R. 

McConnon, president, Democracy Data & Communications, in Washington, D.C. (August 26, 

2004); Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). As of the date of the document, on the Louisiana Coushatta 

account, DDC only warehoused data, that is, provide a very basic list-management program. 

Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, 

D.C. (August 26, 2004); Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). 

laptop and have us install the application on it before delivery to 

the client.’’ 283

Having examined VIP’s database, McConnon opined that it was 

far less capable than his company’s.284 In particular, McConnon 

noted that the quality of the data contained in the VIP system 

seemed inferior to DDC’s; its searching capability was far less extensive than DDC’s; its presentation of information was very limited; it seemed not to contain as much information as DDC’s, which 

is important to implement a more targeted, efficient grassroots program; and the quality of the keypunching seemed very inferior.285

McConnon agreed that someone at CCS apparently showed the 

other vendor the ‘‘access page’’ of his company’s database.286

McConnon confirmed that this would be a violation of the licensing 

agreement that Scanlon executed with DDC.287

For a version of this database, the Pueblo of Sandia paid Scanlon 

$1,857,000.288 That amount corresponds to elements of a proposal 

drafted by Scanlon for the Tribe relating to ‘‘acquisition and design 

of hardware and software, data matching, grassroots development, 

online applications and political modifications.’’ 289 However, in actuality, Scanlon never provided those services. In the ordinary 

course of business, those services would have been provided—at a 

far lesser cost—by one of Scanlon’s vendors. In this case, 

McConnon opined that this database, apparently produced by VIP, 

was worth nothing near $1,857,000; it was probably worth, at the 

very most, about $20,000.290 Whether the database came from 

DDC or VIP, it appears that the representation that CCS ‘‘constructed’’ a database was false.291
174 

292Letter from Michael Scanlon, Scanlon Gould, to Governor Stuwart Paisano, Pueblo of 

Sandia of New Mexico (March 14, 2002) (draft). 293 Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (August 26, 2004); Interview of B.R. McConnon, president, Democracy Data & Communications, in Washington, D.C. (September 28, 2005). 294 Capitol Campaign Strategies document production (BB/LC 017923) (October 23, 2001). 295 Id. (emphasis in original). 296 Id. 297Deposition of Aaron Stetter, former associate, Capitol Campaign Strategies, in Washington, D.C. (May 26, 2005). 298 A full discussion of these activities, and the degree to which Abramoff relied on them in 

support of their Tribal clients, is set forth above in Part 1, Chapter 1, ‘‘Mississippi Band of Choctaw Indians,’’ and below in Part 2, Chapter 2, ‘‘American International Center.’’ 

The draft document goes further: ‘‘We have compiled a state-of- the-art qualitative research database, which can identify allies and 

adversaries by ‘quote.’ ’’ 292 However, the Committee has seen no 

evidence that DDC, or any other vendor for that matter, ever provided CCS with such a database. Nor has the Committee seen any 

evidence that CCS developed such a database internally. Therefore, 

that statement too appears to be false.293

3. CCS’ Use of Fictitious Grassroots Organizations 

Among the things that CCS promised to do for its Tribal Clients was to mobilize, in particular, Christian conservatives and environmental activists to oppose the expansion of gaming in areas that 

would infringe on their market share. Several documents describe 

exactly what Scanlon had in mind. In a document entitled ‘‘Louisiana Political Budget Outline,’’ dated October 23, 2001, Scanlon 

told a representative of the Louisiana Coushatta, ‘‘We plan to use 

three forms of communications to mobilize and win these battles. 

Phones, mail and Christian radio.’’ 294 He continued, ‘‘Our mission 

is to get specifically selected groups of individuals to the polls to 

speak out AGAINST something.’’ 295

According to Scanlon, ‘‘To that end, your money is best spent finding them and communicating with them on using the modes 

that they are most likely to respond to. Simply put we want to 

bring out the wackos to vote against something and make sure the rest of the public lets the whole thing slip past them. The wackos 

get their information form [sic] the Christian right, Christian radio, 

mail, the internet and telephone trees.’’ 296

According to other documents in the Committee’s possession, Scanlon likewise promised the Saginaw Chippewa that it would 

repel threats to its market share by ‘‘execut[ing] the following tactics’’: grassroots mobilization of environmental activities; mobilization of anti-gaming activists; patch-through phone calls to state 

and federal environmental protection agencies; direct mail; as well 

as mobilization of environmental and ‘‘citizen groups.’’ 297 As described above, only a fraction of what the Tribes paid CCS went to 

the grassroots efforts promised by CCS. So, the question arises 

what did CCS in fact do to mobilize grassroots supporters? 

In this regard, it appears that Scanlon and his partner Abramoff 

originally relied on the efforts of Ralph Reed and other vendors to 

conduct these grassroots activities.298 However, at some point, it 

appears that Scanlon and Abramoff chose not to rely on Reed’s efforts or pushed him out entirely, ostensibly to maximize their 

‘‘gimme five’’ income. In fact, in a few cases, Scanlon used fictitious 

organizations to manipulate grassroots support among Christian 
175 

299Deposition of Aaron Stetter, former associate, Capitol Campaign Strategies, in Washington, D.C. (May 26, 2005). 300 Id. 301See Interview with Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Washington, D.C. (April 27–29, 2005). 302Deposition of Aaron Stetter, former associate, Capitol Campaign Strategies, in Washington, 

D.C. (May 26, 2005). 303 Id. 304 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘CCAGE talking points’’) (undated). 305 Id. 306 Id. 307 Id. 308 Id. 

conservatives and environmentally-minded voters. Accordingly, for 

a fraction of the cost associated with bona fide grassroots activities, 

Scanlon was able to convey to his clients the appearance that he 

was coalition-building or mobilizing support, when he was actually 

not doing so. 

According to Aaron Stetter, a former associate at CCS, on several 

occasions Scanlon used fictitious grassroots organizations for the 

Saginaw Chippewa, in particular.299 During his deposition, Stetter 

remarked that the names of such organizations such as ‘‘Concerned 

Citizens Against Gaming Expansion (‘‘CCAGE’’),’’ ‘‘Global Christian 

Outreach Network (‘‘GCON’’),’’ and ‘‘Michigan Environmental 

Group’’ were ‘‘just a title’’ and to his knowledge not bona fide organizations.300 During her interview with staff, Abramoff and Scanlon’s liaison with the Choctaw, Nell Rogers, stated that she believed that CCAGE and GCON were actual grassroots organizations working on the Tribe’s projects.301 That was not the case. 

Stetter told Committee staff that he was required to create phone 

scripts that CCS would use for patch-through phone calls.302 When 

he prepared these scripts he ‘‘would leave the line blank and then 

[the name of the organization] would either be added by [Cathcart 

or Scanlon] during the drafting process’’ or he would receive an 

email ‘‘saying, plug this word in.’’ 303

The pretensions that Scanlon used in mobilizing opposition to 

gaming initiatives that threatened his clients’ market share is reflected in talking points that purport to describe the CCAGE.304

This document falsely describes the CCAGE as ‘‘a watchdog for illegal gaming efforts in the United States.’’ 305 Furthermore, according to the document, ‘‘[a]t the grassroots level, CCAGE draws attention to such efforts while educating the public on the dangers 

of gambling to families and communities.’’ 306 The document deceptively explains that the CCAGE targeted Louisiana because ‘‘[Louisiana] is an affordable media market—our dollars stretch further 

and we felt we have a better shot at being effective, really making 

a difference.’’ 307 In fact, the document misleadingly states, ‘‘We ... 

are not representing their competitors like Harrahs or Isle of 

Capri’’; ‘‘[we get] [n]o money from Harrahs, Isle of Capri or any 

other casinos’’; and ‘‘CCAGE is by no means bogus.’’ 308 Needless to 

say, these talking points do not mention that the CCAGE operated 

for the benefit of a gaming tribe. It is unclear what these talking 

points were used for. However, inasmuch as Scanlon may have 

used them to mobilize unwitting activists and voters as part of his 

grassroots strategy for the Louisiana Coushatta, they give rise to 

concern. 
176 

309Deposition of Aaron Stetter, former associate, Capitol Campaign Strategies, in Washington, D.C. (May 26, 2005). 310See id. 311See id. 312 Id. 313 Id. 314 Id. 315 Id. 316See Interview of Christopher Cathcart, associate, Capitol Campaign Strategies, in Wash- ington, D.C. (May 5, 2005). 317Deposition of Aaron Stetter, former associate, Capitol Campaign Strategies, in Washington, D.C. (May 26, 2005). 318 Interview of Christopher Cathcart, former associate, Capital Campaign Strategies, in Washington, D.C. (May 5, 2005). 319 Interview of Fred Baggett, Chair, National Government Affairs Practice, Greenberg Traurig, in Washington, D.C. (September 29, 2005). 320 Id. 

Stetter also acknowledged that pursuant to instructions from 

Scanlon and/or Cathcart he set up several cell phones with area 

codes in states in which CCS was operating for its tribal clients.309

He then handed the phones over to Amy Biederman, another CCS 

associate.310 She kept a box of phones in her office with the name 

of each organization taped to the back of the respective phone, and 

depending on which phone rang, she answered with ‘‘Concerned 

Citizens Against Gaming Expansion,’’ or with the name of one of 

the other fictitious organizations.311

In addition to using these bogus organizations for phone banking, 

Scanlon issued fliers under their names. Stetter recalled that early 

in his career with CCS he was directed by Scanlon to deliver a flier 

entitled ‘‘GCON, Issue Focus 2002’’ to ‘‘each Member of the [Mississippi State] House and ... Senate.’’ 312 Stetter recalled that he 

stuffed these fliers in, among other places, the mailboxes of each 

state senator.313 One such flier listed the address at a Post Office 

in Flowwood, Mississippi. Stetter admitted that this too was bogus: 

‘‘[my] first order of business on this trip was to, one, set up a post 

office box somewhere in Mississippi ... and to activate a cell phone’’ 

to delude the fliers’ recipients that these were bona fide grassroots 

organizations.314 In fact, Stetter noted that he chose Flowwood 

simply because it was close to the airport where he arrived.315

Scanlon insisted that P.O. Boxes be set up in the states where CCS 

was operating.316 That flier listed Amy Biederman as the national 

director for the GCON. In his deposition, Stetter confirmed that 

Biederman was in fact not the national director for the GCON but 

merely another associate at CCS.317 Scanlon’s right-hand man, 

Christopher Cathcart, maintained in a Committee staff interview 

that this effort was merely intended to find out what opinion leaders thought of gaming.318

In his interview with Committee staff, the head of Greenberg 

Traurig’s national lobbying practice observed that using fictitious 

grassroots entities ‘‘for cover’’ is not uncommon.319 Specifically, he 

reflected, ‘‘When the trial lawyers want to pass their constitutional 

amendment to, to ratchet down the doctors, they create a Coalition 

for Fairness in Medical Practice, and there’s nothing—you can go 

into a state, in Topeka, Florida, and I can give you all the 527s and 

CCEs and the not-for-profits, and most of them we can tell you who 

funded which one of them ... because you know where the money 

is coming from.’’ 320
177 

321 Id. 322 Interview of Brian Mann, former director, American International Center, in Washington, 

D.C. (March 3, 2006). 323 Id. 324 Id. 325 Id. 

He continued, ‘‘You know, the effort to save the greyhounds in 

Florida is an anti, is actually primarily funded by Disney and Universal to keep casinos out ...’’ 321

While using bogus groups in furtherance of grassroots strategies 

may be common, Scanlon and Abramoff’s use of them is distinguishable in that they were employed as part of Abramoff and 

Scanlon’s ‘‘gimme five’’ scheme. In an interview with Committee 

staff, former CCS associate Brian Mann said that he thought that, 

for example, the letter-writing and signature-gathering campaigns, 

many of which he helped lead or otherwise conduct in the name of 

such bogus organizations, were ‘‘fraudulent.’’ 322 He described them 

as ‘‘flashes in the pan [that were designed] to appease [CCS’] clients.’’ 323 He regarded them as exercises that ‘‘created face time’’ 

and ‘‘scuttlebutt’’ by ‘‘send[ing] a few people out there to show them 

that we exist.’’ 324 With CCS associates collecting signatures ‘‘on KMart or Walmart parking lots,’’ Mann felt that those activities 

‘‘didn’t amount to very much.’’ 325

The preceding sections of this Chapter set forth Abramoff and 

Scanlon’s ‘‘gimme five’’ scheme, as it related to CCS, and describe 

how Abramoff and Scanlon furthered that scheme by promoting 

Scanlon’s grassroots business—only after concealing their financial 

relationship from the Tribes. This Chapter has also set forth the 

basis of the Committee’s conclusion that those Tribes received little 

of the intended benefit for the $66 million that they paid CCS from 

2001 through 2003. 

E. CONCLUSION

As a general proposition, Abramoff and Scanlon’s ‘‘gimme five’’ 

scheme involved getting each of the Tribes to hire Scanlon as their 

grassroots specialist; dramatically overcharging them for grassroots 

and related activities; setting aside for themselves a percentage of 

what the Tribes paid at a grossly inflated rate—a rate wholly unrelated to the actual cost of services provided; and using the remaining fraction to reimburse scores of vendors that could help them 

maintain vis-a-vis the Tribes a continuing appearance of competence. 

In all cases, secrecy was key. Only by keeping their financial arrangement secret could they execute the strategies that they devised to secure the Tribes as clients. In some cases, they did so by 

insinuating themselves in tribal council elections and assisting 

with the campaigns of candidates who were calculated to support 

their proposals. In other cases, Abramoff and Scanlon were even 

more aggressive. In one example, they helped shut down the casino 

of one particularly underprivileged Tribe, only to pitch their services afterwards—for a multimillion dollar premium—to help that 

same Tribe, made desperate by their efforts, reopen it. 

Typically, the most expensive element of Scanlon’s proposals to 

the Tribes related to an elaborate political database. But, in all 
178 

cases, it appears that the degree to which Scanlon marked-up his 

actual costs was unconscionable. For example, while Scanlon told 

the Louisiana Coushatta that their ‘‘political’’ database would cost 

$1,345,000, he ended up paying the vendor that actually developed, 

operated and maintained that database about $104,560. The dramatic mark-ups were intended to accommodate Scanlon’s secret 50/ 

50 split with Abramoff. 

In total, six tribes paid CCS at least $66 million over the threeyear period. By the Committee’s reckoning, each Tribe paid CCS as 

follows: the Choctaw, $14,745,650; the Louisiana Coushatta, 

$26,695,500; the Saginaw Chippewa, $10,007,000; the Agua 

Caliente, $7,200,000; the Tigua, $4,200,000; and the Pueblo of 

Sandia, $2,750,000. Of that $66 million, Abramoff secretly collected 

from Scanlon, through (among other entities) an entity called 

Kaygold, about $24 million. This constituted about one-half of 

Scanlon’s total profit from the Tribes. 

As described above in detail, most of the money that the Tribes 

paid Scanlon appears to have been used by Scanlon and Abramoff 

for purely personal purposes—purposes unintended by the Tribes. 

Generally, Abramoff seems to have used his share of the proceeds 

he received from Scanlon to float his restaurant ventures and, 

through the CAF, operate his Jewish boys’ school in Maryland. 

Likewise, Scanlon seems to have used his share to purchase real 

estate and other investments. Given the foregoing, the Committee 

finds that most of the Tribes received little of the intended benefit 

for the significant sums they paid to Scanlon. 
(179) 

1 Brody Mullins, Abramoff Shops Himself on K Street, Roll Call, March 23, 2004. 2Shawn Zeller, Lobbying & Law—K Street Cooled Off in 2002, National Journal, April 19, 

2003. 3 Id. 4Plea Agreement, Factual Basis for the Plea at para. 2, U.S. v. Michael P.S. Scanlon (Dist. 

D.C., November 17, 2005) (CR–05–411); Plea Agreement, Factual Basis for the Plea at para. 4, 

U.S. v. Jack A. Abramoff (Dist. D.C., January 3, 2006) (CR–06–001). 

CHAPTER II 

AMERICAN INTERNATIONAL CENTER 

Ben, I need to set up a web site for the American International Center, which should have all sorts of goodies to 

make it look real ... Can you create something? 

Email from Jack Abramoff to Benjamin Mackler, Mack Design, January 19, 2002 

CHAIRMAN MCCAIN: [Scanlon] approached you in some 

way? 

MR. GROSH: A phone call. 

CHAIRMAN MCCAIN: And said? 

MR. GROSH: Do you want to be head of an international 

corporation. [Laughter] It is a hard one to turn down. 

[Laughter] 

Committee Chairman McCain and former Rehoboth Beach lifeguard David Grosh, 

Committee Hearing, June 22, 2005 

A. INTRODUCTION

In the course of its hearings over the last two years, the Committee preliminarily found that the American International Center 

(‘‘AIC’’), a supposed think tank based in Rehoboth Beach, Delaware, and headed by two of Scanlon’s beach buddies, was not what 

it purported to be. In actuality, AIC was one of several entities 

owned or controlled by Michael Scanlon or Jack Abramoff that they 

used as part of their ‘‘gimme five’’ scheme—their secret scheme to 

wrongfully divert millions of dollars in fees paid by their Tribal clients for purely personal use. However, from 2001 through 2003, 

AIC was itself Abramoff’s ninth biggest lobbying client, reportedly 

paying him and his employer about $1.7 million in lobbying fees.1

In 2002 alone, AIC reportedly paid Greenberg Traurig $840,000, 

making it the Firm’s fifth largest client that year.2 Until the Committee’s hearings, the nature and business of AIC remained elusive: one industry observer described it at the time as ‘‘a client 

with interests that are hard to decipher.’’ 3

In court filings associated with their federal criminal pleas, 

Abramoff and Scanlon admitted that they used AIC (and other 

Scanlon-controlled entities) to receive funds for work done by another Scanlon entity, called Capitol Campaign Strategies (‘‘CCS’’).4

Moreover, recently appearing before the Committee, a representative of Greenberg Traurig described AIC more plainly as ‘‘a sham’’ 
180 

5 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. at 22 (November 2, 2005) (testimony of Fred Baggett, Chair, National Government Affairs Practice, 

Greenberg Traurig). 6 Interview of Christopher Cathcart, former associate, Capitol Campaign Strategies, in Wash- ington, D.C. (May 5, 2005). 7 Id. 8 Id. 9 Interview of David Grosh, former director, American International Center, in Washington, D.C. (February 8, 2005). 10 Id. 11 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. at 35 (June 22, 2005) (testimony of David Grosh, former director, American International Center). 12 Interview of David Grosh, former director, American International Center, in Washington, D.C. (February 8, 2005). 13 Id. 14 Id. 15 Id. 16 Id. 

and merely ‘‘a front for Mr. Abramoff and Mr. Scanlon to collect 

money.’’ 5 Given the information the Committee has obtained during its investigation, the Committee shares that conclusion. Below, 

the Committee explains why. After providing background on how AIC was started and how it was used as a conduit to further the Tribes’ grassroots strategies, 

this Chapter will describe how Abramoff and Scanlon used AIC to 

further their ‘‘gimme five’’ scheme, secretly splitting fees paid by 

the Coushatta Tribe of Louisiana (‘‘Louisiana Coushatta’’) and, to 

a lesser extent, the Mississippi Band of Choctaw Indians (‘‘Choctaw’’). 

B. A DAY AT THE BEACH—HOW AIC WAS STARTED

AIC was apparently started in early 2001.6 In an interview with 

Committee staff, Christopher Cathcart, who ultimately served as 

Scanlon’s most senior and highest-paid assistant, described AIC as 

‘‘a joint project’’ between Scanlon and Abramoff.7 Otherwise, 

Cathcart claims, he did not know what role Abramoff had in AIC.8

Early in 2001, Scanlon called his long-time friend and fellow life- guard David Grosh and asked him whether he wanted to serve as 

a director of an ‘‘international corporation.’’ 9 Grosh, who knew 

quite well that his background was unsuited for such a position, 

thought that this was a joke but finally agreed: 10

CHAIRMAN MCCAIN: [Scanlon] approached you in some 

way? 

MR. GROSH: A phone call. 

CHAIRMAN MCCAIN: And said? 

MR. GROSH: Do you want to be head of an international corporation. [Laughter] It is a hard one to turn down. 

[Laughter].11

Scanlon then offered Grosh $500 per month to serve as a director 

of AIC.12 At some point, Grosh asked Scanlon why he selected him.13 According to Grosh, Scanlon answered, ‘‘because you are a political unknown.’’ 14 When Grosh asked Scanlon what AIC would 

do, Grosh recalled, Scanlon said that it ‘‘would have research done 

by subcontractors in support of a particular political objective and 

would deliver the research to different groups and people.’’ 15 Notably, Grosh also recalled Scanlon mentioning that he had experience 

‘‘running campaigns’’ in countries in Asia and Central America.16
181 

17 Interview of David Grosh, former director, American International Center, in Washington, 

D.C. (February 8, 2005). 18 Id.; American International Center (no longer available) <http://www.americent.org/mission.html> (setting forth AIC mission statement). 19 Interview of David Grosh, former director, American International Center, in Washington, 

D.C. (February 8, 2005). 20 Id. 21 Id. At least one other entity owned or controlled by Scanlon, called the Scanlon Foundation 

for Kids, was later run out of this office. Deposition of Brian Mann, former director, American 

International Center, in Washington, D.C. (March 31, 2005). According to Mann, Scanlon intended the Foundation, which had no employees or physical assets but may have received outside contributions, for only two things: (1) buy books and school supplies for unprivileged children from a particular school and (2) buy, in conjunction with the YMCA, Christmas presents 

for a local ‘‘economically deprived’’ community. Id. 22 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. 

at 35 (June 22, 2005) (testimony of David Grosh, former director, American International Center). At some point, Scanlon had a telephone installed that he instructed Grosh never to answer. 

See Interview of David Grosh, former director, American International Center, in Washington, 

D.C. (February 8, 2005). 23Deposition of Brian Mann, former director, American International Center, in Washington, 

D.C. (March 31, 2005); Interview of David Grosh, former director, American International Center, in Washington, D.C. (February 8, 2005). 24Deposition of Brian Mann, former director, American International Center, in Washington, 

D.C. (March 31, 2005); Interview of David Grosh, former director, American International Center, in Washington, D.C. (February 8, 2005). 25Deposition of Brian Mann, former director, American International Center, in Washington, 

D.C. (March 31, 2005). 26 Id. 27 Id. 28 Id. 

Grosh served as a director of AIC from February through September 2001.17 In his interview with Committee staff, he readily 

conceded that his professional and educational background were 

completely unrelated to the purported mission of AIC of ‘‘enhancing 

the methods of empowerment for territories, commonwealths and 

sovereign nations in the possession of and within the United 

States.’’ 18 He also conceded that his background did not qualify 

him to serve on the board of ‘‘an international think tank.’’ 19

Throughout the time that Grosh served as a director of AIC, he 

thought that ‘‘this was some silly game that Scanlon was playing.’’ 20

Between February and July 2001, ‘‘AIC had no office; AIC’s business address was the beach house that [Grosh] and [yoga instructor 

Brian Mann] rented’’ in Rehoboth Beach.21 In response to a question posed during a Committee hearing about what AIC did, Grosh 

responded that during the four or five months when he was ‘‘involved’’ with AIC, ‘‘we only rented the first floor of a house and installed some computers’’.22

Late in 2001 or early in 2002, Scanlon started talking to Mann 

about possibly working for him.23 Mann was Grosh’s house-mate at 

the time.24 In his deposition, Mann recalls that Scanlon was looking for office space, so Mann set him up with his landlord regarding empty space below where he lived.25 After Mann started working for Scanlon, he came to learn that Scanlon did public relations 

work for Indian casinos.26 In particular, Scanlon claimed he conducted projects intended to help those Tribes with their market 

share.27 In furtherance of these projects, Mann began to research, 

and distribute to other Scanlon employees, articles regarding Scanlon’s Tribal clients.28 In fact, according to Mann, ‘‘researching arti-
182 

29 Id. 30 Id. 31 Interview of David Grosh, former director, American International Center, in Washington, D.C. (February 8, 2005). 32 Id. 33Deposition of Brian Mann, former director, American International Center, in Washington, D.C. (March 31, 2005). 34 Interview of David Grosh, former director, American International Center, in Washington, D.C. (February 8, 2005); See also Deposition of Brian Mann, former director, American International Center, in Washington, D.C. (March 31, 2005). 35 Interview of David Grosh, former director, American International Center, in Washington, D.C. (February 8, 2005). 36 Id. 37 Id. 38Deposition of Brian Mann, former director, American International Center, in Washington, D.C. (March 31, 2005). 39 Capitol Campaign Strategies document production (BB/CCS 023748–49) (September 30, 2001); Capitol Campaign Strategies document production (BB/AIC 000634) (October 30, 2001). 40 Capitol Campaign Strategies document production (BB/CCS 023748) (September 30, 2001). 41 Interview of David Grosh, former director, American International Center, in Washington, D.C. (February 8, 2005). 42 Id. 43 Id. 44 Id. 45 Id. 46Deposition of Brian Mann, former director, American International Center, in Washington, D.C. (March 31, 2005). 

cles is all [he] was doing for AIC or CCS.’’ 29 He was also given the authority to sign checks on behalf of AIC.30

Grosh recalled that Scanlon enticed Mann and him to work for 

AIC by promising, among other things, that AIC would pay for 

both to go surfing at the island of St. Barts.31 Grosh never took 

that trip.32 But, Scanlon paid for Mann to fly to St. Barts about four times.33

Grosh and Mann, who served as AIC’s only directors, recalled that AIC had fewer than five meetings of its board—all of which 

occurred in 2001.34 Grosh recalled that Scanlon characterized those 

meetings as ‘‘a paperwork formality’’.35 Grosh did not recall what, 

if any, business was discussed at those meetings: ‘‘There was nothing to discuss ... As far as I knew, AIC had no business to discuss.’’ 36 Referring to AIC’s being held out as an international think tank, Grosh quipped, ‘‘If AIC was a think tank, I sure don’t know 

what we were thinking about.’’ 37 Mann could only recall discussing 

Scanlon’s acquiring, and his own cleaning, office space for AIC, and 

Grosh’s departure from the organization.38

Records obtained by the Committee indicate that AIC held only 

two board meetings—on September 30 and October 30, 2001.39 Apparently, the ‘‘business’’ they discussed included Grosh’s 

‘‘relinquish[ing] his position’’ with AIC and installing Mann as the 

‘‘Director of day to day [sic] operations of AIC’’, for which he was 

to receive $1500 a month.40

By September 2001, Grosh concluded that ‘‘something was not 

quite right’’: Scanlon had bought two houses in Rehoboth—both of 

which costs millions of dollars.41 Grosh recalls, ‘‘Scanlon was always throwing around money; no one makes that much money over 

such a short period of time.’’ 42 Grosh was also uncomfortable with 

the aspect of Scanlon’s business that related to Indian gaming.43

Therefore, Grosh decided to leave.44 For his ‘‘services,’’ Grosh was 

compensated in total $2,500 to $3,000.45

After Grosh left AIC, Mann was, as far as he knew, its only employee.46 In fact, according to Mann, no one other than Grosh and 
183 

47 Id. 48 Id. 49 Id. 50 Id. 51 Id. 52 Id. 53 Id. 54 Id. 55 Interview of Christopher Cathcart, former associate, Capitol Campaign Strategies, in Washington, D.C. (May 5, 2005). 56Deposition of Brian Mann, former director, American International Center, in Washington, D.C. (March 31, 2005). 57 Id. 58 Interview of Christopher Cathcart, former associate, Capitol Campaign Strategies, in Wash- ington, D.C. (May 5, 2005). 59 Id. 

himself was ever paid by AIC as an employee.47 Moreover, the only 

time Mann recalled Grosh ‘‘ever doing anything was helping me literally put a desk together.’’ 48 Otherwise, he had ‘‘no idea’’ what 

Grosh did.49

Mann, who Scanlon also publicly held out as a director of AIC, 

was (and remains) unsure about exactly what AIC did.50 Mann testified that ‘‘[a]ll [he] knew was that [he] was providing newspaper 

clips,’’ as instructed.51 Mann readily conceded that his professional 

and educational background, like Grosh’s, were completely unrelated to the purported mission of AIC.52 Mann was at AIC until 

late 2002—at which time he started working for CCS and, subsequently, for other Scanlon-controlled entities including Scanlon 

Venture Capital (‘‘SVC’’) and Scanlon Capital Management 

(‘‘SCM’’).53 Convinced that Scanlon was ‘‘a fraud,’’ Mann stopped 

working for SCM in October 2005.54

Christopher Cathcart, who served as Scanlon’s top assistant and 

was therefore in a position to opine about AIC with authority, said 

he considered AIC an alter ego of Scanlon.55 Mann agreed that, although he was getting paid by AIC, he was in fact working for 

Scanlon.56 In his mind, the two were the same.57

C. MAKING IT LOOK REAL—ABRAMOFF HAS AIC POST A WEBSITE

Despite Cathcart’s professed understanding of the nature of AIC, 

he and Abramoff worked together to, among other things, develop 

its website, apparently to make AIC look like a legitimate, established organization. Early in 2002, Scanlon asked Cathcart and 

Amy Biederman, another CCS associate, to help develop a website 

for AIC.58 While Cathcart and Biederman worked on the website’s 

content, Abramoff had an outside contractor program and design 

it.59 Indeed, it appears that Abramoff may have come up with the 

idea for the website—reaching out to a contractor named Benjamin 

Mackler of MackDesign Studios about the prospect of developing it, 

on January 19, 2002: 

Ben, I need to set up a web site for the American International Center, which should have all sorts of goodies to 

make it look real. It should have links to various other 

think tanks, including ISIS in Malaysia, the statehood 

movement in Puerto Rico, Heritage, Americans for Tax Reform, National Center for Public Policy Research, Cato Institute, Toward Tradition. Can you create something? 
184 

60 Email between Jack Abramoff, Greenberg Traurig, and Ben Mackler, Mack Design (no Bates number) (January 19, 2002) (emphasis added). 61 Id. 62 Id. 63 Id. 64 Id. 65 Interview of Christopher Cathcart, former associate, Capitol Campaign Strategies, in Wash- ington, D.C. (May 5, 2005). 66 Id. 67 Id. 68 Id. 69 Id. 70 Id. 71 Id. 72 Email between Christopher Cathcart, Capitol Campaign Strategies, and Jack Abramoff, Greenberg Traurig (no Bates number) (January 31–February 4, 2002). 73 Email from Jack Abramoff, Greenberg Traurig, to Christopher Cathcart, Capitol Campaign Strategies (no Bates number) (February 4, 2002). 74 Email from Jack Abramoff, Greenberg Traurig, to Christopher Cathcart, Capitol Campaign 

Strategies (no Bates number) (February 13, 2002). 

What would the budget be? We’d need a section about 

‘‘who we are’’, ‘‘contact us’’, our leadership, etc.60

In response to a proposal from Mackler to develop a website for 

$2,750, Abramoff asked, ‘‘[C]an you get things moving? Can you see 

what kind of domain name you can get: AIC.org, or 

AmericanInternationalCenter.org?’’ 61

Mackler returned with a request to register a domain name for 

AIC and questions about the website’s design. In response, 

Abramoff answered, ‘‘Yes to all.’’ 62

Subsequently, he instructed Mackler to call Scanlon, who in turn 

told Mackler to contact Cathcart. Mackler turned again to 

Abramoff, saying that Scanlon chose a more expensive option for 

the website.63

Abramoff replied, ‘‘The 3500 option is fine with me. let’s [sic] do 

it.’’ 64

Cathcart testified that ultimately he and Biederman spent only 

about an hour working on the website.65 Cathcart recalled that 

Scanlon provided him with some information that he used for the 

website, including that it was ‘‘an international company’’ with 

‘‘international clients’’—namely Malaysia and Puerto Rico 66. 

Cathcart believed that he may have been given some written material for the website.67 If so, he believed that it would have included 

the articles of incorporation, the bylaws, and other organizational 

documents.68 Cathcart likewise recalled not drafting a mission 

statement, which he said would have been provided to him.69 Otherwise, according to Cathcart, he and Biederman ‘‘didn’t have much 

to go on.’’ 70 Cathcart noted that they gave Scanlon the text that 

they developed for final approval.71 On or about January 21, 2002, 

Abramoff apparently reached out to Cathcart about the website, 

with Cathcart responding, ‘‘10–4. Should have most of the content 

tomorrow.’’ 72

On a request from either Scanlon or Abramoff, on February 4, 

2002, Cathcart forwarded a final copy of the text to Abramoff for 

comments and edits. Abramoff congratulated Cathcart, ‘‘Thanks, 

Chris. I have seen it. great [sic] work. Did Mike [Scanlon] give you 

the list of items the firm wants regarding AIC?’’ 73 On February 13, 

2002, Abramoff followed-up with Cathcart to make sure that 

Mackler got paid.74
185 

75 American International Center (no longer available) <http://www.americent.org/mission.html>. 76See Interview of David Grosh, former director, American International Center, in Washington, D.C. (February 8, 2005); Deposition of Brian Mann, former director, American International Center, in Washington, D.C. (March 31, 2005); Interview of Christopher Cathcart, 

former associate, Capitol Campaign Strategies, in Washington, D.C. (May 5, 2005). 77 American International Center (no longer available) <http://www.americent.org/mission.html>. 78See Interview of David Grosh, former director, American International Center, in Washington, D.C. (February 8, 2005); Deposition of Brian Mann, former director, American International Center, in Washington, D.C. (March 31, 2005); Interview of Christopher Cathcart, 

former associate, Capitol Campaign Strategies, in Washington, D.C. (May 5, 2005). 79 Interview of Christopher Cathcart, former associate, Capitol Campaign Strategies, in Washington, D.C. (November 5, 2004). Supposed AIC director Brian Mann and former Abramoff associate Stephanie Leger Short maintained in their deposition and interview, respectively, that 

Cathcart was by no means a ‘‘go-fer.’’ Deposition of Brian Mann, former director, American 

International Center, in Washington, D.C. (March 31, 2005); Interview of Stephanie Leger 

Short, former associate, Greenberg Traurig, in Washington, D.C. (August 18, 2005). In fact, separately, both described Cathcart as Scanlon’s ‘‘right-hand man.’’ Deposition of Brian Mann, 

former director, American International Center, in Washington, D.C. (March 31, 2005); Interview of Stephanie Leger Short, former associate, Greenberg Traurig, in Washington, D.C. (August 18, 2005) (limiting ‘‘right hand man’’ observation to CCS’ work for Louisiana Coushatta). 

Mann also described Cathcart as ‘‘the manager of the D.C. office’’ and CCS’ ‘‘director of operations.’’ Deposition of Brian Mann, former director, American International Center, in Washington, D.C. (March 31, 2005). Tigua representative Marc Schwartz, who directly interacted with 

Cathcart on the Tribe’s behalf, described Cathcart as Scanlon’s ‘‘gotta-make-what-Scanlon-sold, 

work’’ guy. Interview with Marc Schwartz, president, Partners Group Consultants, in Washington, D.C. (November 10, 2004). Mann insisted that Cathcart ‘‘hired and fired’’ and ‘‘managed 

whatever client situations we had at the time—managed the D.C. office.’’ Deposition of Brian 

Mann, former director, American International Center, in Washington, D.C. (March 31, 2005). 

Moreover, Mann remembered Cathcart ‘‘being the manager, being in charge of the office when 

Scanlon wasn’t there, or even when Scanlon was there, I guess, directing the different folks to 

do what they needed to do.’’ Id. Mann also recalled that Cathcart did ‘‘a lot of client management, like he interacted with the Tribes directly, either through whatever contact people the 

Tribes had or the chiefs or whoever ... that person may have been.’’ Id. From his first-hand experience, Mann also ‘‘assum[ed] [Cathcart had] a hand with Scanlon in coming up with [grassroots 

campaign] strategies and execution of those strategies.’’ Id. Cathcart also provided Mann instruction and guidance on what he should be researching. Id. Mann agreed that ‘‘when Scanlon 

wasn’t around, [Cathcart] was The Man.’’ Id. Mann’s account is corroborated by, among other 

things, Cathcart’s robust role in assisting the Slate of Eight’s successful campaign for the Tribal 

Continued 

In its final form, the website set forth AIC’s mission statement. 

It described AIC as ‘‘a Delaware-based corporation with the global 

minded purpose of enhancing the methods of empowerment for territories, commonwealths, and sovereign nations in possession of 

and within the United States.’’ 75 In each of their depositions and 

interviews with Committee staff, Grosh, Mann and Cathcart said 

they had no idea what this meant.76

The website also touted AIC as (1) ‘‘a premiere international think tank’’; (2) ‘‘determined to influence global paradigms in an increasingly complex world.’’; (3) a ‘‘public policy foundation’’; (4) 

founded ‘‘under the high powered directorship of David A. Grosh 

and Brian J. Mann’’; (5) ‘‘[w]hile only recently incorporated ... striving to advance the cause of greater international empowerment for 

many years’’; (6) ‘‘using 21st century technology and decades of experience to make the world a smaller place’’; (7) ‘‘bringing great 

minds together from all over the globe’’; (8) ‘‘seek[ing] to expand 

the parameters of international discourse in an effort to leverage 

the combined power of world intellect:’’; and (9) comprised of an 

‘‘expert team.’’ 77 To the extent that Grosh, Mann and Cathcart 

could speak to the truth of each of those representations, each 

agreed that they were false.78

During his interview with Committee staff, Cathcart, who described his role at CCS through this period as a ‘‘go-fer’’ and doing 

‘‘research and stuff,’’ 79 admitted to being embarrassed about writ-
186 

Council of the Saginaw Chippewa Indian Tribe, discussed in Part 1, Chapter 3, Section of this 

Report, entitled ‘‘Saginaw Chippewa Tribe of Michigan: ‘Slate of Eight’—Abramoff and Scanlon’s 

Trojan Horse.’’ Dramatic growth in Cathcart’s responsibilities under Scanlon is reflected in the 

considerable increase in his compensation: in April 2001, when Cathcart apparently started 

working with Scanlon, he drew a salary of $44,540 plus an additional $35,000 in bonus. Letter 

from Charles Leeper, Esq., Spriggs & Hollingsworth, to Pablo E. Carrillo, Chief Investigative 

Counsel, Senate Committee on Indian Affairs (November 12, 2004). But, by December 2003, 

when Cathcart left CCS, he received a salary of $105,000, plus a bonus approximating $390,000. 

Id. During his employment with Scanlon, Cathcart received a total of about $740,000 in compensation. See id. 80 Interview of Christopher Cathcart, former associate, Capitol Campaign Strategies, in Wash- ington, D.C. (May 5, 2005). 81 Id. 82 Id. 83 Id. 84 Id. 85Other examples of such activities include Cathcart’s providing the database ‘‘access page’’ that Democracy Data & Communications (‘‘DDC’’) designed for Capitol Campaign Strategies, to 

another vendor. As described above, that vendor apparently used that information, which was 

proprietary to DDC, to develop a far less functional database designed to mimic DDC’s considerably more capable product. Scanlon ‘‘sold’’ the less functional version to at least one of the Tribes 

for millions. Also, on May 1, 2003, as Abramoff and Scanlon’s financial relationship was apparently waning, they schemed to deceive the Louisiana Coushatta into paying them a total of 

$2,000,000. In furtherance of that scheme, which they executed successfully, Scanlon had the 

Tribe pay an entity he controlled called Atlantic Research and Analysis (‘‘ARA’’). This transaction is discussed more fully in Part 2, Chapter 3, Section F, entitled ‘‘Capital Athletic Foundation: In 2003 Abramoff Funnels Tribal Money Through Conduits to CAF.’’ Whether Cathcart 

knew, or should have known, that some of his activities were helping Abramoff and Scanlon further their ‘‘gimme five’’ scheme on the Tribes remains unclear. 86 Interview of Fred Baggett, Chair, National Government Affairs Practice, Greenberg Traurig, in Washington, D.C. (September 29, 2005). 87 Id. 88 Id. (reflecting that Abramoff informed Baggett about AIC). 

ing AIC’s web page but noted that Biederman ‘‘developed the 

puffery.’’ 80 Cathcart never thought a client would see AIC’s website, although he never explained how the website would otherwise be used.81 According to Cathcart, ‘‘[e]veryone who worked with AIC knew it was the same thing as Mike [Scanlon].’’ 82 In his 

interview with Committee staff, Cathcart claimed that he did not 

even know why Scanlon wanted a website.83 Cathcart claimed that 

he thought Scanlon wanted a website ‘‘like he wanted the Range 

Rover.’’ 84 As described below, those Tribes that Abramoff and 

Scanlon directed to pay to and through AIC, did so to their detriment. Therefore, any role that Cathcart may have had in helping 

to facilitate payments by the Tribe to AIC, or to any other ‘‘gimme 

five’’ entity for that matter, may be an area ripe for further inquiry.85

On at least one occasion, Abramoff’s employer, Greenberg Traurig, apparently tried to get information about AIC. Sometime 

in 2002, the director of the firm’s national lobbying practice, Fred 

Baggett, first heard about AIC.86 According to Baggett, Greenberg Traurig was ‘‘to jointly represent [it] with a gentleman named 

Khaled Saffuri’’ on ‘‘Malaysian-related interests and issues.’’ 87 At 

that time, Baggett was unaware of who owned the company; 

Abramoff represented to him that AIC was ‘‘an established Washington area-based think tank like ... the Heritage Center or any 

other number of think tanks.’’ 88 Abramoff also told Baggett that AIC ‘‘had a number of interests and were involved in a broad range 

of issues. One of the issues that they were involved in and for 

which we were retained to assist them with were enhancing business, economic development opportunities in Malaysia, and that 

they were receiving funds from Malaysian business interests to further their and advance their, their efforts with the U.S. Govern-
187 

89 Id. 90 Id. 91 Email from Michael Scanlon, Capitol Campaign Strategies, to Christopher Cathcart, Capitol 

Campaign Strategies (no Bates number) (February 7, 2002). 92 A detailed description of Abramoff’s business relationship with Reed vis-a-vis the Tribes 

and, in particular, how Abramoff relied on Reed to conduct grassroots activities on behalf of his 

Tribal gaming clients, is set forth in Part 1, Chapter 1, Section D, of this Report, entitled ‘‘Mississippi Band of Choctaw Indians: Substantial Fees and Conduit Organizations.’’ 

ment, and that’s what, we were hired by AIC to assist them in 

that.’’ 89

At some point, Greenberg Traurig ‘‘asked Jack to explain [the] 

AIC and the nature of the relationship’’ to ‘‘ensure that we [did] not 

have a problem [with the Foreign Agents Registrations Act 

(FARA)].’’ 90 In that context, it appears that Scanlon withheld important information regarding AIC from the firm. In fact, in a response to queries from Greenberg Traurig to AIC, on February 7, 

2002, Scanlon directed Cathcart to ‘‘[i]nsertr [sic] somewhere’’: 

‘‘While Mr. Abnramoof [sic] and His [sic] team have been an 

unbeleivebal [sic] assest [sic] tou [sic] our organization, we feel that 

if as a vendor of ours if we are presented with such an unexplicalbe 

[sic] line of questioning again, we will unfortuantley [sic] review 

and vote on your continuing representation at our next board meeting.’’ 91 The letter that was apparently sent back to Greenberg 

Traurig was drafted under the signature of one of AIC’s supposed 

directors, Brian J. Mann. Noticeably absent from the letter was 

any indication that Scanlon in fact owned or controlled the company; that the firm’s Tribal clients were making payments directly 

to AIC; or that Abramoff would receive a share of those proceeds 

that the Tribes paid to AIC. This Report explicates each of those 

issues below. 

D. HOW ABRAMOFF AND SCANLON USED CONDUITS TO REPRESENT THE

TRIBES

Just as Abramoff and Scanlon used CCS and the Capital Athletic 

Foundation (‘‘CAF’’) to wrongfully extract ‘‘gimme five’’ proceeds 

from the Tribes so, too, did they use AIC. The Choctaw and, more 

significantly, the Louisiana Coushatta were injured by Abramoff 

and Scanlon’s use of AIC as a ‘‘gimme five’’ vehicle. Understanding 

how Abramoff and Scanlon were able to do so requires understanding, among other things, how historically Abramoff and Scanlon had those Tribes use conduits to implement their grassroots 

strategies. 

As described more fully in those sections of this Report addressing the Choctaw and the Louisiana Coushatta, from 1998 through 

2001, Abramoff and Scanlon had each Tribe use conduits to implement their grassroots campaigns. Over time, those Tribes became 

accustomed to (1) paying substantial fees for their grassroots activities and (2) paying those fees to or through conduits. 

As those sections indicate, the vendor that Abramoff and Scanlon 

used, and relied on, the most to implement those campaigns was 

former Christian Coalition Executive Director and political strategist Ralph Reed.92 While working with Abramoff from 1999 

through 2001, Reed conducted a variety of grassroots activities in 

support of the interests of Abramoff gaming clients, including, telemarketing (patch-through, tape-recorded messages and call-to-ac-
188 

93 Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to [REDACTED] (GTG– 

E000018933) (May 10, 1999). 94The Louisiana Coushatta made this payment through Southern Underwriters, an apparently moribund insurance firm owned or controlled by former Louisiana Coushatta casino CEO 

Aubrey Temple. A discussion of this transaction is contained infra in Part 1, Chapter 2, entitled 

‘‘Coushatta Tribe of Louisiana.’’ 

tion phone calls), targeted mail, legislative counsel and local management, as well as rallies and petitions. 

A May 10, 1999, email between Abramoff and one of his assistants indicates that Preston Gates sent payments to Reed totaling 

$1,303,903, apparently from Abramoff’s clients.93

But, by 2001, Abramoff or Scanlon had the Tribes using conduits 

which they owned or controlled, most notably AIC. As the following 

reflects, from 2001 through 2003, Abramoff or Scanlon directed 

both the Choctaw and the Louisiana Coushatta to pay AIC a total 

of $6,308,854. 

PAYMENTS FROM LOUISIANA COUSHATTA AND CHOCTAW TO AIC 

Choctaw Payments to AIC 

1. 2/27/01 .............................................................................................. $200,000 

2. 4/9/01 ................................................................................................ 150,000 

3. 5/2/01 ................................................................................................ 175,000 

4. 5/11/01 .............................................................................................. 960,654 

1,485,654 

1. 2/22/02 .............................................................................................. 1,000,000 

2. 12/11/02 ............................................................................................ 170,000 

1,170,000 

Total ................................................................................................. 2,655,654 

Louisiana Coushatta Payments to AIC 

1. 3/16/01 .............................................................................................. 400,000 

2. 3/21/01 .............................................................................................. 258,000 

3. 3/30/01 .............................................................................................. 298,000 

4. 4/27/01 .............................................................................................. 397,200 

5. 4/9/03 ................................................................................................ 2,300,000 

Total ................................................................................................. 3,653,200 

Grand Total of Payments from Louisiana Coushatta and 

Choctaw to AIC .................................................................... 6,308,854 

The following 94 suggests that in 2001 and early 2002 much of 

that money ultimately went to entities owned or controlled by 

Reed. 

PAYMENTS BY SCANLON-CONTROLLED ENTITIES TO REEDCONTROLLED ENTITIES

Payments from AIC to Reed-Controlled Entities 

3/16/01 .............. Century Strategies ................................................. $45,000 

3/16/01 .............. Century Strategies ................................................. 350,000 

3/16/01 .............. Century Strategies ................................................. 50,000 

3/16/01 .............. Century Strategies ................................................. 100,000 

3/22/01 .............. Century Strategies ................................................. 200,000 
189 

95See, e.g., Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg Traurig (Bates number 001139446) (November 25, 2001). This email indicates that 

Scanlon at least proposed to conduct many of the grassroots activities that Reed first provided 

for Abramoff’s Tribal lobbying clients. In describing what he intended to do for the Choctaw on 

a particular grassroots project, Scanlon told Abramoff: ‘‘[H]ere are the broad strokes of what I 

am going to do. I am putting our own field operation in [REDACTED] to cover all three sites. 

I am turinimg [sic] on phones hitting reps and dems [sic], I am launching a negative ad campaign against [REDACTED] and [REDACTED], and others. This will be big, and now that the 

slots are in, its gonna take some time to be effective.’’ On December 10, 2001, Abramoff expressed concern about the budget requests Reed wanted him to submit to his Tribal clients: 

‘‘Ralph, they are going to faint when they see these numbers. They will want to know why we 

have not built up any residual strength for the tons of money we have already spent. Give me 

some ammo on that and I’ll do my best.’’ Email from Jack Abramoff, Greenberg Traurig, to 

Ralph Reed, Century Strategies (GTG–E000019059) (December 10, 2001). 96 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000023792) (December 18, 2001). 

4/03/01 .............. Century Strategies ................................................. 198,000 

4/20/01 .............. Century Strategies ................................................. 100,000 

4/30/01 .............. Century Strategies ................................................. 398,000 

5/02/01 .............. Century Strategies ................................................. 100,000 

5/10/01 .............. Century Strategies ................................................. 750,000 

Total .......... ................................................................................... $2,291,000 

Payments from CCS to Reed-Controlled Entities 

6/29/01 .............. Century Strategies ................................................. 100,000 

7/01/01 .............. Capitol Media .......................................................... 618,000 

7/16/01 .............. Century Strategies ................................................. 46,350 

8/1/01 ................ Century Strategies ................................................. 47,000 

11/08/01 ............ Capitol Media .......................................................... 100,000 

11/09/01 ............ Capitol Media .......................................................... 350,000 

12/31/01 ............ Century Strategies ................................................. 250,000 

2/19/02 .............. Capitol Media .......................................................... 51,679 

2/25/02 .............. Capitol Media .......................................................... 60,000 

2/25/02 .............. Capitol Media .......................................................... 100,000 

Total .......... ................................................................................... $1,723,029 

Grand Total of all Payments by Scanlon-Controlled Entities to Reed-Controlled 

Entities 

Grand Total ................................................................................... $4,014,029 

As the foregoing indicates, from March through May 2001, AIC 

paid one of Reed’s companies, called Century Strategies, 

$2,291,000. And, from June 2001 to February 2002, another Scanlon-controlled entity, CCS paid Century Strategies and another 

company owned by Reed called Capitol Media $1,723,029, for a 

total of $4,014,029. 

But, as early as November 2001, things had begun to change. 

With a history of successful grassroots projects behind them and 

Abramoff or Scanlon having had the Tribes pay to or through entities that they owned or controlled, they apparently began to 

squeeze Reed out and started to keep most of the money paid by 

the Tribes for themselves.95

By December 18, 2001, Abramoff appeared resolved to pushing 

Reed out, writing to Scanlon, ‘‘Next year, we need to give [Reed] 

a pittance and we need to keep most of this ourselves.’’ 96

On January 4, 2002, Abramoff and Scanlon expressed concerns 

about work that Reed did for one of their Tribal clients. About that 
190 

97 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign Strategies (GTG–E00001817) (January 4, 2002). 98 Id. (emphasis in original). 99 Id. 100 Id. 101 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign Strategies (Bates number 305641) (January 8, 2002). 102 Id. 103 Id. 104 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000018505) (February 7, 2002). On July 23, 2002, Reed provided Abramoff 

with information that suggested the need to launch a grassroots campaign to squelch support 

for a casino in DeSoto Parish, Louisiana. Seeing a business opportunity for himself and Scanlon, 

Abramoff told Scanlon, ‘‘Forget Ralph, but this poll is very interesting. Can you get to [Louisiana Coushatta Tribal Council member] William [Worfel] and get us some $ so we can fight 

this?’’ Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000020112) (July 23, 2002). Similarly, on July 24, 2002, with a Texas federal 

judge having shut down the Alabama-Coushatta’s casino in Livingston, Reed provided Abramoff 

with information about the possibility that the Alabama-Coushatta might launch a legislative 

initiative to have its casino reopened. Seeing a potential business opportunity, Abramoff immediately forwarded the information to Scanlon: ‘‘Forget about Ralph, but you should call [Louisiana Coushatta Chairman] Lovelin [Poncho] and [Tribal Council member] William [Worfel] ... 

and claim victory on this one, but warn that the [Alabama-Coushatta] are not going away ... 

we need more $$$$.’’ Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol 

Campaign Strategies (GTG–E000020107) (July 24, 2002). 

project, Scanlon asked, ‘‘Did Ralph spend all them [sic] money he 

was given to fight this—or does he have some left?’’ 97

Abramoff responded, ‘‘That’s a silly question! He ‘‘spent’’ it all the 

moment it arrived in his account. He would NEVER admit he has 

money left over. Would we?’’ 98

Scanlon replied, ‘‘No—but Id [sic] like to know what the hell he 

spent it on—he didn’t even know the dam [sic] thing was there— 

and didn’t do shit to shit [sic] to shut it down!’’ 99

Abramoff decreed, ‘‘I agree. He is a bad version of us! no [sic] 

more money for him.’’ 100

Days later, on January 8, 2002, while reviewing their ‘‘gimme 

five’’ income for January 2002, Abramoff had an idea as to how he 

and Scanlon could dramatically reduce their overhead. His suggestion intended to completely cut out Reed: ‘‘[W]e are spending over 

$10M with other people! We have to buy mail house, phone house, 

etc. so we get part of that one too!!’’ 101

Scanlon agreed, ‘‘[Y]our [sic] right—we have to move fast to lock 

in phones and—mail. I think we can cut 5mil [sic] right off the top 

of our outgoing expenses that way just to start.’’ 102

Abramoff concurred, ‘‘Let’s do it fast so we can stop throwing 

away money.’’ 103

By early 2002, Abramoff’s business arrangement with Reed visa-vis his Tribal clients seemed to have run its course. Regarding 

a $50,000 payment to Reed for work supporting the Choctaw, on 

February 7, 2002, Abramoff admonished Scanlon to ‘‘go ahead and 

pay him so I can get him off my back.’’ 104 Documents in the Committee’s possession reflect that the last payment Abramoff made to 

Reed, through any entity owned or controlled by Scanlon, regarding 

any of Abramoff’s Tribal clients, was on or about February 25, 

2002. 

Under the original paradigm, most of the money these Tribes 

paid (at Abramoff or Scanlon’s request) to or through conduits 

seemed to have gone to grassroots activities conducted or coordinated by Reed—with a percentage taken by Reed as a ‘‘manage-
191 

105Documents, however, indicate that at least with respect to one project, Reed received more than simply the management fee he itemized on his invoices: apparently, he and an individual 

named Neal Rhoades shared additional commissions derived from profits that were built into 

costs charged by vendors (associated with Reed) to Preston Gates, which were likely expensed 

to the Tribes. Ralph Reed document production (no Bates number) (undated) (‘‘Preston Gates— 

[REDACTED] Gambling Project Reconciliation as of June 13, 1999’’). Those vendors apparently 

included, among others, National Media and Millennium Marketing. Id. 106 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Choctaw, Mis- sissippi (April 27–29, 2005). 107 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E0001321307) (May 2, 2001). 108 Email from Jack Abramoff, Greenberg Traurig, to Gail Halpern, May & Barnhard, P.C. 

(GTG–000012166) (March 28, 2003). 109 Capitol Campaign Strategies document production (BB/LC 007325) (April 18, 2003). The request in this memorandum (4/18) appears to have resulted in the Louisiana Coushatta’s payment of $2,300,000 to AIC (on or about 4/9). So, the date of this document relative to the date 

of the resulting payments suggests that the date on the memorandum is probably a typographical error. 110 Interview with Kathryn Van Hoof, former counsel, Coushatta Tribe of Louisiana, in Lecompte, Louisiana (September 21, 2005). 

ment fee’’ or similar charge.105 But after February 2002, without the Tribes’ knowledge or consent, most of the money that they paid 

to or through those entities went into Abramoff’s and Scanlon’s 

pockets—with only a fraction going to the underlying grassroots effort. Having been accustomed to paying high fees for grassroots 

work in the past, the Tribes were not suspicious.106 How Abramoff 

and Scanlon succeeded in using AIC in furtherance of their ‘‘gimme 

five’’ scheme is discussed below. 

E. AIC AS A ‘‘GIMME FIVE’’ ENTITY

As early as May 2001, Abramoff and Scanlon were extracting ‘‘gimme five’’ income from payments made by the Choctaw through 

AIC. Abramoff informed Scanlon then, ‘‘[REDACTED] is active 

again. I am going to try to get us $175K. $100K to Ralph; $25K 

to contributions ($5K immediately to Conservative Caucus); rest 

gimme five.’’ 107

But, the Tribe that would be most injured as a result of its pay- ments to AIC would be the Louisiana Coushatta. With his businesses and private charity apparently facing financial difficulty, on 

March 30, 2003, Abramoff told his tax advisor Gail Halpern that 

he expected some money to come in: ‘‘I have $1M coming in (I hope 

directly to CAF or Eshkol) probably next week, and $1M due within the next 2 weeks to Kaygold. Both from CCS. How long will this 

money last both for the school and the restaurants?’’ 108 Needless 

to say, all this would be Tribal money. Ultimately, Abramoff decided not to use CCS; they elected to use AIC. And, to induce the Louisiana Coushatta into paying AIC, 

Scanlon wrote then-Tribal Councilman William Worfel in a Strategy Memorandum, on or about April 18, 2003, ‘‘We sent you and 

[sic] Invoice [sic] from the AIC which is merely an entity I direct 

which was used to conduct public relations activities for various clients. As we discussed, the AIC will pay for operations conducted 

by CCS (myself and my team) and Jack or others vendors and 

staff.’’ 109

So, on or about April 9, 2003, the Louisiana Coushatta paid AIC 

$2,300,000. But, the Tribe was never told that payments made by 

the Tribe to AIC would go to Scanlon and Abramoff.110 Quite the 

contrary, from Abramoff, Louisiana Coushatta Tribal representatives understood that AIC was an entity that supported anti-gam-
192 

111 Id. 112Diehl & Company document production (D00411–512) (undated) (General Ledger, Capitol 

Campaign Strategies). 113 Id. 114These entries are taken from CCS’ accounting ledger and cross-referenced with other information in the possession of the Committee. Of all vendor transactions reflected in the ledger, 

only vendor transactions greater than or equal to $25,000 or traceable to any Tribe are included. 

ing efforts, which the Tribe could support.111 The Tribe was misled: 

on April 13, 2003, AIC paid Abramoff $991,000, through his alter 

ego, Kaygold.112

In an April 18, 2003, strategy memorandum, Scanlon also told 

Worfel, ‘‘[o]n the financial side, the lion’s share of your effort this 

year is for database build up, and voter targeting, and staff time. 

We currently have seven staff members working on this project including myself. Most of the staff will be exclusively working on 

your program for the rest of the year. Jack is also involved heavily 

on a daily/weekly basis.’’ Scanlon’s suggestion to Worfel about 

where the ‘‘lion’s share’’ of the Tribe’s money would go was also 

misleading: on April 22, 2003, Scanlon routed the $1,300,000 left 

over from the Tribe’s $2,300,000 payment to AIC, to CCS.113

AMERICAN INTERNATIONAL CENTER ACCOUNT SNAPSHOT 

Date Description To/From Amount 

4/1/2003 ............. Balance .................................................. ................................................................ $14,900.13 

4/9/2003 ............. Wire Transfer ......................................... Coushatta .............................................. 2,300,000.00 

4/13/2003 ........... Check 1103 ........................................... Kaygold .................................................. (991,000.00 ) 

4/18/2003 ........... Check 1113 ........................................... Scanlon .................................................. (15,000.00 ) 

4/22/2003 ........... Wire Transfer ......................................... CCS ........................................................ (1,300,000.00 ) 

4/29/2003 ........... Closing Balance .................................... ................................................................ 1,083.93 

From there, between May 1, 2003, and May 5, 2003, Scanlon executed a series of shareholder draws for apparently purely personal 

expenses that completely extinguished the Tribe’s payment to AIC. 

Those transactions are explicated below.114

CAPITOL CAMPAIGN STRATEGIES ACCOUNT SNAPSHOT 

Date Description To/From Amount 

4/1/2003 ............. Balance .................................................. ................................................................ $1,062,845.58 

4/14/2003 ........... Taxes Payable ........................................ DC .......................................................... (214,018.00 ) 

4/21/2003 ........... Shareholder Draw .................................. Scanlon .................................................. (100,000.00 ) 

4/22/2003 ........... Wire Transfer ......................................... Coushatta/AIC ........................................ 1,300,000.00 

4/22/2003 ........... Prof. Campaign; LA ............................... Basswood Research ............................... (15,600.00 ) 

5/1/2003 ............. Balance .................................................. ................................................................ 1,844,678.59 

5/1/2003 ............. Shareholder Draw; .................................

25 Tidewater; 2310 ...............................

Tony Beto, Inc. ....................................... (21,594.00 ) 

5/1/2003 ............. Shareholder Draw; 2311 ........................ Dockety Design ...................................... (88,724.00 ) 

5/2/2003 ............. Shareholder Draw; 2312 ........................ Lin Sang Logistics ................................. (150,000.00 ) 

5/5/2003 ............. Shareholder Draw .................................. Michael Scanlon .................................... (150,000.00 ) 

5/5/2003 ............. Shareholder Draw .................................. Michael Scanlon .................................... (991,000.00 ) 

5/5/2003 ............. Balance .................................................. ................................................................ 427,174.71 

As the foregoing indicates, there were five such ‘‘shareholder 

draws’’: May 1, 2003, to Tony Beto, Inc. for $21,594; May 1, 2003, 

to Dockety Design for $88,724; May 2, 2003, to Lin Sang Logistics 

for $150,000; and two payments, dated May 5, 2003, to Michael 

Scanlon for $150,000 and $991,000. 
193 

115See Brian Reynolds-Hughes, Proposed $35M amphitheater coming to Sussex?, Cape Gazette, December 31, 2002, http://www.beachpaper.com/storiesmorgue/arts/2003arts/ 

amphitheater121302.html; Chris Barrish, Abramhoff cohort spent millions on Sussex homes, The 

News Journal, May 14, 2006, <http://www.delawareonline.com/apps/pbcs.dll/article?AID=/ 

20060514/NEWS/605140367/1006>. 116Planetblueprints.com ‘Custom Homes For a More Beautiful Planet’ (visited February 14, 2006) <http://planetblueprints.com/html/aboutlus.html>; Rehoboth Beach business directory (visited Feb. 14, 2006) <http://www.rehobothbeach.com/buslbuildersremodel.asp>. 117Offsetting Expenses with Aircraft Management, Executive Flyer Magazine, Spring 2003, <http://executiveflyer.com/EFMagazine/Vol2lIssue1/OffsettingExplEd.htm>. 118Peter H. Stone, K Street Stumble, National Journal, March 27, 2004, at 958–63. 119During her interview with Committee staff, former Abramoff associate Stephanie Leger 

Short testified, ‘‘[T]he public line was that the [AIC] was a think tank; the real line was that 

that’s how Jack did work for Malaysia and Eritrea.’’ Interview of Stephanie Leger Short, former 

associate, Greenberg Traurig, in Washington, D.C. (August 18, 2005). Looking back, Leger 

opined that Abramoff did work for Malaysia and Eritrea through AIC to avoid registering under 

FARA. Id. According to documents and financial records in the Committee’s possession, the Embassy of Malaysia made four payments of $300,000 each to AIC, on June 29, 2001, October 5, 

2001, January 3, 2002, and March 13, 2002. Almost immediately afterwards, AIC made payments to an individual named Khaled Saffuri in the amount of $90,000, $45,000, and $45,000 

on October 8, 2001, January 3, 2002, and March 20, 2002 respectively, apparently for ‘‘salary/ 

consulting’’ purposes regarding Malaysia. Soon thereafter, each one of those payments was followed by an additional disbursement of $100,000, $210,000, $245,000, and $255,000 to Greenberg Traurig on July 5, 2001, October 8, 2001, February 22, 2002, and February 26, 2002, respectively. 

Saffuri appears to have been a lobbyist at an Abramoff owned or controlled entity called the 

Lexington Group. At one time, Saffuri was reportedly the Assistant Executive Director of the 

American Muslim Council (‘‘AMC’’), where he apparently served as a lobbyist. See Greenberg 

Traurig document production (GTG007370–JA–P) (March 27, 2001). The AMC was apparently 

founded in 1990 by Abdurahman Mohamed Alamoudi, an open supporter of Palestinian terror 

organization Hamas. Id. A few years ago, Alamoudi was implicated in a plot to assassinate the 

Saudi Crown Prince Abdullah. See Department of Justice (visited October 15, 2004) <http:// 

www.usdoj.gov/opa/pr/2004/October/04lcrml698.htm> (describing Abdurahman Alamoudi’s 

sentencing in a Terrorism Financing Case). 

The Committee has been able to locate a Tony Beto in Lewes, Delaware. Apparently an architect, Beto has been described as having knowledge and experience with zoning procedures, particularly 

in Sussex County, Delaware, where Scanlon made some major real 

estate purchases.115 Likewise, the Committee found a company called Dockety Design Construction, a single-family housing contractor located in Rehoboth Beach, Delaware. Apparently, it specializes in home remodeling and new home building.116 Finally, the Committee located a company called Linsang Logistics LLC in Silver Spring, MD. Apparently Linsang creates technology-based companies ‘‘that expand global access to information’’ and charters its 

private jet.117 Given that the foregoing charges are likely unrelated to any work done for the Louisiana Coushatta, they are likely purely personal in nature. With the original $2,300,000 that the Louisiana Coushatta paid AIC just about entirely extinguished, the 

Committee has seen no evidence that the Tribe received the intended benefit for this very large payment. According to media reports, Scanlon and Abramoff may have used AIC for other illicit purposes, including circumventing requirements under the Foreign Agents Registration Act (‘‘FARA’’), 

particularly with respect to the Embassy of Malaysia.118 However, 

those activities are unrelated to the Tribes’ allegations of misconduct. Accordingly, while the Committee has information corroborative of some of those media reports, 119 the Committee has 

arrived at no definitive conclusions regarding those activities. 

F. CONCLUSION

Among the more interesting of Abramoff and Scanlon’s ‘‘gimme 

five’’ entities, that is, entities owned or controlled by Abramoff or 
194 

Scanlon that they used in their kickback scheme, is the putative 

international think tank, AIC. With two of Scanlon’s beach buddies 

sitting on its board, AIC’s purpose was actually to collect fees associated with activities conducted by others and, in some cases, divert 

those fees to entities owned or controlled by Scanlon or Abramoff. 

In other words, AIC was a sham. From 2001 through 2003, the 

Choctaw and the Louisiana Coushatta collectively paid AIC about 

$6,308,854. While much of this money went to vendors who actually conducted grassroots activities for the Tribes, such as Ralph 

Reed, as the Tribes had intended, millions were not used for that 

purpose. 
(195) 

CHAPTER III 

CAPITAL ATHLETIC FOUNDATION 

ABRAMOFF: The package on the ground is $4K per person. 

that [sic] covers rooms, tee times and ground transportation. One idea is that we could use one of my foundations for the trip—Capital Athletic Foundation—and get 

and make contributions so this is easier. OK? 

REED: OK but we need to discuss. It is an election year. 

Email between Jack Abramoff and Ralph Reed concerning golfing junket to Scotland, May 15, 2002 

RUDY: Jack wants this. 

BOULANGER: What is it? I’ve never heard of it. 

RUDY: It is something our friends are raising money for. 

BOULANGER: I’m sensing shadiness. I’ll stop asking. 

Email between Todd Boulanger and Tony Rudy concerning suggested Tribal contributions to CAF, June 20, 2002 

BOZNIAK: He [CAF funds recipient Shmuel Ben Svi] did 

suggest that he could write some kind of letter with his 

Sniper Workshop Logo and letter head. It is an ‘‘educational’’ entity of sorts. 

ABRAMOFF: no [sic] I don’t want a sniper letterhead. 

Email between Jack Abramoff and Allison Bozniak, September 19, 2002 

A. INTRODUCTION

At its hearings over the past two years, the Committee disclosed 

and discussed evidence that Jack Abramoff might have used Capital Athletic Foundation (‘‘CAF’’), his private charitable foundation, 

in ways grossly inconsistent with its tax exempt status and mission. Based on multiple interviews and records, the Committee conclusively finds that (1) CAF was simply another vehicle in 

Abramoff and Scanlon’s ‘‘gimme five’’ scheme; (2) Indian tribes paid 

CAF, directly and indirectly, knowingly and unknowingly, approximately $3,657,000; and, (3) Abramoff treated CAF as his own personal slush fund, apparently using it to evade taxes, finance lobbying activities such as a golfing trip to Scotland, purchase paramilitary equipment, and for other purposes inconsistent with CAF’s 

tax exempt status and stated mission. 

In fact, in court filings associated with Abramoff’s guilty plea in 

January 2006, Abramoff pled guilty to, among other things, misusing CAF ‘‘to receive income and make expenditures for his own 

personal benefit’’ and ‘‘to conceal this income from the Internal 
196 

1Plea Agreement, Factual Basis for the Plea, at para. 37, U.S. v. Jack A. Abramoff (Dist. D.C., 

January 3, 2006) (CR–06–001). 2 Id. 3 Id. at para. 26. 4See Capital Athletic Foundation, 2001, 2002, and 2003 Return of Private Foundations Form 

990PF; and Internal Revenue Service (visited May 25, 2004) <http://www.irs.gov> (excerpt of 

exempt organization search). Interestingly, on March 2, 2000, CAF changed its name to National Institute of Torah, but, on August 17, 2000, changed its name back to CAF. 5 Id. 6Other Abramoff and/or Greenberg Traurig clients apparently donated during those years. In 2001, Foxcom Wireless allegedly donated $50,000. In 2002, SPI Spirits (Cyprus) allegedly donated $25,000. 7 Capital Athletic Foundation (visited June 7, 2004) <http://www.capathletic.org>. 8 Id. (emphasis added). 

Revenue Service and others.’’ 1 In his plea agreement, Abramoff 

further admitted that he ‘‘knew that these activities constituted a 

misuse of these tax exempt entities.’’ 2 For example, Abramoff confessed that he solicited money from the Saginaw Chippewa Indian 

Tribe of Michigan (‘‘Saginaw Chippewa’’) and a distilled beverages 

company, SPI Spirits, ‘‘to partially pay for a golfing trip to Scotland 

for himself, public officials, members of his staff and others.’’ 3

This Chapter will examine the nature and structure of CAF. For 

all years in which CAF received, directly or indirectly, Tribal funds, 

this Chapter will examine the circumstances surrounding the payments, and then review how Abramoff spent CAF’s funds. 

B. GENERAL BACKGROUND ON CAF

Abramoff registered CAF with the Internal Revenue Service as 

a 501(c)(3) exempt private foundation.4 At all relevant times, 

Abramoff and his wife were the only managing members of CAF.5

CAF reported on its 2001 and 2002 federal tax forms that four (4) 

Native American Tribes donated a total of $2,075,000: 6

REPORTED PAYMENTS BY TRIBES TO CAPITAL ATHLETIC FOUNDATION (CAF) 

2001 ........ Coushatta Tribe of Louisiana ............................................................................... $1,000,000 

2002 ........ Mississippi Band of Choctaw Indians ................................................................. $1,000,000 

Saginaw Chippewa Indian Tribe .......................................................................... $25,000 

Alabama Coushatta Entertainment Center .......................................................... $50,000 

Total ......................................................................................................................... $2,075,000 

To the general public, CAF described itself as a youth charity in 

Washington, D.C.7 According to its website, no longer extant, CAF 

purportedly: 

promotes the ideals of sportsmanship by recognizing individuals and organizations across the economic spectrum 

that exemplify the highest values of honorable, civil and 

ethical behavior in their endeavors. The Foundation 

awards grants to support needy and deserving programs 

and activities that develop sportsmanship, and designates 

appropriate individuals as national Ambassadors of 

Sportsmanship. The Foundation also awards grants that 

specifically support sportsmanship programs and activities 

which serve disadvantaged youth.8

The website continued: 
197 

9 Id. (emphasis added). 10 Interview of Fred Baggett, Chair, National Government Affairs Practice, Greenberg Traurig, 

in Washington, D.C. (September 29, 2005); see also Interview of Stephanie Leger Short, former 

associate, Greenberg Traurig, in Washington, D.C. (August 18, 2005). 11 Interview of Fred Baggett, Chair, National Government Affairs Practice, Greenberg Traurig, 

in Washington, D.C. (September 29, 2005). Stephanie Leger, a former Greenberg Traurig employee, told the Committee that it was well known around the office that CAF was Abramoff’s 

personal charity. Interview of Stephanie Leger Short, former associate, Greenberg Traurig, in 

Washington, D.C. (August 18, 2005). 12 Interview of Fred Baggett, Chair, National Government Affairs Practice, Greenberg Traurig, 

in Washington, D.C. (September 29, 2005); Interview of Stephanie Leger Short, former associate, 

Greenberg Traurig, in Washington, D.C. (August 18, 2005). 13 Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to James Kaplan (GTG– 

E000087920–21) (October 23, 2000). 14The Committee has not determined who James Kaplan was, and what his relationship was 

with Congresswoman Morella and Jack Abramoff. 15 Apparently, the name Abramoff originally contemplated for the charity was the Capital 

Education and Athletic Foundation. 16 Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to James Kaplan (GTG– 

E000087920) (October 23, 2000). 17 Id. 18 Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to James Kaplan (GTG– 

E000087924) (October 23, 2000). The Committee has seen no evidence that Congressman DeLay 

knew or authorized what Abramoff and Rudy were attempting. 

[t]he mission of the Capital Athletic Foundation is to foster 

character development by promoting the American ideals 

of sportsmanship in all endeavors. These ideals include integrity, honor, brotherhood, morality, leadership and good 

citizenship. Sportsmanship is ethical behavior both on and 

off the playing field; both in athletics and in business; both 

as a youth and as an adult.9

Abramoff similarly described CAF to his colleagues. Fred 

Baggett, a managing shareholder of Greenberg Traurig and chairman of its national governmental affairs practice, recalled that the 

‘‘CAF Foundation was something that Jack referred to a number of 

occasions that he and his wife were very much involved in to support inner-city children in sports ventures and sports opportunities.’’ 10 Although Abramoff disclosed that he and his wife were 

CAF’s founders, he gave the impression to Baggett that it ‘‘had 

grown into a credible, respectable charitable foundation.’’ 11 What 

Abramoff did not disclose, however, was how he was actually funding and operating CAF.12

C. ABRAMOFF ATTEMPTS TO SECURE FEDERAL FUNDING FOR CAF, AND

FAILS

In 2000, it appears that Abramoff initially sought to capitalize 

CAF with a $5,000,000 federal earmark.13 In attempting to enlist 

the aid of then-U.S. Representative Connie Morella, Abramoff told 

one Jim Kaplan 14 that ‘‘the DeLay guys want to put this grant 

through for the Capital Education and Athletic Foundation 

[CEAF],15 which will be a grantor organization to help build the 

Yeshiva in Kemp Mill.’’ 16 Abramoff apparently believed the earmark could be included in the Labor-HHS Appropriations Conference Report or the VA–HUD Appropriations Conference Report.17 Abramoff confessed that Congressman DeLay might not 

know about it, but that ‘‘Tony [Rudy] [Delay’s then-Deputy Chief 

of Staff] and the staff are working it through for them.’’ 18 Abramoff 
198 

19 Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to pj@morella.com 

(GTG–E000087929) (October 23, 2000). 20 Email from Jack Abramoff, Preston Gates Ellis & Rouvelas Meeds, to Tony Rudy, Office 

of Congressman Tom DeLay (GTG–E000087925) (October 23, 2000). 21 Capital Athletic Foundation, 2001 Return of Private Foundations Form 990PF. 22 Capitol Campaign Strategies document production (BB/LC 017923–26) (October 23, 2001). 23 Id. 24 Id. 25 Id. (emphasis in original). 26 Id. 

even sent an email to a representative of Congresswoman Morella 

and claimed that the CEAF ‘‘is a worthy cause, and not a client.’’ 19

After speaking with a Morella representative, Abramoff advised 

Tony Rudy: ‘‘Tony, I spoke with her guy today and they are going 

to try to get us a letter. Please let me know what we do next.’’ 20

However, after reviewing CAF’s bank, accounting, and tax records, 

the Committee concludes that CAF never received a federal grant 

of any amount. Furthermore, the Committee has seen no evidence 

establishing that Representative Morella supported Abramoff in 

any way on this project. 

Unable to obtain his earmark, Abramoff would turn to other 

means to finance CAF. 

D. ABRAMOFF AND SCANLON MISAPPROPRIATE TRIBAL FUNDS FOR CAF

SEED MONEY IN 2001

1. Abramoff and Scanlon Divert Louisiana Coushatta Money to 

CAF 

In 2001, the single largest contributor by far listed on CAF’s federal tax return was the Coushatta Tribe of Louisiana (‘‘Louisiana 

Coushatta’’) for $1,000,000.21 The Committee finds, however, that 

the Tribe never intended to make a charitable contribution to CAF. 

Rather, Abramoff and Scanlon deceived the Louisiana Coushatta 

into making that payment as part of their ‘‘gimme five’’ scheme. 

Scanlon set the scam in motion with an October 23, 2001, memorandum to Louisiana Coushatta counsel Kathryn Van Hoof, in 

which he proposed three political programs, which he collectively 

dubbed the ‘‘Battleground Program.’’ 22 The program was purportedly designed to stop potential competitors, such as ‘‘Delta Downs 

and Pinnacle’’ from infringing on the Louisiana Coushatta casino’s 

market share 23 According to Scanlon, the Tribe’s money would be 

used for everything from polling to opposition research to phone 

banking and Get Out The Vote efforts.24

Scanlon claimed the money was necessary to manipulate Christian conservatives. In Scanlon’s words: ‘‘Simply put we want to 

bring out the wackos to vote against something. ... The wackos get 

their information form [sic] the Christian right, Christian radio, 

mail, the internet and telephone trees.’’ 25 In fact, Scanlon advised 

using nearly half the proposed budget to influence and mobilize 

‘‘Christian conservatives and minority religious outlets.’’ 26

Abramoff and Scanlon had other designs for the money. One day 

after Scanlon’s memorandum to Van Hoof, Abramoff told Scanlon: 

‘‘I want to see if we can pump up our LDA [reporting requirements 

under the Lobbying Disclosure Act] for the second half to make 

sure we don’t fall out of the top ten [lobbying firms]. I can achieve 
199 

27 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign Strategies (GTG–E000012245) (October 24, 2001). 28 Id. 29 Id. 30 Email from Michael Scanlon, Capitol Campaign Strategies, to Kathryn Van Hoof, Coushatta 

Tribe of Louisiana (GTG–E000011383) (October 25, 2001). 31 Id. 32Greenberg Traurig document production (GTG–E000011384) (undated). 33 Interview of Fred Baggett, Chair, National Government Affairs Practice, Greenberg Traurig, in Washington, D.C. (September 29, 2005). 34 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee On Indian Affairs, 109th Cong. at 37 (November 2, 2005) (testimony of Fred Baggett, Chair, National Government Affairs Practice, Greenberg Traurig). 35 Id. 

this if I can run some of the money for the Coushattas through the 

firm and then get it to CCS.’’ 27

Concerned, Scanlon asked: ‘‘Are u [sic] sure Baggett will let you 

rip it back out?’’ 28

Abramoff responded, ‘‘If not, it’ll be a cold day in hell that they 

get this check from my grubby hands!’’ 29

To convince the Tribe to pay $1,000,000 into Greenberg Traurig, 

Scanlon explained to Van Hoof, ‘‘We broke this into two invoices— 

one to be paid to Greenberg Traurig for 1m, and one paid to Capitol Campaign Strategies—[Greenberg Traurig’s] public affairs entity for the balance. We usually just invoice you through Capitol 

Campaign Strategies so the Lawyers at the firm rest easy while we 

are out burning the country side.’’ 30

He continued, ‘‘In this instance however we plan to do some 

things through the law firm umbrella due to their highly sensitive 

nature and confidentiality reasons. I hate hiding behind lawyers— 

but we are going to do some crazy stuff on this one—so I guess its 

ok:) :) [sic]’’ 31

In furtherance of the ‘‘gimme five’’ scheme, Scanlon apparently 

fabricated and submitted to the Louisiana Coushatta an invoice in 

Greenberg Traurig’s name. The invoice identified the purpose of 

the payment as ‘‘Public Affairs Services.’’ 32 Contrary to Scanlon’s 

representations, Capitol Campaign Strategies (‘‘CCS’’) was not 

Greenberg Traurig’s public affairs entity.33 Nor was Scanlon authorized to prepare or send an invoice on Greenberg Traurig’s behalf.34 At the November 2, 2005 hearing before the Committee, 

Baggett testified: 

THE CHAIRMAN: Was Mr. Scanlon authorized to send an invoice on Greenberg Traurig’s behalf? 

MR. BAGGETT: No, sir; he was not. 

... 

MR. BAGGETT: —the invoice exhibit 99 purporting to be 

from Greenberg Traurig, ‘‘Greenberg’’ is misspelled. 

THE CHAIRMAN: Okay. That is an important point. Thank 

you for bringing it up, Mr. Baggett. [Laughter.] 

MR. BAGGETT: I doubt we would be issuing an invoice with 

our name misspelled.35

Despite the lack of authorization, the Committee finds that Scanlon sent, or caused to be sent, the fabricated invoice to the Louisiana Coushatta for payment. 

Based on Scanlon’s representations, the Tribe understood the 

$1,000,000 payment to Greenberg Traurig would be used for the 
200 

36 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee On Indian Affairs, 109th Cong. 

at 37 (November 2, 2005) (testimony of Kathryn Van Hoof, former counsel, Coushatta Tribe of 

Louisiana). 37 Interview of William Worfel, former Vice Chairman, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 38 Interview of Kathryn Van Hoof, former counsel, Coushatta Tribe of Louisiana, in Lecompte, Louisiana (September 23, 2005); Interview of William Worfel, former Vice Chairman, Coushatta 

Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 39 Interview of Kathryn Van Hoof, former counsel, Coushatta Tribe of Louisiana, in Lecompte, Louisiana (September 23, 2005); Interview of William Worfel, former Vice Chairman, Coushatta 

Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 40 Id. 41Greenberg Traurig document production (GTG023510–ACCT) (October 30, 2001). 42 Interview of Fred Baggett, Chair, National Government Affairs Practice, Greenberg Traurig, in Washington, D.C. (September 29, 2005). 43 Id. 44 Email from Jack Abramoff, Greenberg Traurig, to Fred Baggett, Greenberg Traurig (GTG– 

E000252969) (November 5, 2001). 

Tribe’s political activities, and certainly never intended for it to be 

a charitable contribution: 

THE CHAIRMAN: Ms. Van Hoof, was it your understanding 

that the $1 million was going to be used for political activities benefitting the tribe? 

MS. VAN HOOF: Yes. 

THE CHAIRMAN: Did the tribe authorize anyone to use that 

$1 million as a charitable contribution to the Capital Athletic Foundation? 

MS. VAN HOOF: No. 

THE CHAIRMAN: Did the tribe ever intend to make a $1 

million contribution to Jack Abramoff’s personal charity? 

MS. VAN HOOF: No.36

William Worfel, former Vice Chairman of the Tribe, similarly 

told the Committee that the Tribal Council had never authorized 

that $1,000,000 to be used as a charitable contribution—to CAF or 

any other entity.37 Indeed, neither Van Hoof nor Worfel had any 

contemporaneous knowledge of CAF.38 At no point did Scanlon or 

Abramoff tell the Louisiana Coushatta that its money would be 

used for anything other than the Tribe’s political activities.39 In 

fact, until the Committee’s investigation, the Louisiana Coushatta 

did not even know it was listed as a $1,000,000 donor to CAF.40

Based on Scanlon’s misrepresentations, on October 30, 2001, the 

Louisiana Coushatta executed a check for $1,000,000 to Greenberg 

Traurig.41 On November 2, 2001, Greenberg Traurig received the 

$1,000,000 check, which it deposited into its trust account.42

The next phase of the scheme required Abramoff to deceive his 

former employer, Greenberg Traurig. To extract the money from 

Greenberg Traurig’s trust account, Abramoff told the firm that the 

Louisiana Coushatta knew about the payment to CAF and had authorized it.43 On November 5, 2001, Abramoff sent an email to 

Baggett entitled ‘‘Coushatta million dollar check,’’ and noted, ‘‘It is 

burning a hole in my pocket. Please let’s chat about this today to 

get it worked out.’’ 44 Sometime around that email, Abramoff called 

Baggett in Tallahassee, ‘‘to talk about a contribution that a tribe, 

the Coushatta, that a tribe wanted to make to Capital Athletic 

Foundation, that they had given us a check for a million dollars 

and wanted to put it in a trust account so we could give it to Cap-
201 

45 Interview of Fred Baggett, Chair, National Government Affairs Practice, Greenberg Traurig, in Washington, D.C. (September 29, 2005). 46 Id. 47 Id. 48 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg Traurig (GTG–E000012276) (November 7, 2001). 49 Capital Athletic Foundation, 2001 Return of Private Foundations Form 990PF. 50 Id. There appears to be a discrepancy in the tax return. Statement 5 to the return cites 

$115,930 as the expenses spent on home school program expenses. 51 Id. 52See Peter Stone, Tribes Gave To Abramoff Foundation, National Journal, March 12, 2004, 

at 1866; Michael S. Gerber and Albert Eisele, Republican power broker Jack Abramoff on lobbying in the Bush II era, The Hill, March 26, 2003; see also Email from Gail Halpern, May & Barnhard, to Susan Baker (MB–002124) (September 27, 2002). 53See Eshkol, Inc., 2001 Form 990. Eshkol’s tax return is signed by Sam Hook as executive 

director for the school. Hook is a former contract employee at Greenberg Traurig, the husband 

of Shana Tesler, and owner and president of two other Abramoff-controlled entities, Grassroots 

Continued 

ital Athletic Foundation.’’ 45 Per Abramoff’s direction, Greenberg Traurig paid the Louisiana Coushatta’s $1,000,000 to CAF.46

The Committee finds that the Louisiana Coushatta’s $1,000,000 

never went to the Tribe’s political activities. It instead padded the 

coffers of CAF for Abramoff’s discretionary use. Notably, Abramoff 

did include the $1,000,000 on the Lobbying Disclosure Act filing for 

the Louisiana Coushatta in 2001.47

The Committee harbors no doubt that the $1,000,000 was a pay- ment obtained as part of the duo’s ‘‘gimme five’’ scheme. In a November 7, 2001, email entitled ‘‘Give me five,’’ Scanlon listed 

Abramoff’s take from their scheme: 

The overall numbers in the amounts I owe you are exactly 

$1 million smaller that [sic] what we projected last month 

because your section of the Louisiana Battleground program was paid directly to [Greenberg Traurig]—so I took 

the whole thing of [sic] the chart. I did leave it on the distribution chart so you can see what the ‘‘value’’ of your 

share to date—approximately 5.4 mill. [sic] has gone to 

your [sic] or third party entities at your direction.48

2. Abramoff’s Misuse of CAF Funds in 2001 

Despite receiving $1,248,741 in purported contributions, CAF distributed very little in the form of grants to other entities in 2001— 

only $50,510.49 From the relevant bank records, it appears that 

Abramoff segregated most of the Tribal money into its own account 

and reserved it for use in the following year. From another account, 

into which others such as Foxcom Wireless had paid, CAF made a 

number of expenditures. 

The largest outlay for CAF in 2001 appears to be for operating 

and administrative expenses: 

• $102,510 for ‘‘home school program which combines academic 

and athletic programs for the students.’’ 50

• $50,510 for log and web design and newspaper advertising for 

the benefit of the Eshkol Academy.51 The Eshkol Academy was an 

all boys Jewish orthodox prep school that Abramoff founded in 

2001, but closed in 2003.52 Abramoff’s relationship with Eshkol was 

intimate: he was the president and his wife was the vice president, 

secretary, and treasurer.53 Media reports also claim that some of 

Abramoff’s children attended Eshkol. 
202 

Interactive, LLC and Federal Program Services, LLC. According to Tesler, Abramoff hired Hook 

to serve as interim executive director of Eshkol Academy in November 2002. She stated that 

Hook was paid $20,000 for serving as the interim director, and the payments may have come 

from the Capital Athletic Foundation. 54May & Barnhard document production (MB–002063–65) (December 31, 2001). 55 Id. 56 Capital Athletic Foundation, 2001 Return of Private Foundations 990PF; see also May & 

Barnhard document production (MB–002063–65) (December 31, 2001). 57See Email between Jack Abramoff, Greenberg Traurig, and Shmuel Ben Zvi, Kollel Ohel 

Tieferet (GTG–E000089141–44) (October 18–19, 2001). 58 Email between Jack Abramoff, Greenberg Traurig, and Shmuel Ben Zvi, Kollel Ohel Tieferet (GTG–E000080536–37) (July 15–16, 2003). 59See Email between Jack Abramoff, Greenberg Traurig, and Shmuel Ben Zvi, Kollel Ohel Tieferet (GTG–E000089141–44) (October 18–19, 2001). 60 Id. 61 Id. 

• $3,411.32 for ‘‘Eshkol and Lexington Group work.’’ CAF’s ledger identifies the purpose of the payment as brochures and business 

cards. The Lexington Group was a for-profit venture that Abramoff 

undertook with a lobbyist named Khaled Saffuri and has no apparent role in CAF or its purported charitable mission. 

• Almost $99,000 on consulting fees, 54 which, on information 

and belief, related to Abramoff’s efforts to establish Eshkol. 

• $26,060 for a school van. The records do not indicate whether 

the van was actually used for personal or charitable purposes. 

• $10,000 payment to Sports Suites as a deposit.55 The Sports 

Suites was a limited liability company that Abramoff owned and 

operated and through which he leased various club boxes at several 

sporting venues around the region, including FedEx Field, MCI 

Center, and Camden Yards. Abramoff used the boxes extensively in 

his lobbying practice. 

Curiously, listed on CAF’s 2001 tax form is an $18,057 expenditure for a thermal imager.56 CAF’s tax and accounting records do 

not indicate what possible relation a thermal imager would have to 

the charitable mission of CAF, or to whom it was given. Abramoff’s 

emails, however, illuminate the purpose and beneficiary of 

Abramoff’s largesse. 

For two days in 2001, Abramoff exchanged emails with a person 

the Committee has determined is Shmuel Ben Zvi.57 Ben Zvi and 

Abramoff were classmates at Beverly Hills in California.58 Apparently, Ben-Zvi later moved to the Israeli West Bank. The Committee does not know how Ben Zvi and Abramoff re-established 

ties. 

Nevertheless, in 2001, Abramoff and Ben Zvi tried to find a 

source for a thermal imager.59 Abramoff and Ben Zvi apparently 

intended the thermal imager for paramilitary application, because 

Ben Zvi told Abramoff that ‘‘[t]he paratroop officer in charge of the 

area, that you see in the photo with me that I sent you is very 

happy that we’ll have the thermal imager.’’ 60

Ben Zvi added, ‘‘[I]f it looks like it will take a long time to get 

the Russian model, then we can actually use our army address to 

buy the U.S. made thermal imager and have a colonel or higher 

sign for it. ...’’ 61

The next day, trying to find a way to obtain the imager, Ben Zvi 

suggested that he could fax a letter ‘‘stating that I am purchasing 

this equipment for the IDF [Israeli Defense Force], and at the same 

time get a signed letter from the commander of Paratroop bragade 
203 

62 Id. 63 Capital Athletic Foundation, 2002 Return of Private Foundations, Form 990PF. 64 Id. 65 Id. 66May & Barnhard document production (MB–002063–65) (December 31, 2001); May & Barnhard document production (MB–001940–41) (January-December 2002). 67 Email between Jack Abramoff, Greenberg Traurig, and Ralph Reed, Century Strategies (GTG–E000019854) (May 15, 2002). 68 Id. 69 Email from Jack Abramoff, Greenberg Traurig, to Tony Rudy, Greenberg Traurig (GTG– E000026455) (June 6, 2002). 

[sic]. ...’’ 62 Although CAF’s tax return indicates that Abramoff apparently purchased the thermal imager, the Committee has no further details about the transaction. 

E. IN 2002, ABRAMOFF AND SCANLON SCAM OTHER TRIBES INTO

PAYING INTO CAF

In 2002, reported contributions to CAF climbed to $2,569,934. 

CAF listed a number of substantial contributors for that year: 

• Saginaw Chippewa Indian Tribe—$25,000 

• Alabama-Coushatta Entertainment Center—$50,000 

• National Center for Public Policy Research—$450,000 

• Jack Abramoff—$991,749 

• Mississippi Band of Choctaw Indians–$1,000,000 63

The Committee finds that most of those alleged contributions— 

even those not in the name of an Indian Tribe—are the fruits of 

Abramoff and Scanlon’s ‘‘gimme five’’ scheme. 

1. Abramoff Deceives the Saginaw Chippewa Indian Tribe Into Partially Funding a Golfing Trip to Scotland—June Through November 2002 

In 2002, CAF claimed $234,319 in expenses for travel, conferences, and meetings on its tax return.64 Yet, according to that 

same tax filing, Abramoff and his wife, the only two co-managing 

members, devoted ‘‘minimal’’ time each week to their positions.65

CAF’s tax, accounting, and bank records, suggest that $166,634.26 

of that $234,319 were costs incurred for a golfing trip to Scotland.66

On or about May 15, 2002, Abramoff and his old friend and business associate Ralph Reed began planning the trip. In an email entitled ‘‘Scotland,’’ Abramoff wrote to Reed: 

The package on the ground is $4K per person. that [sic] 

covers rooms, tee times and ground transportation. One 

idea is that we could use one of my foundations for the 

trip—Capital Athletic Foundation—and get and make contributions so this is easier.67

Reed replied, ‘‘OK but we need to discuss. It is an election 

year.’’ 68

Soon thereafter, Abramoff began seeking financing for the golfing 

trip. Abramoff asked his colleague Tony Rudy, Congressman 

DeLay’s former deputy chief of staff, ‘‘Hi Tony. Did you get the 

message from the guys that Tom wants us to raise some bucks 

from Capital Athletic Foundation? I have six clients in for $25K. 

I recommend we hit everyone who cares about Tom’s requests.’’ 69
204 

70 Id. 71 Email from Tony Rudy, Greenberg Traurig, to Jack Abramoff, Greenberg Traurig (GTG– 

E000026450) (June 7, 2002). 72 Email between Jack Abramoff, Greenberg Traurig, and Tony Rudy, Greenberg Traurig 

(GTG–E000076673) (June 17, 2002). 73 Id. 74See Email between Todd Boulanger, Greenberg Traurig, and Tony Rudy, Greenberg Traurig 

(GTG–E000254778–79) (June 20, 2002). 75 Id. 76 Id. 77 Id. 78 Id. 79 Id. 80 Id. 81 Id. 82 Email from Jack Abramoff, Greenberg Traurig, to Christopher Petras, Saginaw Chippewa Tribe of Michigan (GTG–E000026791) (September 30, 2002); Email from Jack Abramoff, Greenberg Traurig, to Christopher Petras, Saginaw Chippewa Tribe of Michigan (GTG–E000057439) 

(August 12, 2002). 83 Email from Jack Abramoff, Greenberg Traurig, to Christopher Petras, Saginaw Chippewa Tribe of Michigan (GTG–E000026653) (July 31, 2002). 

Abramoff then asked Rudy to ‘‘email [Christopher] Petras on the 

Sag chip request (it’ll look better coming from you as a former 

DeLay COS). We’z gonna make a bundle here.’’ 70

Rudy subsequently requested Petras’ email address.71

Later that month, Abramoff again asked Rudy, ‘‘Please hit them 

both [Stoli and Sag Chip] to get checks for the Capital Athletic 

Foundation asap. we [sic] need to get this cash in hand. I am pushing Tigua and Choctaw. We are still short of full cost coverage 

(which is around $115K).’’ 72

Rudy responded, ‘‘Please give me [the] address.’’ 73

Abramoff and Rudy soon began seeking money for the Scotland 

golfing trip in earnest.74 In an email entitled ‘‘Capitol Athletic 

Foundation,’’ Rudy asked Todd Boulanger, another Abramoff associate and the manager of the Saginaw Chippewa Indian Tribe 

(‘‘Saginaw Chippewa’’) lobbying account at Greenberg Traurig, 

‘‘Can you ask [C]hris [Petras] whether they can make a contribution. We asked for 25k.’’ 75

Apparently unfamiliar with CAF, Boulanger inquired: ‘‘What is 

this? I can put this on your Coushatta request list that I’m putting 

together during the July 4th recess ... or I can split it up 1⁄2 to 

Coushatta and 1⁄2 to Choctaw so it doesn’t dilute your other requests. Sag may kick in ... 25K is steep for them. I bet they’d do 

$5k, however. We’ll get it.’’ 76

Rudy cryptically responded, ‘‘Jack wants this.’’ 77

Boulanger inquired further, ‘‘What is it? I’ve never heard of it.’’ 78

Rudy was again vague: ‘‘It is something our friends are raising 

money for.’’ 79

Boulanger finally desisted: ‘‘I’m sensing shadiness. I’ll stop asking.’’ 80

Rudy confirmed Boulanger’s suspicions, ‘‘Your senses are good. If 

you have to say Leadership is asking, please do. I already have.’’ 81

Soon thereafter, Abramoff began hounding the Tribe for the payment.82 Examples include the following: 

• On July 31, 2002, Abramoff reminded Petras ‘‘about getting the Capital Athletic Foundation to me asap per the delay 

request.’’ 83
205 

84 Email from Jack Abramoff, Greenberg Traurig, to Christopher Petras, Saginaw Chippewa Tribe of Michigan (GTG–E000057439) (August 12, 2002). 85 Email from Jack Abramoff, Greenberg Traurig, to Christopher Petras, Saginaw Chippewa Tribe of Michigan (GTG–E000026714) (August 23, 2002). 86 Email from Jack Abramoff, Greenberg Traurig, to Christopher Petras, Saginaw Chippewa Tribe of Michigan (GTG–E000026766) (September 4, 2002). 87 Email from Jack Abramoff, Greenberg Traurig, to Christopher Petras, Saginaw Chippewa Tribe of Michigan (GTG–E000026784) (September 12, 2002). 88 Email from Jack Abramoff, Greenberg Traurig, to Christopher Petras, Saginaw Chippewa Tribe of Michigan (GTG–E000026805) (September 18, 2002). 89 Email from Jack Abramoff, Greenberg Traurig, to Christopher Petras, Saginaw Chippewa Tribe of Michigan (GTG–E000026791) (September 30, 2002). 90Saginaw Chippewa Indian Tribe of Michigan document production (no Bates number) (enti- tled ‘‘Minutes of the Tribal Council Special Session’’) (August 22, 2002). 91 Capital Athletic Foundation document production (SEN–CAF 000681) (November 13, 2002). 92 Email between Christopher Petras, Saginaw Chippewa Tribe of Michigan, to Jack Abramoff, 

Greenberg Traurig; Holly Bowers, Greenberg Traurig; and Jennifer Boice, Greenberg Traurig 

(GTG–E000027002) (November 14, 2002). 93 Capital Athletic Foundation document production (SEN–CAF 000681) (November 13, 2002). 94 Email between Jack Abramoff, Greenberg Traurig, and Maury Litwack, Greenberg Traurig 

(GTG–E000001280–81) (November 19–20, 2002). 

• On August 12, 2002 he asked Petras to ‘‘get me that $25K to Capital Athletic Foundation for the DeLay thing.’’ 84

• On August 23, 2002, Abramoff asked Petras ‘‘any progress on the Capital Athletic Foundation?’’ 85

• On September 4, 2002, Abramoff asked Petras: ‘‘any 

progress.’’ 86

• On September 12, 2002, Abramoff asked Petras about 

CAF, ‘‘Please keep me informed on this one.’’ 87

Throughout the process, Abramoff continued misrepresenting CAF as an independent entity. In a September 18, 2002 email entitled ‘‘where are we on the Capital Athletic Foundation,’’ Abramoff 

advised Petras, ‘‘I saw the CAF guys this morning and we are getting into a bit of an embarrassing situation.’’ 88 Again, on Sep- tember 30, 2002, Abramoff told Petras that ‘‘I am getting serious 

pressure on the Capital Athletic Foundation. Please let me know 

if this is going to happen, and if not, I need to try and find a replacement. I am really out of time on this and am getting called 

daily.’’ 89

In procuring the money from the Tribe, Abramoff apparently misrepresented the nature of CAF and how it would use the funds. 

According to internal Saginaw Chippewa documents, Abramoff represented that CAF ‘‘creates programs that teach leadership skills 

to disadvantaged youth in the DC area in an effort to keep them 

off the streets and enhance their educational opportunities.’’ 90

Finally, on November 13, 2002, the Saginaw Chippewa wrote a check to CAF in the amount of $25,000.91 On November 14, 2002, 

Abramoff received the Saginaw Chippewa check for CAF.92

Abramoff had the check deposited on November 18, 2002.93

Abramoff apparently concealed from the Saginaw Chippewa that 

CAF was his personal charity. After the Saginaw Chippewa donated $25,000 to CAF, Abramoff instructed Maury Litwack, a legislative assistant at Greenberg Traurig, to draft a thank you letter 

to the Tribe, and to sign it as the Program Director.94 The Committee has not been able to verify whether the letter was actually 

sent and received. 

Abramoff used the $25,000 from the Saginaw Chippewa and another $50,000 from the Alabama Coushatta, to partially finance a 

widely publicized golfing trip to Scotland. Regarding these dona-
206 

95Plea Agreement, Factual Basis for the Plea, at para. 7, U.S. v. Jack A. Abramoff (Dist. D.C., 

January 3, 2006) (CR–06–001). 96Plea Agreement, Factual Basis for the Plea, at para. 17, U.S. v. Tony C. Rudy (Dist. D.C., 

March 31, 2006) (CR–06–082) 97 Id. 98 Capital Athletic Foundation, 2002 Form 990PF. 99May & Barnhard document production (MB–001948) (December 31, 2002). 100 Email from Jack Abramoff, Greenberg Traurig, to Laura Lippy, Greenberg Traurig, and Rodney Lane Greenberg Traurig (GTG–E000114360) (December 27, 2001). 101 Email from Gail Halpern, May & Barnhard, to Jack Abramoff, Greenberg Traurig (GTG– E000010719) (January 3, 2002). 

tions, both Abramoff and Rudy pled guilty to defrauding the Saginaw Chippewa. According to Abramoff’s plea agreement: 

From June 2002 to November 2002, Abramoff and a 

former lobbying colleague, who was also a former congressional staffer (‘‘Staffer A’’) successfully solicited the Michigan Tribe for a $25,000 payment to CAF. Instead of using 

the funds for CAF, Abramoff used this money for his personal and professional benefit to partially pay for a golfing 

trip to Scotland for himself, public officials, members of his 

staff, and others.95

Rudy pled similarly: 

In June 2002, Rudy, at Abramoff’s direction, solicited one 

of Firm B’s clients, a Native American Tribe in Michigan, 

for a $25,000 contribution to CAF made by check ... by 

falsely claiming that a public official requested them to solicit funds for the charity from their clients. Abramoff and 

Rudy intended to use this money for their personal and 

professional benefit to partially pay for a golfing trip to 

Scotland for Abramoff, Rudy, Representative #1, members 

of his staff and others, which Rudy ultimately did not attend.96

Notably, Rudy admitted in his plea agreement that he solicited 

money from the Saginaw Chippewa ‘‘by falsely claiming that a public official [DeLay] requested them to solicit funds for the charity 

from their clients.’’ 97

2. Abramoff and Scanlon Deceive the Mississippi Band of Choctaw 

Indians Into Sending $1,000,000 to CAF—January and August 

2002 

CAF’s 2002 Form 990PF listed the Mississippi Band of Choctaw 

Indians (‘‘Choctaw’’) as its biggest contributor—at $1,000,000.98 According to CAF’s accounting ledger, the Tribe made two payments: 

(1) $500,000 on January 3, 2002; and, (2) $500,000 on August 6, 

2002.99 The Committee finds, however, that Abramoff and Scanlon 

deceived the Tribe into paying that $1,000,000 into CAF for uses 

the Tribe never intended. 

On December 19, 2001, Scanlon sent the Choctaw an invoice purportedly from CAF for $500,000 for ‘‘Professional Services Rendered.’’ Barely one week later, Abramoff was looking for the money. 

He asked Laura Lippy and Rodney Lane, two of his associates, 

‘‘[d]id we ever get the [sic] $500K for Cap Athletic from Choctaw 

per Scanlon?’’ 100 The payment actually arrived a few days after the 

New Year.101
207 

102 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000110037) (March 3, 2002). 103 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000110065) (March 13, 2002). 104 Id. 105 Id. 106 Id. 107 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E00010056) (March 30, 2002). 108 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg 

Traurig (GTG–E000110088) (April 1, 2002). 109 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000110224) (May 23, 2002). 110 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (GTG–E000110212) (May 29–30, 2002). 111 Id. 112 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign 

Strategies (Bates number 1735978) (June 12, 2002). 

Within two months, Abramoff and Scanlon began chasing the 

Choctaw for their next score for CAF. On March 3, 2002, Abramoff 

instructed Scanlon: ‘‘See if you can get [Nell Rogers] to send my 

share to Capital Athletic Foundation. She liked using that entity 

anyway. This is for the next payment, not the last one.’’ 102

Scanlon continued to be the prime actor, while Abramoff skulked 

in the shadows. Abramoff asked Scanlon, ‘‘Can you have one of the 

upcoming payments from Choctaw (or one of the others) made to 

‘‘Capital Athletic Foundation’’ up to $500K? I need to get more 

money in there.’’ 103

Scanlon agreed, ‘‘I will do it.’’ 104 And, he offered to go even further, ‘‘there is another payment coming due—I can get 1 mil in 

there in about two weeks—IS [sic] that ok?’’ 105

Abramoff, however, replied that ‘‘$500k is enough’’ for CAF.106

As time passed, and the Choctaw’s money did not arrive, 

Abramoff again asked Scanlon to get it done, and this time for 

more money. In an email entitled ‘‘Capital Athletic Foundation’’, 

Abramoff reminded Scanlon ‘‘Please don’t forget this one. $1M in 

there would be good if that’s the amount you can get Nell [Rogers] 

to send.’’ 107

Scanlon assured Abramoff, ‘‘I’ll approach her on this today.’’ 108

Nearly two months later, the money had still not arrived. Consequently, over the next few weeks, Abramoff badgered Scanlon to 

have the Tribe make the payment: 

• On May 23, Abramoff asked Scanlon to ‘‘find out what’s up 

with the Choctaw’s payment to CAF’’.109

• On May 29, Abramoff asked Scanlon, ‘‘Where are we on 

this? I did not get the CAF check.’’ 110

• On May 30, Abramoff again asked, ‘‘Anything happen with 

this yet?’’ 111

Abramoff became desperate, suggesting to Scanlon that he ‘‘call 

Nell [Rogers] today and push her on the $500K for CAF’’ and instructing Scanlon ‘‘to tell her that they [CAF] spent the money already with the trust that they’d get it, and that they are all over 

you now.’’ 112

Abramoff apparently grew increasingly frustrated by Scanlon’s 

failure to secure the money for him. In an email entitled ‘‘Choctaw 
208 

113 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000110378) (July 1, 2002). 114 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign Strategies (GTG–E000057339–40) (July 5, 2002). 115 Id. 116 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000110378) (July 10, 2002). 117 Email between Jack Abramoff, Greenberg Traurig, and Laura Lippy, Greenberg Traurig, to Jack Abramoff, Greenberg Traurig (GTG–E000110548) (August 6, 2002); see also May & Barnhard document production (MB–001948) (December 31, 2002). 118 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee On Indian Affairs, 109th Cong. at 17 (June 22, 2005) (testimony of Nell Rogers, planner, Mississippi Band of Choctaw Indians). 119 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Philadelphia, Mississippi (April 27–29, 2005). 120 Id. 121 Id. 122 Id. 

CAF!’’, Abramoff implored Scanlon, ‘‘Mike, what do we have to do 

to get this money in?’’ 113

When the money had still not arrived, Abramoff suggested to 

Scanlon that he tell Nell Rogers at Choctaw that they were ‘‘going 

to lose the ability to use this group [CAF] as a front if we don’t 

get this current.’’ 114 Scanlon agreed to do so.115 Abramoff followed 

up a few days later, asking Scanlon ‘‘Can you call her again 

today?’’ 116 Finally, on August 6, 2002, a $500,000 check for CAF 

arrived from the Choctaw.117

Despite being listed as CAF’s largest donor, the Choctaw never 

intended to make a charitable contribution to CAF. During the 

June 2005 hearing before the Committee, Rogers, who dealt with 

Abramoff and Scanlon, testified: 

THE CHAIRMAN: Ms. Rogers, in 2002 the Capital Athletic 

Foundation, Mr. Abramoff’s private charitable foundation, 

reported on its tax forms that the Mississippi Band of 

Choctaw Indians was far and away the single biggest contributor ... Michael Scanlon and Jack Abramoff directed 

the tribe to make these contributions? 

MS. ROGERS: These were not intended as contributions, 

Senator. They were intended to be pass-throughs to other 

groups doing grassroots public advocacy work for the tribe. 

THE CHAIRMAN: In other words, the tribe did not know 

that 70 percent of these moneys were going to—— 

MS. ROGERS: Not at all. They were never intended to be 

contributions. 

THE CHAIRMAN: Jack Abramoff and Michael Scanlon never 

told you that the Capital Athletic Foundation was Mr. 

Abramoff’s private charity? 

MS. ROGERS: No.118

At all relevant times, the Tribe intended that the payments to 

CAF would pass through to grassroots organizations working to oppose the expansion of gaming in the Choctaw casino’s customer 

market.119 At no time did Abramoff or Scanlon advise the Choctaw 

that CAF would keep any part of the money, as a charitable contribution or otherwise.120 Rogers was disgusted that Abramoff 

would not only abuse the Tribe’s trust, but also use a charity to do 

it.121

Neither Abramoff nor Scanlon ever told the Tribe that CAF was 

a charitable organization.122 The Tribe was led to believe that CAF 
209 

123 Id. 124 Id. 125 Id. 126 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee On Indian Affairs, 109th Cong. at 29–30 (June 22, 2005) (testimony of Amy Ridenour, president, National Center for Public Policy Research). 127 Id. 128 Id. 129 Id. 130 Id. 

‘‘was another one of Mike’s entities that was a vehicle to be used 

as a pass-through to grassroots groups.’’ 123 Rogers understood that 

CAF was ‘‘something conveniently set up to use for pass-through 

activities.’’ 124 Before the Committee’s investigation, the Tribe had 

no idea that Abramoff was using CAF to finance the Eshkol Academy.125 Based on its review of CAF’s Form 990PFs, accounting 

ledger, profit and loss statements, and other accounting records, 

the Committee finds that CAF paid none of the Choctaw’s funds to 

grassroots organizations and vendors as the Tribe had intended. 

3. Abramoff and Scanlon Misappropriate Another $1,000,000 From 

the Choctaw—October 2002 

Abramoff and Scanlon’s diversion of Choctaw funds, intended by 

the Tribe for political purposes, did not end there. In October 2002, 

Abramoff and Scanlon successfully deceived the Tribe into paying 

another $1,000,000, nearly half of which went to CAF. To accomplish this, Abramoff betrayed not just the Tribe, but also two longtime friends, and violated his fiduciary duty to a non-profit organization on whose board he sat. 

According to its president, Amy Ridenour, the National Center 

for Public Policy Research (‘‘NCPPR’’) is ‘‘a 23-year-old conservative 

free market non-profit institution.’’ 126 Abramoff joined the 

NCPPR’s board in 1997.127 Ridenour told the Committee that ‘‘[a]t 

that time, I had known Jack for nearly 17 years. He was a dedicated conservative, a successful lobbyist and businessman, and his 

managerial skills it seemed to me at the time exceeded my 

own.’’ 128 Abramoff introduced Ridenour and NCPPR to Chief Martin and the Choctaw in 1997.129

Five years later, in October 2002, Abramoff used his position as 

an NCPPR director to further carry out his and Scanlon’s ‘‘gimme 

five’’ scheme. Abramoff apparently sowed the seeds months earlier 

at lunch with Ridenour and her husband at Abramoff’s restaurant 

Signatures.130 Ridenour testified before the Committee: 

Jack shared with us details of his work doing what he 

called ‘‘a new kind of lobbying.’’ He said he and his colleagues working with the Mississippi Choctaws had noted 

that for-profit non-Indian gaming establishments were 

pushing to establish themselves in areas of the Country 

not noted for their admiration of gaming. They believed 

that a public backlash against gaming was brewing and 

that before things came to a head, perhaps 4 to 5 years 

down the road, they would educate the public about the 

Choctaw success story. 

I was very interested in what I was hearing. I noted that 

his new kind of lobbying was not lobbying at all, but edu-
210 

131 Id. 132 Id. 133 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (Bates number 1636313) (October 1, 2002). 134 Interview of Nell Rogers, planner, Mississippi Band of Choctaw Indians, in Philadelphia, Mississippi (April 27–29, 2005). 135 Id. 136 Id. 137 Id. 138 Id. 139 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee On Indian Affairs, 109th Cong. at 30 (June 22, 2005) (testimony of Amy Ridenour, president, National Center for Public Policy 

Research). 140Greenberg Traurig document production (Bates number 1640098) (October 10, 2002). 141 Email between Jack Abramoff, Greenberg Traurig, and Amy Ridenour, National Center for Public Policy Research (Bates number 1640097) (October 10, 2002). 142 Id. 143Greenberg Traurig document production (Bates number 1640097–99) (October 10, 2002). 

The Committee observes that this invoice is similar in form and content to the invoices Scanlon 

sent on his companies’ behalf, usually just identifying ‘‘Professional Services’ as the reason for 

the payment request. 

cational work and I expressed an interest in the National 

Center sponsoring it. Jack seemed mildly agreeable, but 

noncommittal. I did not press the matter, assuming the 

Choctaws were financing the project and would have to approve our involvement.131

Nothing happened for four months.132 Then, on October 1, 

Abramoff told Scanlon, ‘‘Amy Ridenour has asked if we can run any 

funds through them to pump up their non email donations (they 

will give us back 100%). Let’s run some of the non-caf Choctaw 

money through them to the camans [sic].’’ 133

To induce the Tribe into making the payment, Abramoff told them that the money would be used for their grassroots activities. 

In her interview with Committee staff, Rogers said that the Tribe 

paid $1,000,000 to the NCPPR at Abramoff’s direction.134 The 

Tribe intended and understood that the money would pass-through 

the NCPPR to grassroots organizations and vendors trying to defeat the expansion of gaming into the Choctaw casino’s customer 

market.135 Ralph Reed’s firm Century Strategies was among the firms that, Abramoff assured Rogers, would ultimately receive part 

of the $ 1,000,000.136 The Tribe never intended any part of that $1,000,000 to go to CAF, Abramoff, Scanlon, or any other entity 

owned or controlled by Abramoff or Scanlon.137 Until the Committee’s investigation, the Tribe did not know that Abramoff and Scanlon had diverted the $1,000,000 for their own personal use and 

benefit.138

Thus, on October 10, 2002, at Abramoff’s direction, NCPPR drew 

up a $1,000,000 invoice.139 The invoice Ridenour prepared listed as 

its purpose ‘‘contribution to the National Center for educational 

and research programs and activities.’’ 140 Ridenour sent the invoice to Abramoff by email.141 That was not the invoice that the 

Choctaw received, however. 

Abramoff forwarded NCPPR’s original invoice to Scanlon.142

Someone at Scanlon’s companies apparently fabricated another invoice purportedly from the ‘‘National Center for Public Policy Research’’ for ‘‘Professional Services.’’ 143 That was the invoice the 

Tribe ultimately saw and paid. 

To NCPPR’s Ridenour, Abramoff explained that part of the 

money was a donation ultimately destined for CAF, and the rest 
211 

144 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee On Indian Affairs, 109th Cong. at 30–31 (June 22, 2005) (testimony of Amy Ridenour, president, National Center for Public Policy Research). 145 Id. at 37. 146 Id. 147 Id. 148 Email from Amy Ridenour, National Center for Public Policy Research, to Jack Abramoff, Greenberg Traurig (no Bates number) (October 17, 2002). 149 Email from Jack Abramoff, Greenberg Traurig, to Amy Ridenour, National Center for Pub- lic Policy Research (no Bates number) (October 19, 2002). 150 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg Traurig, (GTG–E000034219) (October 21, 2002). 151 Email from Jack Abramoff, Greenberg Traurig, to Allison Bozniak, Greenberg Traurig (GTG–E000034220) (October 21, 2002). 152 Id. 153 Email from Jack Abramoff, Greenberg Traurig, to Christopher Cathcart, Capitol Campaign 

Strategies (GTG–E00011851) (October 21, 2002). 

was intended for a huge educational effort the Tribe was undertaking to educate the public on the benefits of Indian gaming, and 

the distinction between Indian and non-Indian gaming. According 

to Ridenour’s testimony before the Committee: 

When the funds arrived, he [Abramoff] told me how they 

should be disbursed: $450,000 to the Capital Athletic 

Foundation as a grant; $500,000 to Capitol Campaign 

Strategies; and; and $50,000 to a company called 

Nurnberger and Associates. 

I believe Capitol Campaign Strategies was to be paid for 

educational program services, while Ralph Nurnberger was 

going to help coordinate the project. Jack referred to his 

receiving ‘‘instructions’’ for the disbursements, which I 

took to mean recommendations from the donor, which was 

consistent with my belief that the Mississippi Choctaws 

were actively involved.144

Abramoff repeatedly assured Ridenour that influencing legislation was not part of the effort.145 Abramoff explained that the payment to CCS ‘‘was to be used for educational program services, particularly polling and telephone banks, but not necessarily exclusively; research, potentially paid advertising; I was told later petition drives, that sort of thing, but 100 percent educational program 

services.’’ 146 Abramoff told Ridenour that Nurnberger & Associates 

would coordinate the effort.147

On October 17, 2002, Ridenour confirmed for Abramoff NCPPR’s 

receipt of the $1,000,000 dollar wire transfer from the Choctaw.148

Two days later, Abramoff instructed Ridenour to send $450,000 to 

CAF and $50,000 to Nurnberger & Associates.149

In dividing their ‘‘gimme five’’ spoils, Scanlon reminded Abramoff 

to have NCPPR send Abramoff’s share directly to CAF to avoid a 

taxable event.150 When Ridenour requested invoices from CAF and 

Nurnberger, Abramoff directed his assistant to ‘‘make up two invoices.’’ 151 Abramoff further instructed that the ‘‘invoices should be 

generic as follows: 1. From Capital Athletic Foundation for ‘Sports 

and Politics’ project for $450K 2. Nurnberger and Associates (use 

Ralph Nurnberger’s home address) for ‘research grant’ for 

$50K.’’ 152 Abramoff similarly instructed Christopher Cathcart, 

Scanlon’s right-hand man at CCS, to prepare an invoice from CCS 

‘‘for polling services or something like that.’’ 153 When Cathcart for-
212 

154 Email from Jack Abramoff, Greenberg Traurig, to Christopher Cathcart, Capitol Campaign 

Strategies (GTG–E000011848) (October 22, 2002). 155 Interview of Christopher Cathcart, former employee, Capitol Campaign Strategies, in 

Washington, D.C. (May 5, 2005). 156 Interview of Ralph Nurnberger, president, Nurnberger & Associates, in Washington, D.C. 

(June 21, 2005). 157 Id. 158 Id. 159 Id. 160 Id. 161 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee On Indian Affairs, 109th Cong. at 15, 18 (June 22, 2005) (testimony of Donald Kilgore, Attorney General, Mississippi Band of 

Choctaw Indians). 

warded the invoice to him, Abramoff asked him to ‘‘change this to 

$500K and find out from Amy is [sic] this suffices.’’ 154

NCPPR paid according to the invoices submitted by Abramoff 

and Scanlon. From a review of CAF’s internal business and financial records, the Committee finds that CAF performed no services 

benefitting the Choctaw. Similarly, from a review of CCS’s records, 

the Committee finds it performed no services for the $500,000 it received through NCPPR. Cathcart told the Committee that, contrary 

to the invoice he prepared, CCS did not provide polling or any 

other services to NCPPR.155

The Committee finds that Abramoff fabricated the invoice from 

Nurnberger & Associates. During his interview with Committee 

staff, Nurnberger reviewed the invoice purportedly sent by his 

firm, Nurnberger & Associates, dated October 2002, for a ‘‘Research 

Grant.’’ Nurnberger said that he had never seen the invoice, and 

was certain that neither he nor his firm had ever invoiced the 

NCPPR for this $50,000 payment.156

Nurnberger also told the Committee that at no time did he or his 

firm provide any service to the NCPPR requiring remuneration.157

The payment, according to Nurnberger, was in fact repayment of 

a $50,000 loan that Nurnberger had made to Abramoff many years 

earlier for the production of the movie ‘‘Red Scorpion.’’ 158 After 

reading articles lauding Abramoff and his success in 2002, 

Nurnberger approached Abramoff about repayment.159 Abramoff 

claimed he was not liquid; however, Abramoff explained that the 

NCPPR, of which Abramoff admitted he was a director, owed him 

money, and he would arrange for payment to go instead directly to 

Nurnberger.160

In fact, the Tribe never intended to donate any of that money to 

Abramoff’s personal charity, to Nurnberger, or to CCS. Donald Kilgore, the Attorney General for the Choctaw, testified before the 

Committee that Abramoff told the Tribe that the entire $1,000,000 

would be passed through to grassroots organizations working on 

issues important to the Tribe.161

4. Abramoff’s Misuse of CAF Funds in 2002 

Based on its review of the records, the Committee finds that 

Abramoff never passed the Choctaw’s money through CAF to grassroots groups or vendors working for the Tribe’s benefit as the Choctaw had intended. Nor did CAF perform the work itself. Abramoff 

instead diverted the funds to his own personal causes and concerns. 
213 

162 Capital Athletic Foundation (visited June 7, 2004) <http://www.capathletic.org>. 163 Capital Athletic Foundation, 2002 Form 990PF. 164See Capital Athletic Foundation (visited June 7, 2004) <http://www.capathletic.org>. 165 Id. 

In 2002, CAF doled out $2,331,656 to various organizations. Before Abramoff shut it down, CAF’s website identified the following 

organizations as representative grant recipients: 

• The Alexandria Police Youth Camp Foundation 

• American Youth Soccer Organization 

• Bethesda Chevy Chase Baseball 

• Belize Youth Soccer 

• Boy Scouts of America 

• Columbia Heights Youth Club 

• Girl Scout Council of the Nation’s Capital 

• Howard County Youth Program 

• JCC of Greater Washington 

• Joy of Sports Foundation 

• Metropolitan Police Boys and Girls Club 

• Washington DC Scores 

• Washington Tennis Education Foundation 

• YMCA of Metropolitan Washington 162

Despite millions of dollars in ‘‘grants’’ that year, these organizations received a mere $500 each. Cumulatively, the organizations 

received $7,000, which is only 0.3% of the purported grants made 

that year by CAF. 

Individuals and organizations Abramoff did not tout publicly 

were, in fact, the major beneficiaries of Abramoff’s share of the 

‘‘gimme five’’ scheme. According to CAF’s 2002 Form 990PF, the 

ten top recipients were: 

• Eshkol Academy—$1,857,704 

• P’tach—$300,000 

• Kollel Ohel Tiferet—$97,000 

• Chabad Lubavitch—$20,000 

• GIFT School—$14,500 

• Toward Tradition—$10,000 

• The Waldorf School of Atlanta—$6,000 

• Jewish Federation of Greater Washington—$5,000 

• Washington Redskins Leadership Council—$4,000 

• The Voice Behind—$2,500 163

Despite receiving $2,254,704—nearly all of the $2,331,656 that 

Abramoff had CAF dole out in ‘‘grants’’ in 2002—neither Eshkol 

Academy, P’tach, nor Kollel Ohel Tiferet were listed among the recent recipients identified on CAF’s website. In fact, of the top ten 

recipients of CAF funds, only the Waldorf School and the Voice Behind were listed.164 Similarly, in promotional literature distributed 

to the public for ‘‘The Spy Game,’’ an event scheduled at the Spy 

Museum for March 26, 2003 but which apparently did not occur, 

the Eshkol Academy, Kollel Ohel Tiferet, and P’tach are conspicuously absent from the list of recent grant recipients.165

Many of the top ten recipients of CAF largesse in 2002 had close 

ties to Abramoff: 
214 

166 Email from Gail Halpern, May & Barnhard, to Mimi Stansbury (MB–002043) (November 7, 2002). 167 Capital Athletic Foundation, 2002 Form 990PF. 168 Interview of Fred Baggett, Chair, National Government Affairs Practice, Greenberg Traurig, in Washington, D.C. (September 29, 2005). 169Toward Tradition: Mission Statement (visited June 13, 2006) <http:// 

www.towardtradition.org/mission.htm>. 170 Id. 171 Id. 172 Capital Athletic Foundation, 2002 Form 990. 173See Rick Anderson, Meet the Lapin Brothers, Seattle Weekly, May 11, 2005 at 11. Accord- ing to Seattle Weekly, Daniel Lapin allegedly received a $1.2 million no-bid government contract 

with the Northern Marianas, an Abramoff client during his days at the law and lobbying firm 

of Preston Gates Ellis & Rouvelas Meeds. Id. 174The Jewish Federation of Greater Washington: About Us, (visited June 7, 2006) <http:// 

shalomdc.org/sectionldisplay.html?ID=31> (explanatory parenthetical needed). 175The Jewish Information and Referral Service, (visited June 7, 2006) <http://www.jirs.org> (explanatory parenthetical needed). 176Maryland Department of Assessments and Taxation. 177Torah School of Greater Washington, (visited June 7, 2006) <http://www.tsgw.org/>. 178The Voice Behind, (visited June 28, 2004) <http://www.voicebehind.org>. 179 Id. 

• The single largest beneficiary of money was the Eshkol Academy, the middle school and high school for Orthodox Jews 

founded in 2001 by Abramoff. He and his wife were the only 

members of the board of directors.166 The money allegedly was used for teaching facilities, instructors, and an ice rink.167 In 

concealing his use of CAF to fund Eshkol, Abramoff told 

Greenberg Traurig’s Baggett that he was personally funding 

the Eshkol Academy.168 Abramoff’s school, Eshkol Academy, received nearly 80% of the funds Abramoff had CAF distribute 

as ‘‘grants.’’ • Toward Tradition is ‘‘a non-profit (501.c.3), educational organization working to advance our nation toward the traditional Judeo-Christian values that defined America’s creation 

and became the blueprint for her greatness.’’ 169 During 2002, Abramoff sat on the Board of Directors of Toward Tradition.170

Toward Tradition is headed by Rabbi Daniel Lapin, a longterm Abramoff friend.171

• Rabbi David Lapin received $60,529 from CAF for ‘‘consulting’’ services.172 According to news reports, Rabbi David Lapin is Daniel Lapin’s brother, and another long-time 

Abramoff friend.173

• The Jewish Federation of Greater Washington describes itself as ‘‘the voice of the Jewish community in and around the 

nation’s capital since 1925.’’ 174 The Jewish Federation of 

Greater Washington is the ‘‘operating agency’’ of the Torah 

School of Greater Washington, which is located at 12721 

Goodhill Road in Silver Spring, Maryland.175 Records filed 

with the Maryland Secretary of State show that Abramoff was/ 

is the registered agent for the Torah School of Greater Washington.176 The Torah School of Greater Washington is a Jewish school for kindergarten through sixth grade.177

• In 2004, the Voice Behind claimed to be ‘‘a faith-based, 

501c3 [sic] non-profit creative organization dedicated to creating, commissioning, and celebrating transcendent works of 

art and media.’’ 178 Its vision was a ‘‘creative renaissance that 

illumines the good, the true, and the beautiful through excellence and artistry for the glory of God, the service of neighbor, 

and the renewal of culture.’’ 179 According to a press release, 
215 

180 Id. 181P’tach: About P’tach, (visited June 13, 2006) <http://www.ptash.org/about.php>. 182Letter from Brian Caplan, P’tach, to Capital Athletic Foundation, c/o Mr. And Mrs. Jack Abramoff (GTG001764–JA–P) (March 12, 2002) (concerning $14,500 gift); Letter from Brian 

Caplan, P’tach, to Capital Athletic Foundation, c/o Mr. And Mrs. Jack Abramoff (GTG001762– 

JA–P) (July 11, 2002) (concerning $47,500 gift); Letter from Brian Caplan, P’tach, to Capital 

Athletic Foundation, c/o Mr. And Mrs. Jack Abramoff (GTG001761–JA–P) (August 14, 2002) 

(concerning $275,500 donation). 183May & Barnhard document production (MB–001952) (December 31, 2002). 184 Id. 185 Email from Gail Halpern, May & Barnhard, to Jack Abramoff, Greenberg Traurig (GTG– 

E00001186) (November 5, 2002). 186 Email from Don Feder to Jack Abramoff, Greenberg Traurig (GTG–E000020082) (July 2, 

2002). 187See May & Barnhard document production (MB–001952) (December 31, 2002); see also 

Email from Allison Bozniak, Greenberg Traurig, to Jack Abramoff, Greenberg Traurig, and Gail 

Halpern, May & Barnhard (GTG–E00008858) (September 19, 2002) (referring to payments used 

for jeep); Email from Gail Halpern, May & Barnhard, to Jack Abramoff, Greenberg Traurig 

(GTG–E000011885) (November 5, 2002) (requesting Abramoff cut ‘‘Shmuel spy equipment and 

his monthly stipend ($3560) ...’’); Email from Jack Abramoff, Greenberg Traurig, to Gail 

Halpern, May & Barnhard (GTG–E000088619–21) (December 24, 2002) (‘‘I cannot cut him off 

from the stipend and the jeep payment.’’). 

The Voice Behind, in collaboration with Abramoff, the Capital 

Athletic Foundation, and others hosted the premier of ‘‘the 

Best of the Damah Film Festival: Spiritual Experiences in 

Film’’ in Washington, D.C.180 The Committee has not been able 

to confirm whether this event actually occurred. 

The second largest recipient, P’tach, is a school in Brooklyn, New York for Jewish children with learning disabilities.181 Among CAF’s donations to P’tach were $275,500 for P’tach to purchase a 

new facility for its GIFT High School, Gutmann Institute for Child 

Development, and for administrative offices, and $47,500 for a deposit on a proposed campus in Marriottsville, Maryland.182

The third largest recipient, Kollel Ohel Tiferet, is a purported educational institution in Israel; according to CAF’s 2002 990 Tax 

Return, the grant was supposedly used for education, athletics, and 

security. Based on its review of the documents, the Committee 

finds that the Kollel Ohel Tiferet was nothing more than an entity 

established on paper to conceal the ultimate recipient of CAF 

grants: Shmuel Ben Zvi. As noted above, in 2001 CAF apparently purchased a thermal imager for one Shmuel Ben Zvi for paramilitary use in the Israeli 

West Bank. In 2002, CAF sent money to Ben Zvi in Israel, simply 

listing it as a transfer.183 Additional entries reflect that the pay- ments were for a ‘‘new Jeep.’’ 184 Gail Halpern, Abramoff’s tax advisor, labeled the purchases for Ben Zvi as ‘‘spy equipment.’’ 185 According to one former Abramoff friend, Abramoff allegedly procured 

‘‘rifle scopes for settlers’’ in Israel.186 The Committee thus finds 

that in 2002, Abramoff was making jeep payments for Ben Zvi and 

paying him a stipend from CAF funds.187

At some point, Abramoff began getting pressure to ‘‘clean up’’ the books of CAF to conform, at least on paper, CAF’s expenditures 

with some legitimate charitable purpose. When Abramoff proposed 

changing how the payments were made, Allison Bozniak, one of 

Abramoff’s former assistants at Greenberg Traurig, reported to 

Abramoff: 

I spoke with Shmuel [Ben Zvi] and he is a little afraid to 

begin changing things with the bank since they set up the 

loan for the jeep based on the 2K payments each month for 
216 

188 Email between Allison Bozniak, Greenberg Traurig, and Jack Abramoff, Greenberg 

Traurig, and Gail Halpern, May & Barnhard (GTG–E000088582) (September 19, 2002). 189 Id. 190 Id. 191 Email from Gail Halpern, May & Barnhard, to Jack Abramoff, Greenberg Traurig (GTG– 

E000088599) (November 11, 2002). 192 Email between Jack Abramoff, Greenberg Traurig, and Shmuel Ben Zvi, Kollel Ohel Tieferet (GTG–E000088186) (December 23, 2002). 193 Email between Jack Abramoff, Greenberg Traurig, and Shmuel Ben Zvi, Kollel Ohel Tieferet (GTG–E000088183) (December 23, 2002). 194 Id. 195 Email from Jack Abramoff, Greenberg Traurig, to Shmuel Ben Zvi, Kollel Ohel Tieferet (GTG–E000088623) (December 24, 2002). 

the last year. They regarded the 2k as a sign that the 

transfers were stable and felt that these consistent payments, plus the letter from Jack made the loan a good 

risk. 

He studies half a day at a place called ‘‘Kollel’’ but he 

doesn’t think that they even have a bank account as it 

really doesn’t pay it’s [sic] members. He also has no way 

to set this up with a Yeshiva at the moment.188

Bozniak proposed a solution, ‘‘He did suggest that he could write 

some kind of letter with his Sniper Workshop Logo and letter head. 

It is an ‘educational’ entity of sorts.’’ 189

Abramoff could only respond, ‘‘No, don’t do that. I don’t want a 

sniper letterhead.’’ 190

Abramoff’s use of CAF continued to raise alarm among his tax 

advisors. On November 11, 2002, Halpern wrote specifically about 

the payments to Ben Zvi: 

[W]e need to work this into the tax exempt purpose of the 

Foundation. More to come on this subject in an email tomorrow or so. [The accounting firm of May and Barnhard] 

is finishing the 2001 return and read me the riot act on 

some of the stuff that we are doing. We need to ‘‘fix’’ the 

holes.191

Abramoff’s solution was not to cease the questionable activity; 

rather, he chose to conceal it with a paper transaction. Abramoff 

advised Ben Zvi, ‘‘The other thing is that, if possible, it would be 

easier for me to get you funds through a kollel over there or something like that. my [sic] accountant is very unhappy with the way 

we have done this, through our foundation which was not set up 

for these kinds of activities.’’ 192

Ben Zvi advised Abramoff, ‘‘Anyone can have a Kollel here. If I 

set up the account name in the name of a Kollel and send you papers with a Kollel stationary would that work?’’ 193

When Abramoff shared Ben Zvi’s hardship with his tax planner 

Gail Halpern, Halpern suggested ways to make the transaction 

pass muster on paper, although she knew the ultimate recipient 

and use of the payments.194

Nearly one month later, Abramoff asked Ben Zvi to ‘‘set up an 

account for a kollel and get me the info so we can send the $ [sic] 

there from now on.’’ 195 Later that same day, Halpern advised 

Abramoff on the need to route the money through another institution: 
217 

196 Email from Gail Halpern, May & Barnhard, to Jack Abramoff, Greenberg Traurig (GTG– 

E000088619) (December 24, 2002). 197 Email between Jack Abramoff, Greenberg Traurig, and Shmuel Ben Zvi, Kollel Ohel 

Tieferet (GTG–E000088618) (December 26, 2002). 198 Email from Shmuel Ben Zvi, Kollel Ohel Tieferet, to Jack Abramoff, Greenberg Traurig (GTG–E000088616) (December 27, 2002). 199 Email from Gail Halpern, May & Barnhard, to Jack Abramoff, Greenberg Traurig (GTG– E000088619) (December 24, 2002) (emphasis added). 200 Id. 201May & Barnhard document production (MB–001952) (December 31, 2002). 202 Id. 

[B]ut let’s try to figure it out in a way where we don’t 

screw up the foundation. we [sic] need to get the money to 

a 501c3 [sic] or an educational institution, not directly to 

him. can [sic] you ask him if he can work something out 

w/the kollel so the money goes from the kollel to him? 196

When Ben Zvi reported to Abramoff that the bank from which he 

had obtained the loan for the jeep insisted the money continue to 

go through Ben Zvi’s account, Abramoff responded: 

They are being ridiculous. tell [sic] them that all the 

money will come into the Kollel account, which can be in 

their bank. Same amount of money, but CAF cannot make 

the payments directly to you. must [sic] be to the kollel.197

Ben Zvi soon succeeded. On December 27, 2002, in an email entitled ‘‘CAF/Shmuel payments,’’ he sent wiring information to 

Abramoff for the ‘‘KOLLEL OHEL TIFERET (For: Shmuel Ben 

Zvi).’’ 198

When Abramoff advised Halpern that Ben Zvi would do the 

kollel, Halpern instructed, ‘‘[H]e needs to give us the name and 

bank account info. and [sic] can the jeep payments go to the kollel 

as well, as well as all the other military expenses that don’t look 

good on the Foundation’s books?’’ 199 Halpern further suggested 

that ‘‘at the end of the year, he’ll need to write us a letter on Kollel 

stationary thanking the Foundation for the money to promote their 

educational purpose.’’ 200

Of the nearly $100,000 booked on CAF’s ledger as contributions 

to Kollel Ohel Tiferet, not all were payments to Ben Zvi either directly or through the Kollel account. Listed under the Kollel entry 

of CAF’s ledgers are sizable reimbursements of a number of Greenberg Traurig employees: Allison Bozniak, Hillel Broder, Holly Bowers, and Laura Lippy.201 The reimbursements appear to be for the 

purchase of ‘‘books,’’ ‘‘videos,’’ ‘‘supplies,’’ ‘‘camera,’’ ‘‘light/photon 

supplies,’’ ‘‘custom suit expense’’ and ‘‘lights and alarms,’’ apparently intended for paramilitary use.202

The ‘‘custom suit expense’’ on CAF’s books is curious. The ‘‘custom suit’’ is a ghili suit, that is, camouflage apparel, typically used 

by snipers. According to one email from Ben Zvi to Hillel Broder, 

apparently a former Greenberg Traurig employee: 

Hillel, I want to order a GHILLI SUIT [sic]. from [sic] this 

company so that we have a basic structure to copy from. 

These are made well and will help us to no end. 

I want to get the FULL MILITARY GHILI SUIT [sic] in 

(light) BROWN DICIDOUS [sic] colors just like the one 

display in the photo on their site. 
218 

203 Email from Shmuel Ben Zvi, Kollel Ohel Tieferet, to Hillel Broder, Greenberg Traurig 

(GTG008442-JA-P) (July 29, 2002). 204 Id. 205 Id. 206Greenberg Traurig document production (GTG008438-JA-P/GTG008439-JA-P) (entitled 

‘‘Packing List from Blackhawk Industries, Inc. to Hillel Broder’’) (August 6, 2002). 207 Email from Holly Bowers, Greenberg Traurig, to Jack Abramoff, Greenberg Traurig (GTG– 

E000059454) (July 23, 2002). 208 Email from Holly Bowers, Greenberg Traurig, to Jack Abramoff, Greenberg Traurig (GTG– 

E000026750–51) (August 12, 2002). 209May & Barnhard document production (MB–001946) (December 31, 2002). 210See The Lexington Group (visited July 8, 2004) <http://www.lexingtongroupusa.com> (The 

website also claimed that The Lexington Group was partnered with Greenberg Traurig). 211 Email from Jack Abramoff, Greenberg Traurig, to Gail Halpern, May & Barnhard (GTG– 

E000011514) (February 26, 2002). 212May & Barnhard document production (MB–001946) (December 31, 2002). 

The sizes go by BDU (battle dress uniform) So [sic] the 

bottom should be XXX long and the top should be XXXX 

long. 

Now the order form on their site gives a buba misa about 

these suits needing a special state department licence and 

blah, blah, blah. 

These suits are used by goyim who do alot [sic] of hunting. 

PLEASE [sic] don’t get freaked out about this warning, 

suits of similar design can be bought from any of the hunting supply catalogs. 

Anyway when you box it up and send it to me, send it as 

THE GRANDMOTHER TREE COSTUME [sic] for the play 

POCAHONTAS [sic].203

Ben Zvi further advised that should Broder need ‘‘to call them 

and they ask you what you need it for just tell them that it is a 

present for a relative who goes DEER HUNTING [sic].’’ 204 Scribbled upon the return email is one word: ‘‘Orderd’’ [sic].205

Broder also apparently ordered other sniper paraphernalia for 

Ben Zvi, for which he was reimbursed by CAF. According to invoices from Blackhawk Industries, Inc., Broder purchased tactical 

hydration tubes, web gear, shooters mats, sniper mats, and sniper 

cleaning kits.206 Holly Bowers, Abramoff’s assistant, apparently 

paid for some of the items Broder ordered for Ben Zvi. On July 23, 

2002, Bowers listed in her daily wrap-up list on item 12: ‘‘Gave 

Hillel my credit card number to order the anti-terrorism literature 

for your friend in Israel.’’ 207 Bowers similarly included in her August 12, 2002 list in item 14: ‘‘Gave Hillel my credit card to order 

things for Shmuel.’’ 208

Other, curious expenditures are on CAF’s accounting ledger. To 

name a few, 

• Abramoff spent another $10,000 on The Lexington Group 

in April and May 2002.209 On its website, The Lexington 

Group claimed to practice ‘‘in all areas of legislative representation.’’ 210 Abramoff described it as ‘‘just something i have set 

up with a guy who gt [Greenberg Traurig] would not hire but 

who will do a lot of business.’’ 211

• Abramoff spent $50,000 on an ice rink for Eshkol.212
219 

213May & Barnhard document production (MB–001940) (January-December 2002). 214 Interview of Fred Baggett, Chair, National Government Affairs Practice, Greenberg Traurig, in Washington, D.C. (September 29, 2005). 215 Email from Rodney Lane, Greenberg Traurig, to Jack Abramoff, Greenberg Traurig (GTG– E000107574) (January 3, 2002). 216See Capital Athletic Foundation, 2003 Form 990PF. 217 Capital Athletic Foundation, 2003 Form 990PF. 218 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Louisiana 2002[sic] Political Program’’) (undated) (erroneously date stamped ‘‘9/21/2005’’). 

• In 2002, CAF spent $67,685 on a Spy Museum Fundraiser.213 Despite the large expenditures, the fundraiser appar- ently never occurred.214

• CAF funds were apparently paid to Livsar, the company that owned and operated Abramoff’s Signatures restaurant. On 

January 3, 2002, Rodney Lane, Abramoff’s former assistant 

who left Greenberg Traurig to set up the restaurant, advised 

Abramoff of a ‘‘5 minute transfer from CAF to Livsar.’’ 215

F. IN 2003, ABRAMOFF FUNNELS TRIBAL MONEY THROUGH CONDUITS

TO CAF

CAF’s 2003 Form 990PF does not list any Tribe as a donor.216

The major donors listed on CAF’s 2003 Form 990PF are: 

• Kaygold, LLC—$47,891 • IIA—$500,000 • National Center for Public Policy Research—$250,000 • Atlantic Research & Analysis—$950,000 • Sony Electronics, Inc.—$6,000 • Jack Abramoff—$400,000 217

Nevertheless, the Committee has found substantial evidence establishing that the alleged contributions from Kaygold and Atlantic 

Research & Analysis (‘‘ARA’’) were actually funds from Indian 

Tribes. 

1. Kaygold Sends Tribal Funds to CAF 

According to Kaygold’s bank statements, Kaygold’s primary source of income was Scanlon’s companies. Thus, the $47,891 ‘‘contribution’’ was actually fruits of the ‘‘gimme five’’ scheme. 

2. Abramoff and Scanlon Use ARA as a Conduit To Funnel Louisiana Coushatta Funds to CAF 

From its review of banking and accounting records, the Com- mittee finds that the money allegedly from ARA is actually money 

from the Louisiana Coushatta. Scanlon’s right-hand man, Christopher Cathcart, apparently set up ARA solely to run through payments from the Louisiana Coushatta. 

As he had in 2001, Scanlon started this scam with another 

memorandum. According to a January 21, 2003, memorandum prepared by Scanlon for then-Tribal Vice-Chairman William Worfel on 

the Louisiana Political Program, ARA was allegedly established as 

a front entity to provide cover to Worfel and then-Chief Poncho politically by concealing that the Louisiana Coushatta was still paying Scanlon.218 Scanlon attached invoices to the memorandum 

‘‘that direct the funds to several different entities that will play different roles in this campaign along with a letter from Me/CCS informing the tribe that I will no longer be providing the political 
220 

219 Id. 220 Id. 221 Email between Michael Scanlon, Capitol Campaign Strategies, and Christopher Cathcart, Capitol Campaign Strategies (no Bates number) (January 21–22, 2003). 222 Id. 223 Id. 224See Wachovia document production (D00519–20) (April 1, 2003–April 30, 2003) (bank account statement for Atlantic Research & Analysis, which is the first such statement for ARA 

and shows a $0.00 opening balance on 04/01/03). 225 Email from Jack Abramoff, Greenberg Traurig, to Gail Halpern, May & Barnhard (GTG– E000012166) (March 30, 2003). 226 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000034571) (February 20, 2003). 227 Email between Jack Abramoff, Greenberg Traurig, and Michael Scanlon, Capitol Campaign Strategies (GTG–E000252852) (March 18, 2003). 228 Id. 229 Id. 

services to the tribe as I have in the past.’’ 219 Regarding ARA specifically, Scanlon wrote: 

ARA will be the entity to conduct all the market analysis, 

polling, district research, opposition research and general 

strategy. ARA will also be that primary funding entity for 

the campaign; Meaning that this is where the lions share 

of the money will go, and then ARA can sub-contract or 

hire CCS to conduct strategic functions for the campaign.220

On January 21, 2003, the same day as his memorandum to 

Worfel, Scanlon asked Cathcart, ‘‘Can you get A [sic] DBA on the 

Scanlon CM account that is Atlantic Research and Analysis.’’ 221

The next day, Cathcart informed Scanlon: ‘‘[I] am going to have 

JD [Scanlon’s accountant Jeremy Diehl] set up a new llc [sic] for 

ara [sic] ... reason is that ScM has its own unique tax status as a 

commercial real estate lessor. [S]o, added liability protection and 

smarter for tax reasoins [sic] to keep separate. [W]ill not impact 

our ability to collect the dough from coush [Coushatta].’’ 222

Two hours later, Scanlon authorized Cathcart to establish the 

new entity.223 The Committee has found no corporate registration 

or other filing for ARA in Maryland, Delaware, or the District of 

Columbia establishing that ARA was ever incorporated. The Committee has determined that ARA opened a bank account on or 

about April 1, 2003.224

Meanwhile, Abramoff and Scanlon were on the move. In an apparent effort to avoid taxes on his take, Abramoff wanted Scanlon 

to have the Coushatta send his share of the ‘‘gimme five’’ funds directly to CAF. Abramoff told Halpern, his tax adviser, that he 

would soon have $1,000,000 for CAF ‘‘directly from Coushatta.’’ 225

Abramoff directed Scanlon: ‘‘Please make sure the next $1M from 

Coushatta for me goes to Eshkol Academy directly. Please tell them 

that we are ‘using the school as our conduit for some activities.’ If 

that won’t fly with them, use CAF, or National Center for Public 

Policy Research.’’ 226

The following month, Abramoff asked Scanlon ‘‘did we get the 

Coushatta money?’’ and implored Scanlon, ‘‘Can you please please 

please get it written to Eshkol Academy?’’ 227 Abramoff again suggested that Scanlon ‘‘[t]ell them that’s our front group to cover 

some of this.’’ 228 Scanlon agreed to do so.229
221 

230 Capitol Campaign Strategies document production (no Bates number) (entitled ‘‘Atlantic Research and Analysis INVOICE’’) (April 15, 2003). 231See Chris Barrish, Abramoff Cohort Spent Millions on Sussex Homes, The New Journal, 

May 16, 2006. 232 Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in 

Washington, D.C. (September 13–14, 2005). 233 Id. 234 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (no Bates number) (April 16, 2003). 235 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (no Bates number) (April 28, 2003). 236 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg Traurig (no Bates number) (April 28, 2003). 237Wachovia document production (D00521–22) (May 1, 2003–May 30, 2003). 238 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg Traurig (no Bates number) (May 5, 2003). 239 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (no Bates number) (May 5, 2003). 240 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (no Bates number) (May 6, 2003). 241 Email from Michael Scanlon, Capitol Campaign Strategies, to Jack Abramoff, Greenberg Traurig (no Bates number) (May 6, 2003). 242 Email from Michael Scanlon, Capitol Campaign Strategies, to Christopher Cathcart, Cap- itol Campaign Strategies (no Bates number) (May 7, 2003). 243 Email from Christopher Cathcart, Capitol Campaign Strategies, to Michael Scanlon, Capitol Campaign Strategies (no Bates number) (May 7, 2003). 

On or about April 15, 2003, Scanlon submitted a $2,000,000 invoice to the Louisiana Coushatta in the name of ARA, along with 

invoices from his other groups.230 The address listed on the invoice 

for ARA—53 Baltimore Avenue, Rehoboth Beach, DE 19971—was 

the clapboard house from which another Scanlon entity, the American International Center, operated.231 Worfel, the Louisiana 

Coushatta’s Vice-Chairman at the time, was led to believe that 

ARA was ‘‘just another entity of Greenberg ... that they operate 

under.’’ 232 Worfel understood ARA was one of many front-groups 

that Abramoff and Scanlon used so the Tribe’s political opposition 

would not know what they were doing.233

Abramoff still wanted Scanlon to have the Tribe send his part of 

the ‘‘gimme five’’ payments to CAF.234 While Scanlon awaited arrival of the funds, Abramoff told Scanlon, ‘‘I really need to get 

those funds into Eshkol asap.’’ 235 Scanlon advised Abramoff that 

he could not guarantee the payment would go to CAF, and was certain the money would not be routed directly to Eshkol because he 

could not find ‘‘any invoices on the school.’’ 236

On May 1, 2003, ARA received a $2,000,000 wire transfer from 

the Louisiana Coushatta.237 Scanlon advised Abramoff in a May 5 

email entitled ‘‘Coush!’’: ‘‘Hey FYI—Coushatta has paid for the 

Louisiana 2003 program in full now. If it’s ok—I think it would be 

wise to hold back a bit for a rainy day (100 or so to cover operations), other than that please tell me where to send the funds.’’ 238

Abramoff instructed Scanlon to send it to CAF.239

When Abramoff did not receive the money, he asked Scanlon on 

May 6, ‘‘Did we get this money yet? I am in urgent need of 

funds.’’ 240

Scanlon assured Abramoff that he would ‘‘have a check tomorrow 

at your office via courier!’’ 241

True to his word, on May 7, 2003, Scanlon instructed Cathcart 

to ‘‘cut a check to Capital Athletic Foundation for 950k.’’ 242

Cathcart responded, ‘‘950? Wow. It will come from atlantic research 

[sic]. I will pay Ccs [sic] out of the rest.’’ 243 According to ARA’s 
222 

244Wachovia document production (D00521–22) (May 1, 2003–May 30, 2003). 245May & Barnhard document production (MB–000252) (December 31, 2003). 246 Beis Avrohom Chaim, Articles of Incorporation. 247 Id. For reasons unknown to the Committee, Rodney Lane, Abramoff’s former executive as- sistant who was instrumental in setting up the Signatures restaurant, subsequently replaced 

Abramoff’s wife as a trustee. See Articles of Amendment for a Religious Corporation, for Beis Avrohom Chaim. 248 Id. 249May & Barnhard document production (MB–00255) (December 31, 2003). 250 Id. 251 Id. 252 Id. 253 Compare May & Barnhard document production (MB–00255) (December 31, 2003), with Capital Athletic Foundation, 2003 Form 990. 254Deed, July 10, 2003 between Benjamin L. Allen, PR and Marie-Louise Allen Kempe, PR of the Estate of Marie Louise Allen, Estate no. W–37905 as to 1⁄2 interest and Marie Louise 

Allen and James S. Allen, by Benjamin L. Allen, his Attorney-in-fact, as to 1⁄2 interest, as tenants in common as to the whole to Beis Avrohom Chaim. The property is apparently down the 

street from Abramoff’s home. 

bank records, ARA executed a check for $950,000.244 Abramoff deposited the $950,000 into CAF’s bank account on May 8, 2003.245

3. Abramoff’s Use of CAF Funds in 2003 

In 2003, Abramoff used CAF as he had before. According to the 2003 Form 990PF, Abramoff directed CAF to pay: 

Eshkol Academy ..................................................................................... $2,366,512 

Beis Avrohom Chaim ............................................................................. $251,242 

Kollel Ohel Tiferet ................................................................................. $44,220 

American Friends of Lubavitch ............................................................ $10,000 

The DeLay Foundation for Kids ........................................................... $25,000 

Bais Yaakov Brooklyn ........................................................................... $20,000 

Total ................................................................................................. $2,716,974 

Abramoff’s Eshkol Academy was again the biggest beneficiary, receiving 87% of CAF’s grants. Kollel Ohel Tiferet, the paper entity 

established by Abramoff’s friend in Israel, received another 

$44,000. 

Beis Avrohom Chaim is another Abramoff entity that received CAF funding. According to the articles of incorporation, Beis 

Avrohom Chaim was incorporated in June 2003 under Maryland 

law as a religious corporation.246 The trustees were Jack Abramoff 

and his wife; Shana Tesler, a former Greenberg Traurig employee 

who worked closely with Abramoff; and, her husband Sam Hook.247

The principal place of worship listed in its articles of incorporation 

is Abramoff’s home address.248

According to Beis Avrohom Chaim’s General Ledger, total con- tributions from CAF totaled $251,242 in 2003.249 Two payments made on July 10, 2003, for $241,250 are described as contributions 

from CAF.250 Another payment on August 5, 2003, for $2,500 is de- scribed as payment by CAF for professional services.251 A final 

payment of $7,492 on August 8, 2003 is described as mortgage recordation fees related to a mortgage closing.252 The total listed on 

Beis Avrohom Chaim’s general ledger—$251,242—matches the 

amount of donations listed on CAF’s Form 990.253

Incorporated as a religious corporation, Beis Avrohom Chaim ap- pears to be a holding company for real estate. According to a deed 

filed in Montgomery County, Maryland, on July 10, 2003, Beis 

Avrohom Chaim purchased property at 800 Edelblut Drive, Silver 

Spring Maryland (close to Abramoff’s home) for $845,000.254 On 

CAF’s 2003 Form 990, Abramoff described Beis Avrohom Chaim as 
223 

255 Capital Athletic Foundation, 2003 Form 990PF. 256 Id. 257May & Barnhard document production (MB–000250) (January–December 2003). 258 Id. 259Plea Agreement, Factual Basis for the Plea, at para. 39, U.S. v. Jack A. Abramoff (Dist. 

D.C., January 3, 2006) (CR–06–001). 260 Id. at para. 41. 

a ‘‘religious organization, [that] provides religious services for the 

congregation and housing for the Eshkol Academy student athletes.’’ 255

As it had for 2002, for 2003 CAF also listed substantial expenses 

associated with travel, conferences, and meeting: $251,163.256

Abramoff used approximately $150,000 of CAF’s funds to finance 

another trip to Scotland.257 Abramoff also spent over $100,000 on 

the Spy Museum Event that apparently did not take place.258

G. CONCLUSION

Despite the self-serving statements about ‘‘ethical conduct’’ and 

helping ‘‘disadvantaged youth’’ on CAF’s website, the Committee 

finds that Abramoff used CAF as his personal slush fund. In pleading guilty to tax evasion, Abramoff admitted that he ‘‘misrepresented the receipt of diverted funds [from the Tribes] as charitable 

donations and mischaracterized personal and business expenditures as being used for a tax exempt purpose.’’ 259 He further confessed that he ‘‘engaged in similar evasive conduct for the tax years 

2001 and 2003. Due to this and other evasive conduct, Abramoff attempted to evade approximately $1,724,054 in individual income 

taxes for the 2001 through 2003 tax years.’’ 260

(225) 

1Deposition of Italia Federici, president, Council of Republicans for Environmental Advocacy, 

in Washington, D.C. (October 7, 2005). 2 Id. 

3 Id. During her deposition, Federici recalled first working with Norton on her race for Colorado attorney general, after a volunteer stint on the 1994 Jeb Bush for Governor campaign. Id. 

PART THREE—OTHER 

CHAPTER I 

COUNCIL OF REPUBLICANS FOR ENVIRONMENTAL 

ADVOCACY 

Who writes $50,000 checks to people they don’t know if it 

wasn’t what Jack—Jack said these people have a lot of 

money, they want to give to Republicans, they’re taking 

my advice, and they really just don’t want to be bothered 

with executive directors [like me]. Fine, and then they sent 

their checks in. And then what did these disappointed people think they were going to get, and you tell me who’s 

committing fraud ... I mean it all fit ... 

Deposition testimony of CREA president Italia Federici to Committee staff, October 7, 2005 

You are an environmental organization. You come into a 

lot of money from Indian tribes. My guess is that that 

money had nothing to do with generosity, or had very little 

to do with energy or the environment but had a lot to do 

with Mr. Abramoff saying to his contacts in these tribes, 

‘‘I want you to stick money into Ms. Federici’s organization,’’ and they did. 

Comments from Committee Vice-Chairman Byron Dorgan to CREA president 

Italia Federici during Committee hearing, November 17, 2005 

A. BACKGROUND

Among the issues investigated by the Committee is whether 

monies paid by the Tribes at Jack Abramoff or Michael Scanlon’s 

direction, to or through particular entities, were used for purposes 

intended by the Tribes. In that context, the Committee is concerned 

about ‘‘contributions’’ that some of the Tribes made at Abramoff’s 

direction to an organization called the Council of Republicans for 

Environmental Advocacy (‘‘CREA’’) and, in particular, the circumstances under which they made those contributions. 

CREA was created in 1997 by Italia Federici.1 In her deposition 

with Committee staff, Federici stated that she originally formed 

the organization in the memory of her mother.2 According to 

Federici, her mother passed away two weeks before former Interior 

Secretary Gale Norton’s 1996 campaign for the U.S. Senate ended.3

(Federici testified that she worked on Norton’s failed Senate cam-
226 

4 Id. 

5 Id. In her deposition, Federici could not recall having drawn a salary from CREA from 1997– 

2000. Id. In 2001, she believed that ‘‘her income tax return said that [she] made like $25,000.’’ 

Id. And, in 2002, she believed that she ‘‘might have made like 56 [thousand dollars]’’ and 

$85,000 in 2003. Id. It is noteworthy that Federici’s salary from CREA appears to have spiked 

during the period that Abramoff’s Tribal clients contributed to CREA. 6 Id. Federici described, in her deposition with Committee staff, that Norquist was instrumental to CREA by including CREA in his Wednesday policy meetings and introducing CREA 

to Newt Gingrich, who served as CREA’s ‘‘first kickoff speaker ever, which was huge.’’ Id. She 

further described Norquist as ‘‘[j]ust always helpful, [providing] good advice.’’ Id. According to 

an email dated January 8, 1999, Federici met Abramoff ‘‘at a football game with ... Norquist.’’ 

Email between Susan Ralston, Greenberg Traurig, and Jack Abramoff, Greenberg Traurig, ‘‘Call 

from’’ (GTG–E000079149) (January 8, 1999). 7Deposition of Italia Federici, president, Council of Republicans for Environmental Advocacy, 

in Washington, D.C. (October 7, 2005). 8 Id. 

9Originally called the Coalition of Republicans for Environmental Advocacy, in mid-2000, 

CREA was renamed the Council of Republicans for Environmental Advocacy and registered as 

both a 527 political fund-raising entity and as a D.C.-based 501(c)(4), a nonprofit organization 

that may engage in some lobbying activities. Josephine Hearn, DOJ Subpoenas GOP Group, The 

Hill, March 1, 2005. However, last year, CREA reportedly edited a reference on its website referring to it as a 501(c)(4), replacing the text with more vague language. Id. 10Website, Council of Republicans for Environmental Advocacy, ‘‘Mission Statement,’’ http:// 

www.crea-online.org/2222-20.html (last visited, June 3, 2006). Since its inception, CREA has 

met skepticism from other environmental groups. See Josephine Hearn, DOJ Subpoenas GOP 

Group, The Hill, March 1, 2005. For example, Republicans for Environmental Protection called 

the group a ‘‘greenscam’’ in 1998 after it was revealed that the group received significant funding from the mining, logging, chemical and coal industries. Id. 11 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. 

at 38–40 (November 17, 2005). 12See Interview of Marc Schwartz, president, Partners Group Consultants, by telephone (February 22, 2005). 

paign ‘‘from the day that it started to the day that it ended.’’ 4) 

Federici stated that her mother ‘‘liked the notion, my idea of a Republican environmental organization, so I decided to kind of honor 

her memory by creating CREA in 1997.’’ 5 Subsequently, Norton 

and anti-tax activist Grover Norquist came on board as CREA’s 

honorary national co-chairmen.6

According to Federici, CREA later closed ‘‘because we reorganized when we moved out here [to Washington, D.C.] in 1999 and 

[prominent Republican lawyer] Ben Ginsburg became our general 

counsel and he said, I want to reincorporate you guys in the District [of Columbia].’’ 7

It did so.8 After having been registered as a 527 political fundraising entity, it reorganized as a 501(c)(4) non-profit organization.9

According to CREA’s website, its mission is ‘‘to foster environmental protection by promoting fair, community[-]based solutions 

to environmental challenges, highlighting Republican environmental accomplishments and building on our Republican tradition 

of conservation.’’ 10

1. Abramoff Has His Tribal Clients Pay CREA 

In testimony before the Committee, Federici revealed that, from 

2001 through 2003, Abramoff or his clients ‘‘contributed’’ in total 

about $500,000 to CREA.11 Evidence obtained by the Committee 

indicates that Abramoff directed some of his Tribal clients to ‘‘contribute’’ to CREA, occasionally under false pretenses. For example, 

to induce the Ysleta del Sur Pueblo of Texas (‘‘Tigua’’) into giving 

$25,000 to CREA in 2002, Abramoff told a Tribal representative 

that CREA was ‘‘a DeLay organization.’’ 12
227 

13See Interview of Nell Rogers, planner, Mississippi Band of Choctaw, in Choctaw, Mississippi 

(April 27, 2005). 14 Id. 15 Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 16 Id. 17 Id. 18 Id. See ‘‘Tribal Lobbying Matters’’ Hearings before the Committee on Indian Affairs, 109th 

Cong. at 45 (November 2, 2005). 19 Id. See Interview of Nell Rogers, planner, Mississippi Band of Choctaw, in Choctaw, Mississippi (April 27, 2005). 20 Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in Washington, D.C. (September 13–14, 2005). 21 ‘‘Tribal Lobbying Matters’’ Hearings before the Committee on Indian Affairs, 109th Cong. at 

50–53 (November 2, 2005). 22See id. at 107 (‘‘I do not have any recollection of that today at all. At some point in my 

background, somebody may have told me something, but I was not at Interior, and I cannot 

imagine conducting a poll for Interior, Senator.’’). 23 Interview of David Otto, former council member, Sagniaw Chippewa Indian Tribe, in Washington, D.C. (August 27, 2004). 24 Id. 

In March 2002, the Mississippi Band of Choctaw Indians (‘‘Choctaw’’) contributed $50,000 to CREA.13 In soliciting the Tribe for 

that contribution, Abramoff told that Tribe that CREA did work ‘‘in 

terms of liberalizing environmental rules and that was an activity 

the Tribe wanted to support.’’ 14

In 2001, the Coushatta Tribe of Louisiana (‘‘Louisiana 

Coushatta’’) gave $50,000 and $100,000 in 2002.15 Of the $50,000 

that the Tribe paid CREA in 2001, it paid at least $25,000 in connection with a private fund-raiser, held on September 24, 2001.16

During that dinner, then-Tribal Chief Lovelin Poncho met Norton 

and other senior Administration officials.17

In his interview, former Louisiana Coushatta Vice-Chairman 

William Worfel testified that the $25,000 that the Tribe paid to 

CREA was actually intended to support a ‘‘national park research 

study’’ that Interior was supposedly conducting—a ‘‘pet project.’’ 18

He was told that the Choctaw had contributed, or intended to contribute, $25,000 to CREA in support of the study 19 and that ‘‘Interior then would look and always consider you [that is, the Tribe] 

friends because you went out on a limb, you went out, reached in 

your pockets and helped a pet project of the U.S. Department of the 

Interior when they was [sic] strapped for funds.’’ 20

The Committee has seen no evidence that this study was ever 

conducted. Worfel never saw this study and does not know whether 

such a study was actually conducted.21 Former Interior Deputy 

Secretary J. Steven Griles testified at a Committee hearing that he 

too is unaware of such a study and is highly skeptical about whether one was ever conducted.22

Apparently, Abramoff used a different pretext to induce the Saginaw Chippewa Indian Tribe (‘‘Saginaw Chippewa’’) to contribute at 

least $50,000 to CREA. In his interview with Committee staff, 

former Tribal Council member David Otto recalled that former 

Tribal legislative director Christopher Petras told him that CREA 

was a group with which then-Interior Secretary Norton was ‘‘involved.’’ 23 Petras said that supporting a project the Secretary was 

involved with would ‘‘look good’’ for the Tribe, according to Otto.24

Otto also recalled that he was told that doing so would help them 
228 

25 Id. 26 Email from Jack Abramoff, Greenberg Traurig, to Christopher Petras, Sagniaw Chippewa Indian Tribe (GTG–E000105234) (September 20, 2001). 27 Id. 28 Email from Jack Abramoff, Greenberg Traurig, to Allison Bozniak, Greenberg Traurig (GTG–E000107697) (January 31, 2002). 29Federici, Griles and Norton’s former counselor at Interior, Michael Rossetti, have testified 

that Norton had no relationship with CREA after Norton became Interior Secretary. Deposition 

of Italia Federici, president, Council of Republicans for Environmental Advocacy, in Washington, 

D.C. (October 7, 2005); Interview of J. Steven Griles, former Deputy Secretary, U.S. Department 

of the Interior, in Washington, D.C. (October 20, 2005); Interview of Michael Rossetti, former 

counselor to the Secretary, U.S. Department of the Interior, in Washington, D.C. (October 28, 

2005). In addition, Federici testified that she never had any conversations with Norton between 

2001 and 2004 about any of Abramoff’s Tribal clients. Deposition of Italia Federici, president, 

Council of Republicans for Environmental Advocacy, in Washington, D.C. (October 7, 2005). 30 Email between Todd Boulanger, Greenberg Traurig, and Jack Abramoff, Greenberg Traurig (GTG–E000107575) (January 3, 2002). 31 Id. 

with appropriations for their school, drug abuse center, senior center, and other facilities.25

Documents reflect that after Norton became Secretary, Abramoff 

told Petras (and members of his own lobbying team) that Norton 

supported CREA. In an attempt to get the Tribe to financially support the September 2001 CREA fund-raiser, Abramoff pitched 

CREA to Petras as ‘‘hav[ing] been incredibly helpful on certain specific tribal issues.’’ 26 He also identified CREA as ‘‘[Secretary] Norton’s main group outside the department.’’ 27 Having sold CREA on 

Petras (who was to approach the Tribal Council for a contribution), 

Abramoff directed his assistant to amend a requested contribution 

list he was sending to the Saginaw Chippewa to ‘‘add in $50,000 

for CREA and put a note in the candidate column as follows: Sec. 

Norton.’’ 28

The Committee has seen no evidence that Abramoff’s representations about Norton’s interest in CREA are true. Nor has the Committee seen any evidence to suggest that Norton knew of, much 

less sanctioned, Abramoff or anyone else using her name in seeking 

fees and donations from Native Americans.29 However, it is clear 

that, at some point, Abramoff came to believe that CREA president 

Italia Federici had special access at Interior and that she was willing to use it for his or his clients’ benefit. That is reflected in numerous documents, described in this Chapter, illustrating how 

Abramoff repeatedly went to Federici urgently asking for her help 

with Interior on pending matters affecting his much-valued Tribal 

clients. It is also reflected in how much he had these same clients 

‘‘donate’’ to CREA. It is further corroborated by a number of internal business communications between Abramoff and his team 

members that reflect his belief. 

A notable example of such a communication is an email, dated 

January 3, 2002, entitled ‘‘Italia Meeting,’’ from Abramoff to members of his team. In this document, Todd Boulanger, a senior member of Abramoff’s team asked, ‘‘Can [Italia] get shit in the President’s budget to [C]ongress?’’ 30

Abramoff responded, ‘‘I don’t think she has juice beyond 

[I]nterior.’’ 31 Another example is an email between Abramoff and 

Boulanger, dated February 12, 2002, entitled ‘‘Political Contribution Requests.’’ In that email, the two discussed including CREA in 

a political contribution request list they were submitting to the 
229 

32 Email between Jack Abramoff, Greenberg Traurig, and Todd Boulanger, Greenberg Traurig (GTG–E000025072) (February 12, 2002). 33 Id. 34 Email between Jack Abramoff, Greenberg Traurig, and Rodney Lane (GTG–E000105191) (March 4, 2003). 35 Id. 36See, e.g., Email from Jack Abramoff, Greenberg Traurig, to Rodney Lane (GTG– E000105140) (June 27, 2002). 37Deposition of Italia Federici, president, Council of Republicans for Environmental Advocacy, in Washington, D.C. (October 7, 2005). 38 Id. 39 Id. 40 Id. 41 In somewhat surprising testimony, it seems that Federici too found this rationale implausible. While discussing Abramoff’s explanation as to why his Tribal clients were willing to make 

sizeable contributions to CREA without directly discussing with her CREA’s mission or work, 

the following exchange occurred during Federici’s deposition. ‘‘FEDERICI: Who writes $50,000 

checks to people they don’t know if it wasn’t what Jack—Jack said these people have a lot of 

money, they want to give to Republicans, they’re taking my advice, and they really just don’t 

want to be bothered with executive directors [like me]. Fine, and then they sent their checks 

in. And then what did these disappointed people think they were going to get, and you tell me 

who’s committing fraud ... I mean it all fit. ... STAFF: [Mr. Abramoff] told you that? FEDERICI: 

Yes. ...’’ Id. Why, given her concerns, Federici continued to accept these contributions remains unclear. The Committee defers to law enforcement authorities to determine (1) whether, in connection with their contributions to CREA, the Tribes were in fact defrauded and, (2) if they were 

defrauded, who did so or conspired to do so. 

Saginaw Chippewa.32 Abramoff wrote Boulanger, ‘‘Todd, did we not request money for CREA from them? That’s our access to Norton. 

We need $ for them more than many of these others.’’ 33

Still another example is an email from Abramoff to business associate and Signatures partner Rodney Lane, entitled ‘‘CREA— 

Freshman Reception.’’ There, the two discussed ‘‘comping’’ a CREA 

function.34 Ultimately, Abramoff replied, referring to Federici, ‘‘[u]nfortunately, she is critical to me.’’ 35 This email is typical of others, such as an email dated June 27, 2002, that describes 

Abramoff’s reluctantly ‘‘comping’’ CREA functions—at least some of 

which appear to have been attended by Members of Congress, senior Administration officials, or their senior staff.36 The Committee 

finds that only one person could have induced Abramoff so convincingly into believing that Federici had stroke at Interior that he directed his Tribal clients to provide substantial contributions to 

what she herself described as a ‘‘mom and pop non-profit’’ 37—Italia 

Federici. What she said or did to so induce him into this belief is 

one question, among others, that this Chapter attempts to answer. 

2. Federici Promises To Help Abramoff in Exchange for, or Because of, CREA Contributions 

When she testified before the Committee, Federici attempted to 

explain the Tribes’ largesse to her organization by saying that 

Abramoff told her that his Tribal clients were concerned that over 

the decades, Democrats became dominant in electoral politics.38 So, 

according to Federici, Abramoff told her that those Tribes had become used to giving very ‘‘heavily to one political party and ... 

wanted to diversify.’’ 39 They wanted to make sure that they were giving ‘‘more evenhandedly.’’ 40

As an explanation for why Abramoff’s clients gave so much to CREA within such a short period of time, this is unconvincing.41

There is no doubt that Abramoff directed his Tribal clients to contribute to CREA. The question is why? Why would Abramoff have 

had his much-valued Tribal clients (whom he relied on as a significant source of sizeable federal campaign contributions as well as 
230 

42See id. 43See id. 44 Email between Italia Federici, Council of Republicans for Environmental Advocacy, and Jack Abramoff, Greenberg Traurig (GTG–E000105164) (January 30, 2001) (emphasis added). 

Federici construed these ‘‘generous offers’ from Abramoff to mean ‘‘[in] general, let’s get you 

funded, let’s get some support for you guys, this looks like a really good idea.’’ Deposition of 

Italia Federici, president, Council of Republicans for Environmental Advocacy, in Washington, 

D.C. (October 7, 2005). 45See id. 46 Email between Italia Federici, Council of Republicans for Environmental Advocacy, and Jack Abramoff, Greenberg Traurig (GTG–E000105164) (January 30, 2001). 47During Federici’s deposition with Committee staff, staff specifically asked her, ‘‘Did you ever 

help Mr. Abramoff in getting any particular person into the U.S. Department of the Interior 

at transition in 2000 after the election? ’’ Deposition of Italia Federici, president, Council of Republicans for Environmental Advocacy, in Washington, D.C. (October 7, 2005). She responded, 

‘‘No. Like everyone else in Washington, Jack was forwarding me names of people he thought 

[then-Interior Secretary] Gale [Norton] would love ... [Abramoff would ask] Hey it would be 

great if she could interview this person or that person.’’ Id. Documents in the Committee’s possession suggest what Abramoff had in mind. For example, in a contemporaneous email from 

Abramoff to former Christian Coalition Executive Director Ralph Reed, Abramoff asked Reed 

for help placing him on the Interior transition team, noting, ‘‘this [sic] would be really key for 

future clients for both of us. Let’s discuss.’’ Email from Jack Abramoff, Preston Gates Ellis & 

Rouvelas Meeds, to Ralph Reed, Century Strategies, ‘‘Interior Dept [sic] transition team’’ (GTG– 

E000022954) (October 24, 2000). Reed responded, ‘‘ok.’’ Id. 

millions in federal lobbying revenue to Greenberg Traurig, secret 

‘‘gimme five’’ partnership income with Scanlon, contributions to run 

his Jewish boys’ school in Maryland; and capital to float his restaurants) pay so much to this obscure organization? Documents in 

the Committee’s possession suggest that Abramoff did so because 

of, or in exchange for, special favors that Federici had promised to 

do for him or his Tribal clients at Interior. 

B. ABRAMOFF AND FEDERICI START WORKING TOGETHER

In her deposition with Committee staff, Federici recalled first 

reaching out to Abramoff, on the advice of friends, to try to persuade him to participate in a real estate investment deal.42 In the 

course of discussing that deal, they first discussed CREA.43 On 

January 30, 2001, it appears that Federici held herself out to 

Abramoff as having access to the political appointment process 

being undertaken by the incoming Administration: 

I very much appreciate your generous offers regarding 

CREA and I’ve been working on the document you requested regarding grassroots and strategy. I look forward 

to sharing it with you when you return. According to the 

folks I’ve talked with, Gale is expected to be confirmed 

with about 80 votes. ... Jeanne Adkins (my friend from 

[Colorado]) has been offered the CFO position. She and I 

are talking later about other positions and she will continue to discuss resumes with appropriate contacts ...44

Abramoff got the hint. After having offered to help raise money 

for CREA, 45 he responded, ‘‘Thanks so much Italia. Please let me 

know what I can do to help Dennis Stevens, Mark Zachares (Office 

of Insular Affairs) and Tim Martin (Bureau of Indian Affairs) be 

placed. Look forward to hearing form [sic] you regarding CREA.’’ 46

Apparently, these were individuals who Abramoff, for his own reasons, wanted placed in the Administration.47

According to an email dated March 1, 2001—just seven days before the President nominated Griles for the second highest position 
231 

48See Email between Italia Federici, Council of Republicans for Environmental Advocacy, and 

Jack Abramoff, Greenberg Traurig, ‘‘Thanks from me and Steve and Invitation’’ (GTG– 

E000037865) (March 1, 2001). 49 Id. While Griles vaguely recalls having met Abramoff ‘‘sometime before becoming Deputy 

Secretary,’’ he specifically recalls first meeting him at the September 2001 private dinner for 

CREA. See Interview of J. Steven Griles, former Deputy Secretary, U.S. Department of the Interior, in Washington, D.C. (October 20, 2005). Griles could not remember what he talked with 

Abramoff about—only that he ‘‘spoke and said hello to everyone who was there.’’ Id. A few weeks 

after that dinner, Abramoff prepared a letter to Griles, thanking him for ‘‘calling me today’’ and 

expressing appreciation for ‘‘your help with the [Commonwealth of the Northern Marianas Islands (‘‘CNMI’’)] governor’s race and ensuring that the President does NOT endorse anyone in 

that race, in particular the liberal ‘‘Republican’’ Juan Babuata, who is running against the 

Speaker and former chairman of the Bush campaign there, Ben Fitial.’’ Email from Jack 

Abramoff, Greenberg Traurig, to J. Steven Griles, U.S. Department of the Interior; to Laura 

Lippy, Greenberg Traurig, ‘‘FW: Letter’’ (GTG–E000105260) (October 18, 2001) (emphasis in 

original). At his deposition, Griles had no recollection of having had any conversations with 

Abramoff about the CNMI, Fitial or ‘‘anything like that with the White House.’’ Interview of 

J. Steven Griles, former Deputy Secretary, U.S. Department of the Interior, in Washington, D.C. 

(October 20, 2005). Furthermore, Griles insisted that ‘‘if [he] would have done something on 

that, [he] would think that [he] would recall it today.’’ Id. In his draft letter to Griles, Abramoff 

went further, writing, ‘‘I also appreciate anything you can do to prod things forward to get Mark 

Zachares into position at OIA.’’ Email from Jack Abramoff, Greenberg Traurig, to J. Steven 

Griles, U.S. Department of the Interior; to Laura Lippy, Greenberg Traurig, ‘‘FW: Letter’’ (GTG– 

E000105260) (October 18, 2001). The Committee has seen no evidence that this letter was ever 

sent. 50 Email between Italia Federici, Council of Republicans for Environmental Advocacy, and 

Jack Abramoff, Greenberg Traurig, ‘‘Thanks from me and Steve and Invitation’’ (GTG– 

E000037865) (March 1, 2001). 51Press Release, Judicial Watch, U.S. Secret Service Releases to Judicial Watch White House 

Logs Detailing Abramoff Visits—Logs Appear to be Incomplete, Show 2 Documented Visits Available on Judicial Watch’s Internet Site, www.judicialwatch.org, http://www.judicialwatch.org/ 

abramoff-docs.shtml May 10, 2006 (linking to ‘‘Abramoff Secret Service Logs’’). 52See e.g., Email from Jack Abramoff, Greenberg Traurig, to Italia Federici, Council of Republicans for Environmental Advocacy, ‘‘Subject: urgent tribal issue’’ (SENCREA 00018) (March 20, 

2001). 53 Email between Italia Federici, Council of Republicans for Environmental Advocacy, and 

Jack Abramoff, Greenberg Traurig (GTG–E000105287) (April 10, 2001). 54 Id. 55 Id. 

at Interior, Abramoff met with Griles.48 Apparently, Federici was 

present—later reporting to Abramoff that ‘‘[a]fter I retrieved my 

coat I ended up sharing a cab with Steve [Griles]. He really enjoyed 

meeting you and was grateful for the strategic advice on BIA and 

Insular Affairs. You definitely made another friend.’’ 49

Abramoff responded, in part: ‘‘Thank you so much for everything. 

I am so glad we are working together.’’ 50

According to records recently released by the Secret Service, 

Abramoff visited the White House on March 6, 2001—two days before Griles’ nomination.51 After Griles was nominated but before he 

was confirmed, documents suggest, Abramoff tried to approach 

Griles about tribal issues, in particular, about the BIA’s tribal insurance policy.52

Also in this interim, Abramoff worked with Federici on some special projects. For example, according to an email dated April 10, 

2001, entitled ‘‘Ben Fitial seeing Secretary Norton,’’ Federici tried 

to help Abramoff get a photo opportunity for Ben Fitial with Secretary Norton.53 Fitial had successfully run for governor of the 

Commonwealth of the Northern Marinas Islands (‘‘CNMI’’) and reportedly pressured senior CNMI officials to hire Abramoff. In this 

email, Federici and Abramoff discussed that the Secretary was not 

doing ‘‘photo-ops’ with anyone.54 In that context, Federici promised 

Abramoff that she would ‘‘try to figure out what exactly is going 

on over there.’’ 55 Interestingly, Federici also offered to cover 
232 

56 Id. 57 Email from Italia Federici, Council of Republicans for Environmental Advocacy, to Jack 

Abramoff, Greenberg Traurig (GTG–E000105174) (May 7, 2001). This is similar to an email 

dated a few months later, January 26, 2002, entitled ‘‘Hi Italia.’’ There, Abramoff asked Federici 

whether she had ‘‘any word on getting the Chief a meeting with Gale?’’ Email between Jack 

Abramoff, Greenberg Traurig, and Italia Federici, Council of Republicans for Environmental Advocacy (SENCREA 10/04 000018) (January 26, 2002). In response, Federici offered, ‘‘I meet with 

folks tomorrow and I will call you tomorrow in the early evening.’’ Id. 58The Senate confirmed Griles as Deputy Secretary of the U.S. Interior Department on July 

12, 2001. 59 Email from Jack Abramoff, Greenberg Traurig, to Kathryn Van Hoof, Coushatta Tribe of 

Louisiana, and Shawn Vasell, Greenberg Traurig, ‘‘Status’’ (COUSH-MiscKVH-0001529) (July 

18, 2001). 60 Id. 61 Email between Italia Federici, Council of Republicans for Environmental Advocacy, and 

Jack Abramoff, Greenberg Traurig (GTG–E000253568) (January 2, 2002). 62 Id. 63 Id. 64 Email between Italia Federici, Council of Republicans for Environmental Advocacy, and 

Jack Abramoff, Greenberg Traurig (GTG–E000105067) (January 3, 2002). 65 Id. The Committee notes the apparent inconsistency between Abramoff’s statement in this 

email and other older emails (some of which the Committee has cited to above) in which 

Abramoff professes to have a close relationship with Griles. 

Fitial’s travel expenses to Washington, D.C. in the future and 

‘‘schedule [a] meeting with Gale.’’ 56

Likewise, in an email dated May 7, 2001, entitled, ‘‘[former Louisiana Coushatta Chairman] Chief Poncho,’’ Federici asked 

Abramoff, ‘‘[i]s there something that I can do to say thank you for 

[Chief Poncho’s] support for CREA—besides the time with Sec. 

Norton [?].’’ 57

On July 18, 2001, less than a week after Griles arrived in office, 58 Abramoff wrote former Louisiana Coushatta counsel Kathryn Van Hoof and an associate covering the Tribe: 

I have a call into our guy Steve Griles, the Deputy Secretary and his assistant has a memo on the situation ... 

Just so I am clear when he and I do hook up, what is our 

full wish list at this point other than to inform him of the 

situation on the ground and the need, possibly, to get some 

positive signals from Norton to the Governor? 59

He concluded, ‘‘Just want to make sure I make all the asks we 

need.’’ 60

Afterwards, with Abramoff apparently having induced at least 

one of his Tribal clients into contributing to CREA in connection 

with the September 2001 private dinner, Federici wanted to help 

with Abramoff’s book of business. In an email dated January 2, 

2002, entitled ‘‘dates for another dinner [sic],’’ Federici proposed to 

Abramoff another CREA dinner at a private residence.61 According 

to this email, Federici offered to ‘‘target’’ intergovernmental relations officials from agencies that Abramoff ‘‘need[ed] to work with 

on CNMI and Indian issues.’’ 62 Abramoff was amenable to the 

idea.63 In a similar email, Federici held out the possibility that she 

could get Abramoff together with Griles and former Assistant Secretary for Indian Affairs Neil McCaleb for a small lunch or dinner.64 Abramoff responded, ‘‘A small lunch with Steve would be 

huge for us, since we really need to get to know him.’’ 65 There can 

be no doubt that a ‘‘CREA dinner’’ that focused on Abramoff’s lobbying needs and ‘‘target[ed]’’ agencies that Abramoff ‘‘need[s] to 
233 

66 Email between Italia Federici, Council of Republicans for Environmental Advocacy, and Jack Abramoff, Greenberg Traurig (GTG–E000253568) (January 2, 2002). 67 Email between Italia Federici, Council of Republicans for Environmental Advocacy, and 

Jack Abramoff, Greenberg Traurig (GTG–E000105202) (January 9, 2003). 68 Id. 69 Id. 70 Email from Italia Federici, Council of Republicans for Environmental Advocacy, to Jack 

Abramoff, Greenberg Traurig (SENCREA 10/04 000057) (January 9, 2003). 71 Email between Jack Abramoff, Greenberg Traurig, and Italia Federici, Council of Repub- licans for Environmental Advocacy (SENCREA 10/04 000062) (January 21, 2003). 72 Id. 73 Id. 74 Email between Jack Abramoff, Greenberg Traurig, and Italia Federici, Council of Repub- licans for Environmental Advocacy (SENCREA 10/04 [illegible]) (April 3, 2003). 75 Id. 

work with on CNMI and Indian issues’’ 66 had little to do with 

CREA’s tax exempt purpose. 

C. CONTRIBUTIONS IN EXCHANGE FOR ACCESS?

A number of records indicate that Federici promised to help 

Abramoff’s clients in contemplation of continued contributions from 

Abramoff’s clients to CREA. Among those records is a January 9, 

2003, email between Federici and Abramoff, entitled ‘‘help??!!,’’ in 

which Federici asked Abramoff, ‘‘I hate to bother you with this 

right now, but I was hoping to ask about a possible contribution 

for CREA ... [we] have started out the new year with practically 

nada. I thought I’d see if there was any way you could help us 

reach out to some of your folks who were so generous last year?’’ 67

Abramoff responded, ‘‘Absolutely. We’ll get that moving asap. 

[REDACTED] are coming to DC [REDACTED] so I’ll hit them immediately.’’ 68

But, he continued, ‘‘By the way[,] Gov Foster ... just sent Gale 

another letter pushing a new compact he signed for [J]ena. Can 

you make sure Steve [Griles] knows about this and puts the kibosh 

on it? Thanks.’’ 69

Federici promised, ‘‘I will tell him where they are now—and with 

whom. Thanks Jack!’’ 70

Likewise, in an email from Abramoff to Federici, dated January 

21, 2003, entitled ‘‘Intel from Dept of Int/BIA,’’ Abramoff asked 

Federici if she could help him get inside information on BIA action 

on a pending matter affecting the Louisiana Coushatta, one of 

Abramoff’s clients and a major contributor to CREA.71 In the very 

next sentence, he told Federici that a contribution from one of his 

clients was on the way: ‘‘I’ll have it in a week or so. I’m still working on the rest.’’ 72

In response, Federici wrote, ‘‘Thanks Jack! I will ask about the 

timing and content and call you.’’ 73

Similarly, in an April 3, 2003, email entitled, ‘‘urgent alert—DOI 

Proposes Policy Changes in Compact Review Process,’’ Abramoff attached a memo on this issue to an email to Federici and wrote, ‘‘If 

this attached memo is correct, someone over at BIA is doing some 

really odd things. Any way to see if this is something coming from 

the top? All of our tribes are very agitated about this one.’’ 74

In response, Federici wrote, ‘‘I will definitely see what I can find 

out. I hate to bug you, but is there any news about a possible contribution from [REDACTED]?’’ 75
234 

76 Email from Jack Abramoff, Greenberg Traurig, to Italia Federici, Council of Republicans for Environmental Advocacy (SENCREA 10/04 000094) (April 10, 2003). 77 Email between Jack Abramoff, Greenberg Traurig, and Italia Federici, Council of Repub- licans for Environmental Advocacy (SENCREA 10/04 000100) (May 1, 2003) (emphasis in original). 78 Id. 79 Email between Italia Federici, Council of Republicans for Environmental Advocacy, and Jack Abramoff, Greenberg Traurig (SENCREA 10/04 000110) (August 2, 2003). 80 Id. 81 Email between Jack Abramoff, Greenberg Traurig, and Italia Federici, Council of Repub- licans for Environmental Advocacy (SENCREA 10/04 000018) (January 26–27, 2002). 82 Id. 83 Id. 84 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000010914) (February 15, 2002). 85Deposition of Italia Federici, president, Council of Republicans for Environmental Advocacy, in Washington, D.C. (October 7, 2005). According to Federici, Abramoff elaborated that ‘‘his 

work product and his clients were being mistreated and not treated equitably, not treated the 

way other lobbyists’ clients were being treated.’’ Id. 

Additionally, in an email from Abramoff to Federici, dated April 10, 2003, Federici discussed the costs associated with a CREA program. In response, Abramoff wrote, ‘‘I met last night with [a client]. They offered [REDACTED] but I felt badly asking them since 

they are not getting any cooperation yet. Perhaps once the court 

case clears in a few weeks Steve [Griles] might be able to grab control of this. [T]hey are great folks.’’ 76

Another example is contained in two emails from Abramoff to 

Federici, dated May 1, 2003. There, referring to a matter pending 

before Interior, Abramoff told Federici that the BIA is ‘‘about to 

screw the Coushattas, and the other tribes there as well’’ and 

asked ‘‘[c]an you bring this to [Steve Griles’] attention? We MUST 

get this stopped.’’ 77 About an hour later, Abramoff reported to 

Federici that one of his clients was going to send over a contribution to CREA the following week.78

In an email dated August 2, 2003, and entitled ‘‘Saginaw Cost Share,’’ Federici responded to an email from Abramoff regarding an 

apparently unrelated tribal issue pending before Interior.79 There, 

Federici invited Abramoff to call her ‘‘if there is an urgent matter’’ 

and said that she will ‘‘try to talk to someone about this first 

thing.’’ 80

Still another example can be seen in the email between Abramoff 

and Federici, dated January 26, 2002, entitled, ‘‘Hi Italia.’’ There, 

Abramoff asked Federici for an update on getting the chief of one 

of his Tribal clients a meeting with then-Secretary Norton.81 In the 

very next sentence, he gave Federici an update on a contribution 

to CREA from one of his clients.82 In the same email stream, he 

insisted that Federici needed to get information related to the Jena 

Band’s efforts to get a compact, to Griles ‘‘immediately.’’ 83 A few 

weeks later, in an email, dated February 15, 2002, between 

Abramoff and Scanlon, entitled ‘‘shit,’’ Abramoff described a phone 

call he received from Federici about information she obtained from 

Griles about the Jena deal.84

In testimony before the Committee, Federici attempted to explain away her solicitousness for Abramoff’s practice as generosity or, in 

her words, ‘‘to be nice’’—acts of kindness in the face of complaints 

by Abramoff, ‘‘consistent ... over the course of years,’’ that the Bureau of Indian Affairs (‘‘BIA’’) was ‘‘in the back pocket of people 

who didn’t like him’’ and that his work-product and clients were 

not being treated fairly by Interior.85 Federici maintained that she 
235 

86 Id. 87See id. 88 It is notable that, during her deposition, Federici admitted that she never mentioned 

Abramoff’s concerns about BIA being ‘‘in the back pocket’’ of others, to Griles. Id. 89 Interview of J. Steven Griles, former Deputy Secretary, U.S. Department of the Interior, in 

Washington, D.C. (October 20, 2005). 90 Id. 91 Id. 92Deposition of Italia Federici, president, Council of Republicans for Environmental Advocacy, 

in Washington, D.C. (October 7, 2005). See also Email between Jack Abramoff, Greenberg 

Traurig, and Italia Federici, Council of Republicans for Environmental Advocacy (GTG– 

E000105153) (September 24, 2002). 93 Id. 94Deposition of Italia Federici, president, Council of Republicans for Environmental Advocacy, 

in Washington, D.C. (October 7, 2005). 95 Id. 

was sympathetic to Abramoff’s concerns about not being able to get 

a meeting on a timely basis or get answers to basic questions.86

And, she insisted, with her friend Griles serving as the chief operating officer at Interior, she was happy to help a friend.87

Federici’s explanation is unconvincing. The documents described 

above suggest that Federici promised to help Abramoff with Interior because of, or in exchange for, Abramoff’s directing his clients 

to contribute to CREA.88 Indeed, contributions from Abramoff’s 

Tribal clients were critical to CREA. During a Committee hearing, 

Federici admitted that Abramoff and his clients contributed about 

$500,000 over the relevant period. Also, during his deposition, 

Griles told Committee staff that one evening Federici called him 

very upset after money from Abramoff’s clients stopped coming 

in.89 Griles recalled that Federici complained that because ‘‘Jack is 

not giving us funds anymore,’’ she had to ‘‘go back and find more 

money in order to keep [CREA’s] activities going.’’ 90 Griles recalled 

simply telling Federici that she had to go back to contributors who 

helped her in the past.91

Federici’s explanation that she was motivated strictly by friendship and generosity is also belied by at least one occasion when 

Federici apparently lied to Abramoff about a promise to communicate with Griles. In an email, dated September 24, 2002, 

Abramoff asked Federici for a favor: to ask Griles to mention him 

to a Tribe with which Griles was meeting.92 To this request, 

Federici responded, ‘‘I will remind him about that and I’m sure he’d 

love to mention your help.’’ 93 However, in her deposition, Federici 

dismissed the email, saying that she did not approach Griles about 

this because she actually thought Abramoff’s request was 

‘‘cheesy.’’ 94 But, she never told Abramoff that she decided not to do 

as she had originally promised.95 Why not? Likely to ensure that 

Abramoff would continue directing his clients to make significant 

contributions to CREA. 

Vice Chairman Dorgan summarized Federici’s testimony, and the 

Committee’s skepticism of her testimony, at a recent hearing: ‘‘You 

are an environmental organization. You come into a lot of money 

from Indian tribes. My guess is that that money had nothing to do 

with generosity, or had very little to do with energy or the environment, but had a lot to do with Mr. Abramoff saying to his contacts 
236 

96 ‘‘Tribal Lobbying Matters’ Hearings before the Committee on Indian Affairs, 109th Cong. at 

31 (November 17, 2005). 97 Id. at 32. 98 Id. at 33. 99Deposition of Italia Federici, president, Council of Republicans for Environmental Advocacy, 

in Washington, D.C. (October 7, 2005). 100 Email from Jack Abramoff, Greenberg Traurig, to Italia Federici, Council of Republicans for Environmental Advocacy (SENCREA 10/04 000110) (August 21, 2003). 101Deposition of Italia Federici, president, Council of Republicans for Environmental Advocacy, in Washington, D.C. (October 7, 2005). 102 Id. 103 Id. 104 Id. 

in these tribes, ‘I want you to stick money into Ms. Federici’s organization,’ and they did.’’ 96

At the same hearing, the Vice Chairman succinctly described the Committee’s belief of why Abramoff’s clients contributed so much 

to CREA, as follows: 

I am just telling you that our records are full of these 

things. It is full of references to the duties that you were 

performing [or promised to perform] for Mr. Abramoff. 

Those duties had to do with the term ‘juice’ that also exists 

in our set of records. You had ‘juice.’ You got paid for that 

‘juice’ by having Mr. Abramoff direct funds to your organization, and you spent a lot of time in your correspondence 

back and forth with Mr. Abramoff about what you are 

doing; not about the environment; not about energy; [but 

about] all of these issues that have to do with Mr. 

Abramoff. It looks to me like you were working for Mr. 

Abramoff and you were getting money from Indian tribes 

to do it. That’s what it looks like to me.’’ 97

He also observed, ‘‘The way you describe it in this testimony is the Indian tribes are generous; Jack is generous; everybody is generous. That is unbelievable to me.’’ 98 It is unbelievable to the Committee. 

D. WHAT DID FEDERICI DO FOR ABRAMOFF AT INTERIOR?

In her deposition with Committee staff, Federici said that she 

could only remember talking to Abramoff about three issues—a 

‘‘school cost-share’’ issue, relating to the Saginaw Chippewa; the 

Gun Lake Tribe’s land-into-trust application; and the Jena Band’s 

attempts at getting land-into-trust and a compact in Louisiana.99

For the Saginaw Chippewa, Abramoff asked Federici to help him with former Interior Deputy Secretary Griles on a ‘‘school cost 

share program.’’ 100 This was one context that, according to Federici, Abramoff told her that the BIA was in the back-pocket of 

people who did not like him and that his clients were not being 

treated fairly. Consequently, Federici testified, she felt bad for 

Abramoff and thought she could help with Griles.101 But, when 

Abramoff sometimes asked her to get Griles to ‘‘kill’’ this or ‘‘put 

the kibosh’’ on that, she never told him that she would not do any 

of it or ever correct him, she said.102 She wasn’t ‘‘going to correct 

a 50-year old, male, conservative activist leader, [and] you know, 

donor.’’ 103

About the ‘‘school cost share’’ program, Federici denied having 

had a substantive conversation with Griles.104 According to 
237 

105 Id. 106 Id. 107 Id. 108 Id. 109 Id. 110 Id. 111 Id. 112 Id. 113 Email between Jack Abramoff, Greenberg Traurig, and Italia Federici, Council of Repub- licans for Environmental Advocacy (SENCREA 10/04 035) (September 24, 2002). 114 Id. 115 Email between Jack Abramoff, Greenberg Traurig, and Italia Federici, Council of Repub- licans for Environmental Advocacy (GTG–E000024441) (December 4, 2002). 116 Id. 117 Email between Jack Abramoff, Greenberg Traurig, and Italia Federici, Council of Repub- licans for Environmental Advocacy (SENCREA 10/04 000041) (December 6, 2002). 118 Id. 

Federici, she merely mentioned to Griles, ‘‘Is anybody paying attention to what’s going on with the school cost share [?]’’ 105 Otherwise, 

she recalled only having repeated Abramoff’s ‘‘line’’ that excluding 

the Saginaw was ‘‘unfair’’; that his ‘‘[clients] [weren’t] being treated 

adequately’’; and that ‘‘[M]embers of Congress are worked into a 

frenzy.’’ 106 Regarding her interaction with Griles on these and 

similar issues, Federici insisted, ‘‘[T]hese were not conversations. 

These were mentions and sort of heads-up ...’’ 107

The Gun Lake Tribe’s application for land-into-trust also had the 

potential to negatively affect the Saginaw Chippewa. Federici could 

only recall that Abramoff told her that Interior was ‘‘directly going 

against what Steve wanted.’’ 108 However, Federici has no recollection of having talked with Griles about that issue.109

Finally, regarding the Jena Band’s efforts to get a compact and 

land-into-trust, which would have harmed the Louisiana 

Coushatta, Federici testified that Abramoff told her that key conservatives, including James Dobson and Ralph Reed, were writing 

in opposition.110 As a result, Federici recalls, she just made sure 

that Griles knew that ‘‘conservatives were upset’’ and were calling 

into Interior in droves.111 According to Federici, the foregoing reflects her memory about her discussions with Abramoff about matters affecting his clients and her communications with Griles about 

those issues.112

However, documents indicate that Federici at least promised 

Abramoff that she would liaise with Griles more extensively than 

she has admitted to the Committee. For example, according to a 

September 24, 2002, email, Abramoff asked Federici to talk to 

Griles about a ‘‘Tigua water issue.’’ 113 Federici responded, ‘‘I am 

calling right now.’’ 114 Similarly, in an email dated December 4, 

2002, entitled ‘‘[G]un [L]ake [I]ndian [T]ribe [C]asino,’’ Abramoff 

complained to Federici about developments relating to this Tribe 

and conveyed to Federici a strategy, regarding that Tribe’s environmental impact report, to shut down its land-into-trust application.115 Federici responded, ‘‘I will call [Steve Griles] asap.’’ 116

Also, in another email dated December 6, 2002, entitled ‘‘Gun 

Lake: New Hope For Gun Lake Casino,’’ Abramoff urged Federici, 

‘‘[T]his is what we have to stop.’’ 117 Federici responded, ‘‘seeing 

him at 4pm today.’’ 118

In a related email dated March 6, 2003, and entitled ‘‘Saginaw 

Chippewa Tribe—School Cost Share,’’ Abramoff asked Federici ‘‘if 
238 

119 Email between Jack Abramoff, Greenberg Traurig, and Italia Federici, Council of Repub- licans for Environmental Advocacy (GTG–E000027919) (March 6, 2003). 120 Id. 121 Email between Jack Abramoff, Greenberg Traurig, and Italia Federici, Council of Repub- licans for Environmental Advocacy (SENCREA 10/04 000039) (December 2, 2002). 122 Id. 123 Email from Jack Abramoff, Greenberg Traurig, to Michael Scanlon, Capitol Campaign Strategies (GTG–E000010914) (February 15, 2002). 124 Id. 125 Email between Jack Abramoff, Greenberg Traurig, and Italia Federici, Council of Repub- licans for Environmental Advocacy (SENCREA 10/04 000062) (January 21, 2003). 126 Id. 127 Email between Jack Abramoff, Greenberg Traurig, and Italia Federici, Council of Repub- licans for Environmental Advocacy (SENCREA 10/04 000075) (March 9, 2003). 128 Id. 129Deposition of Italia Federici, president, Council of Republicans for Environmental Advocacy, in Washington, D.C. (October 7, 2005). 130 Id. 131 Id. 

[she] can call Steve on this.’’ 119 She responded, ‘‘got it.’’ 120 Additionally, in an email from Abramoff to Federici, dated December 2, 

2002, entitled ‘‘Jena Band: Panel, Logansport asked to speak on 

proposed casino–Shreveport Times,’’ Abramoff wrote, ‘‘It seems that 

the Jena are on the march again. [I]f you can, can you make sure 

Steve squelches this again?’’ 121 Federici responded, ‘‘Thanks for the 

update. I’ll bring it up asap!’’ 122

Likewise, in an email from Abramoff to Scanlon, dated February 

15, 2002, entitled ‘‘shit,’’ Abramoff wrote that he ‘‘just got a call 

from [Federici].’’ 123 According to that email, Federici apparently 

provided Abramoff with then-nonpublic information she indicated 

that she had gotten from Griles that ‘‘as of now, Norton is going 

to sign the Jena deal.’’ 124 Similarly, in an email dated January 21, 

2003, entitled ‘‘Intel from dept of Int/BIA,’’ Abramoff asked Federici 

if there is ‘‘any way to find out’’ when and how the BIA will respond to a letter from Governor Foster about a new Jena casino.125

Federici responded, ‘‘Thanks, Jack! I will ask about the timing and 

content and call you. ...’’ 126 Abramoff also reached out to Federici 

about the Jena Band’s casino proposal in another email, dated 

March 9, 2003, entitled ‘‘Jena Choctaw Update.’’ 127 Then, Federici 

responded, ‘‘I will call you on Monday with whatever I can find 

out.’’ 128 These emails stand for a modest, but important, proposition: that Abramoff repeatedly asked Federici to contact Griles on 

issues important to his clients—the same clients that contributed 

to CREA—and that Federici promised to help. 

In attempting to explain away those emails, Federici suggested 

that she did not necessarily follow-through on Abramoff’s requests.129 She explained that after she received such ‘‘hair-on-fire’’ 

emails from Abramoff requesting that she talk to Griles, she would 

say ‘‘I’ll call’’ or ‘‘something like that.’’ 130 But, Federici testified, 

‘‘[a]nd if I said yes, I’ll try to call Steve, and I couldn’t reach Steve, 

it’s not like anybody was, you know, necessarily—it could just completely drop off his plate until the next hair-on-fire email, you 

know. I just figured Jack was throwing stuff against the wall. 

Maybe somebody else sorted it out.’’ 131 Federici elaborated as follows: 

I would say, I’ll call. But the gist of the email. If he would 

say—Jack, I think some of them are almost comical. It’s 

like his hair is on fire: Oh my God, this is happening and 
239 

132 Id. 133 Id. Federici elaborated, ‘‘The whole cost share, just the whole like—you know, to the best 

of my recollection it was like oh my God, Senator this and Senator that, the Senate’s leaving 

in a half an hour and this is going to expire, and why are they doing this, that, and the other 

thing. And it was just like, you know—I think my initial response to that was, I don’t care. 

And then, you know: But you have to care; it’s about money for school for poor kids and it’s 

$3 million, this is terrible. I mean, it was just way over the top. It was too much pressure on 

me.’’ Id. 134 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. at 89 (November 2, 2005). See, e.g., ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee 

on Indian Affairs, 109th Cong. at 89 (November 2, 2005) (testimony of J. Steven Griles, former Deputy Secretary, Department of the Interior); Letter from Barry M. Hartman, Esq., counsel 

to J. Steven Griles, Kirkpatrick & Lockhart Nicholson Graham, to Pablo E. Carrillo, Esq, Chief 

Investigative Counsel, U.S. Senate Committee on Indian Affairs, January 3, 2006; Letter from 

Barry M. Hartman, Esq., counsel to J. Steven Griles, Kirkpatrick & Lockhart Nicholson 

Graham, to the Honorable John McCain, U.S. Senate Committee on Indian Affairs, April 6, 

2006. 135 Interview of J. Steven Griles, former Deputy Secretary, U.S. Department of the Interior, in Washington, D.C. (October 20, 2005) (‘‘That was my vision, and there was nothing unique 

about it.). 136 Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in 

Washington, D.C. (September 13, 2005). 137 Id. 

that’s happening. By the way, great to see you tonight. It’s 

like, you know, you go back and you read some of these. 

So, if he said, you know, I’m having a problem, this problem with the Saginaw thing, again with the school cost 

share, this Saginaw thing, this Saginaw thing, can you— 

or the Jena, you know. ... I mean, I would just take that 

information and digest it down into what it, the components that it actually was, which is Jack’s worried about 

Jena. And ... if I said I would call Steve I would try to 

reach him. But if he was traveling or giving a speech or 

something and a few days passed, I wouldn’t try to take 

it back up again. I mean, again it’s something I was just 

doing to be polite to Jack. It’s not my job, and I was actually doing CREA work.132

Federici underscored that while she originally helped Abramoff 

with his Tribal clients vis-a-vis Griles ‘‘to be nice, ... after the Saginaw thing it was just, it was way too stressful and, frankly, not my 

job.’’ 133 But, having repeatedly promised Abramoff that she would 

speak with Griles on matters at Interior affecting his Tribal clients, 

she was all too willing to continue accepting significant tribal ‘‘contributions’’ from Abramoff. 

E. WHAT, IF ANYTHING, GRILES DID FOR ABRAMOFF’S CLIENTS IS

UNCLEAR

Griles repeatedly testified that Abramoff had no special access to 

him.134 In his deposition, Griles agreed that ‘‘[Abramoff] was another lobbyist with whom he did business. Just as [he] did business 

with many others in town.’’ 135

However, some evidence suggesting that Griles may have assisted Abramoff gives rise to concern. Former Louisiana Coushatta 

Tribal councilman William Worfel testified that Abramoff told him 

that he would approach Griles about stopping the Jena Band of 

Choctaw Indians’ attempt to get a compact in Louisiana.136 Worfel 

recalls that Abramoff ultimately told him that Griles helped kill, 

or helped convince the Secretary to reject, the Jena compact.137
240 

138 Id. 139 Interview of Stephanie Leger Short, former associate, Greenberg Traurig, in Washington, D.C. (August 18, 2005). 140 Id. 141 Id. 142 Id. 143 Interview of William Worfel, former Vice-Chairman, Coushatta Tribe of Louisiana, in 

Washington, D.C. (September 13, 2005). 144 Id. 145 Id. 146 Id. 147 Id. 148 Interview of J. Steven Griles, former Deputy Secretary, U.S. Department of the Interior, in Washington, D.C. (October 20, 2005). 149 Id. 150 Id. 151 Id. 

During his interview, Worfel also told staff that Abramoff’s lob- bying associate Stephanie Leger Short told him that Griles was 

also supposed to help the Tribe with economic development 

grants.138 In her interview, Short, who formerly managed the Lou- isiana Coushatta account for Abramoff, testified that Abramoff described Griles as ‘‘[his] guy’’ and was always ‘‘going to call Griles’’ 

and ‘‘get on Griles.’’ 139 Based on Abramoff’s comments, Short understood that Abramoff and Griles were ‘‘close’’: ‘‘When things got 

hairy with Coushatta, it was always [that Abramoff] was going to 

call Griles and see what he could do.’’ 140 Regarding the Louisiana Coushatta, Griles’ name came up mostly during the Jena Band’s efforts in Logansport and Vinton, Louisiana.141 It also came up, according to Short, on an Agua Caliente tax issue and an issue regarding the Choctaw.142 According to Worfel, Abramoff said that Griles was willing to help the Tribe because of its ‘‘contribution’’ to 

CREA, which made the Tribe ‘‘a friend of Interior.’’ 143

Worfel also stated that Abramoff told him that he interviewed 

Griles for his position at Interior and, in fact, helped him get his 

job there.144 He also recalled that Abramoff mentioned Griles’ 

name many times and said that they were ‘‘close.’’ 145 From his conversations with Abramoff, Worfel thought of Griles as Abramoff’s 

‘‘point man’’ or ‘‘inside man’’ at Interior: ‘‘[t]hat was his person. 

Boom, he could pick up the phone and Griles—it was like Griles 

worked for him.’’ 146 At his interview, Worfel told Committee investigators, ‘‘The only thing I can tell you is I’ve said Steve Griles’ 

name about 20 times since we started this [interview]. [In the context of getting help for the Tribe,] Jack Abramoff said Steve Griles’ 

name maybe 200 times.’’ 147 Worfel’s recollection about what 

Abramoff told him about how Griles could help his Tribe is consistent with the accounts of other Tribal representatives. 

Notwithstanding the testimony and documents described above, 

Griles could recall only one or two conversations with Federici concerning Abramoff’s Tribal clients.148 In that conversation, Griles remembered Federici saying only something to the effect of ‘‘I was 

talking [to] Jack Abramoff, he really would like for you to give him 

a call.’’ 149 Griles said he believed that this communication may 

have been related to ‘‘an Indian insurrection question.’’ 150 Nor does 

Griles recall Federici’s asking him to help Abramoff’s clients.151

Griles denied talking with Federici about matters that, according 

to documents, Abramoff asked her to discuss with him. In his interview, Griles stated, ‘‘I don’t recall Ms. Federici ever mentioning 
241 

152 Id. 153 Id. 154 Id. 155 Id. 156 Id. 157 Id. 158 Id. 159 Id. 160 Id. 161 Id. 162 Id. 163 Id. 164 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. at 91 (November 2, 2005) (Rossetti’s testimony). 165 Id. at 92 (Griles’ testimony). In an interview with Committee staff, former Abramoff associate Stephanie Leger Short indicated that she prepared the binder. Interview of Stephanie 

Continued 

Gun Lake to me.’’ 152 Similarly, Griles held that he did not ‘‘recall ever having a discussion on a Tigua tribe or a water issue with 

anyone.’’ 153 Griles also stated that he did not ‘‘recall receiving any information from Ms. Federici on Bay Hills [sic].’’ 154 Likewise, 

when asked about Abramoff or Federici asking him to pull [BIA 

personnel] from the Choctaw elections, Griles asserted ‘‘I don’t recall ever hearing of the issue.’’ 155 Griles’ recollection failed him 

again when he stated ‘‘I don’t recall any discussion with [Abramoff] 

about Mashpee. I didn’t do tribal recognitions.’’ 156 Correspondingly, Griles did not ‘‘recall a conversation with [Federici] either’’ regarding the Mashpee recognition.157 Griles later declared, ‘‘I don’t recall 

today having any discussions with [Federici] about [the Jena Band 

compact].’’ 158

Committee staff tried to explore the precise nature of Griles’ relationship with Abramoff and whether Griles did anything to further 

the interests of Abramoff’s clients on matters pending at Interior. 

To that end, a discussion about a binder ensued. During his interview, Griles stated that one day he returned to his office to find 

a mysterious binder with no name on his desk.159 After inquiring where the binder came from, his secretary told him that it had 

been delivered to the front desk, and he decided to ‘‘just [flip] 

through it.’’ 160 Skimming the documents he discovered that the notebook was actually a packet of information about the Jena Band 

and ‘‘looked like it had letters—congressional letters, it had studies 

or something in it.’’ 161 Accordingly, Griles remembered asking Sue Ellen Wooldridge, Counselor to the Interior Secretary, what to do 

with the notebook and was informed that it was now a federal 

record and that he had ‘‘no option except to give it to Interior lawyer Michael Rossetti.’’ 162 Griles maintained that he gave the note- book to Rossetti and ‘‘didn’t endorse its contents.’’ 163

Rossetti, however, has a different recollection of those events. 

Rossetti recalled that only after ‘‘some time’’ and ‘‘a series of questions that took much longer to get to that answer than I would 

have thought was necessary,’’ Griles actually told him where the 

binder came from: from a member of Congress by way of a chief 

of staff by way of a lobbyist ‘‘who turned out to be Mr. 

Abramoff.’’ 164

Griles strenuously disagreed: ‘‘I did not say it came from Mr. 

Abramoff. I did not say it came from Congress. I speculated that 

it could have come from any of those sources. I did not know and 

I do not know today where it came from.’’ 165 Griles testified that 
242 

Leger Short, former associate, Greenberg Traurig, by telephone (June 16, 2006). She explained 

that in the binder, which was actually one of about 15 or so, she inserted letters opposing the 

Jena Band’s land-into-trust application, applicable sections of the Indian Gaming Regulatory Act 

(‘‘IGRA’’), and other related documents. Id. She also noted that, while some copies went to members of the Louisiana delegation, she was ‘‘99 percent sure’’ that Abramoff was supposed to get 

a copy to the U.S. Department of the Interior. Id. But, she had no recollection of Abramoff’s 

mentioning Griles at the time. Id. 166 ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th Cong. at 92 (November 2, 2005). 167 Id. at 99. 168 Id. 169 Id. 170 Id. 171 Interview of Michael Rossetti, former counselor to the Secretary, U.S. Department of the Interior, in Washington, D.C. (October 28, 2005). 172 Id. 173 Id. 174 Id. 175 Id. 176 Id. 177 Id. 

the conversation concluded with his advising Rossetti ‘‘to please 

make sure the Secretary knew that there were all sides of this 

issue, and please brief her on that.’’ 166

With regard to the charge that Griles tried to insinuate himself in matters pending at Interior affecting Abramoff’s Tribal clients, 

Rossetti’s account is again fundamentally different from Griles. 

Rossetti recalls that Griles became involved with the Jena’s landinto-trust application issue the second time it was brought up at 

Interior.167 Rossetti testified that Griles had several discussions 

with him during which Griles requested to be involved in his meetings with career employees and the Secretary about a possible decision on the Tribe’s application.168 Rossetti said that those discussions took place twice in a hallway and in Rossetti’s office and that 

he thought that it was unusual that Griles was so concerned about 

those meetings.169 He speculated that Griles was worried that 

some secret discussion might be taking place.170 Rossetti stated 

that he assured Griles that Griles would be there at the meeting.171

Rossetti testified that Griles’ attendance at a meeting regarding Abramoff’s clients came up again.172 At that time, Rossetti asked 

Griles, ‘‘[w]hy is this issue so important to you?’’ 173 According to Rossetti, Griles simply replied, ‘‘I just want to be at the meeting.’’ 174 On a third occasion, Rossetti asked Griles, ‘‘[w]hat’s your deal? What do I need to know? Are there any outside voices that 

I need to know about?’’ 175 At that point, according to Rossetti, Griles ‘‘turned purple’’ and immediately left.176 Ultimately, Rossetti said, Griles told him that he did not have to be at that meeting 

and did not attend.177

Relevant to understanding the full extent of Griles’ relationship with Abramoff are any communications that Griles may have had 

with Abramoff about possibly working at Greenberg Traurig. According to a July 17, 2003, email from Abramoff to Federici, whatever direct line of communication Abramoff had with Griles was 

disrupted: 

Hi there. Are you around for a chat? I am in a most difficult situation regarding Interior and need your advice. 

Steve [Griles] is nothing but a gentleman and great guy to 

me, but he can’t (or at least won’t) discuss any of my cli-
243 

178 Email from Jack Abramoff, Greenberg Traurig, to Italia Federici, Council of Republicans 

for Environmental Advocacy, ‘‘FW: Griles’ (SENCREA 10/04 000108) (July 17, 2003). While 

Federici’s answer to this email is unknown, she recalled this email during her deposition. Deposition of Italia Federici, president, Council of Republicans for Environmental Advocacy, in Washington, D.C. (October 7, 2005). She testified that she never asked Abramoff or Griles about why 

Griles was not ‘‘discussing [Abramoff’s] clients with [him]’’: ‘‘I didn’t ask Jack because I didn’t 

want to pry and I didn’t raise it with Steve [Griles] because I knew better.’’ Id. She elaborated, 

‘‘I [knew] that if Steve’s not going to talk with somebody he’s not going to talk with them ...’’ 

Id. 179 Email from Jack Abramoff, Greenberg Traurig, to Kevin Ring; Todd Boulanger; Michael 

Williams; and Duane Gibson, Greenberg Traurig; ‘‘Griles’ (Bates number 56340) (September 9, 

2003). Exactly when and where this conversation occurred, much less what was discussed, remains unclear. 180See Event Reminder from Jack Abramoff, Greenberg Traurig, to self, ‘‘Steve Griles and 

Fred Baggett—Sigs’ (Bates number 100878) (undated) (indicating that meeting was to occur on 

‘‘Mon 1/12/2004 [from 5:00 p.m.–6:00 p.m.]’’). Griles best recollection is that this meeting might 

have occurred sometime in 2003. See Interview of J. Steven Griles, former Deputy Secretary, 

U.S. Department of the Interior, in Washington, D.C. (October 20, 2005). 181 ‘‘Tribal Lobbying Matters’’ Hearings before the Committee on Indian Affairs, 109th Cong. 

at 104 (November 2, 2005). But see Interview of J. Steven Griles, former Deputy Secretary, U.S. 

Department of the Interior, in Washington, D.C. (October 20, 2005) (attributing statement to 

‘‘[e]ither [Abramoff or Baggett] or both’’). 182 Id. See also ‘‘Tribal Lobbying Matters’’ Hearings before the Committee on Indian Affairs, 

109th Cong. at 104 (November 2, 2005). 183 Id. 184 Interview of J. Steven Griles, former Deputy Secretary, U.S. Department of the Interior, 

in Washington, D.C. (October 20, 2005); ‘‘Tribal Lobbying Matters’’ Hearings before the Committee on Indian Affairs, 109th Cong. at 104 (November 2, 2005). 185 Interview of J. Steven Griles, former Deputy Secretary, U.S. Department of the Interior, 

in Washington, D.C. (October 20, 2005); ‘‘Tribal Lobbying Matters’’ Hearings before the Committee on Indian Affairs, 109th Cong. at 104 (November 2, 2005). 

ents with me. the [sic] problem is that, since he won’t do 

so, and since you are not able to chat with him now, I am 

left in a real dilemma. I can’t deliver anything from Interior for my clients. It is as if the Clinton guys are back in 

power. I don’t know what to do. I have a few clients that 

need answers, basic answers, from Interior, and I have no 

one to chat with. What should I do? 178

But, subsequently, on September 9, 2003, Abramoff wrote to 

some of his associates: ‘‘This cannot be shared with anyone not on 

the distribution list. I met with [Griles] tonight. He is ready to 

leave Interior and will most likely be coming to join us ... I expect 

that he will be with us in 90–120 days.’’ 179

Apparently, on or about January 12, 2004, Griles and Abramoff 

met with Greenberg Traurig lobbying practice head Fred 

Baggett.180 In testifying before the Committee, Griles stated that 

‘‘[a]t the end of [the meeting], they said, we would like for you to 

join our firm.’’ 181 Griles insisted that he merely ‘‘politely listened’’ 

and replied, ‘‘I’m not leaving the Federal Government.’’ 182 Griles 

testified that he had made the determination that he was going to 

serve through ‘‘the 4 years of the President before [he] left.’’ 183 According to Griles, he then returned to Interior and spoke with the 

agency ethics officer and the deputy ethics officer at Interior about 

the discussion.184 Griles remembered that these ethics officials told 

him that this meeting triggered no waiver or recusal obligations— 

he did not have to do anything.185

In contrast to Griles’ recollection that ‘‘they,’’ that is, Abramoff 

and Baggett, told him that ‘‘we would like for you to join our firm,’’ 

in his interview with Committee staff, Baggett described the meeting as merely ‘‘introductory’’ and maintained that he never talked 
244 

186 Interview of Fred Baggett, Chair, National Government Affairs Practice, Greenberg 

Traurig, in Washington, D.C. (September 29, 2005). 187 Id. 188 Email from Jack Abramoff, Greenberg Traurig, to DCCasino, Greenberg Traurig, ‘‘Griles’’ 

(Tracking Number 3707795) (February 3, 2004). 189See Interview of J. Steven Griles, former Deputy Secretary, U.S. Department of the Interior, in Washington, D.C. (October 20, 2005). 

to Griles about coming to work at Greenberg Traurig.186 Baggett also indicated that he had no knowledge about Abramoff (or anyone 

else at Greenberg Traurig) having had employment discussions 

with Griles.187

Days after the meeting at Signatures, on February 3, 2004, Abramoff followed-up with his associates about the prospect of 

Griles’ joining Greenberg Traurig, writing simply, ‘‘Has decided he 

cannot leave the administration before the election.’’ 188 Griles categorically denied having had any other conversations with 

Abramoff about possibly working at Greenberg Traurig, other than 

this meeting.189

Based on the information in its possession, the Committee cannot 

definitively conclude what, if anything, Griles did to assist 

Abramoff’s clients on matters then pending at Interior. In its totality, the information described above supports relatively modest 

propositions, namely, that Abramoff believed that he had influence 

over Griles, either directly or through Federici; that Abramoff told 

others that he had a robust relationship with Griles or had some 

influence over decision-making at Interior; and that it was likely 

on that basis that he may have directed his Tribal clients to ‘‘contribute’’ to CREA. However, it must be carefully said that, without 

more evidence, it is plausible that, in fact relying on his relationship with Federici, Abramoff may have simply exaggerated his access to Griles to his clients. 

In any event, given the paucity of evidence in the Committee’s possession, the Committee is unable to arrive at any definitive conclusions as to the veracity of Griles’ testimony on his relationship, 

and interaction, with Abramoff during all times relevant. And, 

without a good faith basis for concern that Griles may have been 

untruthful with the Committee, further exploration is beyond the 

scope of the investigation. However, it should be noted that the 

Committee is troubled by the marked inconsistency between Griles’ 

and Rossetti’s testimonies on the narrow issue of whether Griles 

tried to insinuate himself in decision-making processes affecting any of Abramoff’s Tribal clients. It is also concerned about the implications of some of the fragmentary evidence discussed above. 

F. CONCLUSION

Over the last two years, the Committee’s investigation has 

sought to determine, among other things, whether monies paid by 

the Tribes at Abramoff or Scanlon’s direction to or through various 

entities were ultimately used for purposes intended by those 

Tribes. In the case of CREA, by Federici’s own admission, Abramoff 

and/or his clients contributed about $500,000 to the organization 

between 2001 and 2003. 

From the evidence discussed above, it appears that some of the 

Tribes were induced into paying CREA because Abramoff told 

them, among other things, that those payments would get them fa-
245 

190 A part of Federici’s testimony that concerns the Committee relates to the nature of CREA. 

When Federici appeared before the Committee on November 17, 2005, a Member asked her 

whether any of monies paid to CREA as contributions were ultimately used for purely personal 

purposes. ‘‘Tribal Lobbying Matters,’’ Hearings before the Committee on Indian Affairs, 109th 

Cong. at 49 (November 17, 2005). In response, Federici said, ‘‘No; not to the best of my recollection.’’ Id. at 38–40. Elsewhere in the hearing, Federici responded to a similar question, stating, 

‘‘No. I mean if money from CREA goes to me, it is salary or reimbursement.’’ Id. at 49. Therefore, an outstanding fact question is whether any of those expenses, for which Federici sought 

and received reimbursement, were purely personal in nature. Elsewhere, Federici testified, ‘‘But 

Senator, I was not abusing non-profit resources, okay?’’ Id. at 40. 

vorable treatment at Interior. The evidence also suggests that 

Federici may have led Abramoff into believing that she had pull at 

Interior and that she would use it in exchange for, or because of, 

contributions by Abramoff’s Tribal clients to CREA. Unfortunately, 

the extent to which Federici actually sought to influence Interior 

on pending matters affecting Abramoff’s clients remains unclear. 

Also unclear is what, if anything, Griles (who Abramoff believed 

was Federici’s contact at Interior) might have done on behalf of 

Abramoff’s clients at Interior and (if Griles did anything) what his 

motives for doing so might have been. 

Against that backdrop, the Committee is concerned about the veracity of Federici’s testimony on several important areas, discussed 

above.190 Additional inquiry into those areas by the appropriate authorities appears warranted. 

(247) 

PART FOUR—RECOMMENDATIONS 

A. INTRODUCTION

Over the past two years, the Committee on Indian Affairs (the ‘‘Committee’’) has developed a robust legislative record on the facts 

and circumstances surrounding Jack Abramoff and Michael Scanlon’s relationship with and representation of the Mississippi Band 

of Choctaw Indians (‘‘Choctaw’’), the Coushatta Tribe of Louisiana 

(‘‘Louisiana Coushatta’’), the Saginaw Chippewa Indian Tribe 

(‘‘Saginaw Chippewa’’), the Agua Caliente Band of Cahuilla Indians 

(‘‘Agua Caliente’’), the Ysleta del Sur Pueblo of Texas (‘‘Tigua’’), and 

the Pueblo of Sandia (collectively, ‘‘Tribes’’). After careful consideration of that record, the Committee makes the following observations and recommendations. 

B. CONTRACTING FOR LEGAL, LOBBYING AND OTHER PROFESSIONAL

SERVICES

1. No New or Revised Federal Legislation Needed 

The Committee has exhaustively examined Abramoff and Scan- lon’s ‘‘gimme five’’ scheme, by which the two bilked the Tribes out 

of tens of millions of dollars. Without doubt, the depth and breadth 

of their misconduct was astonishing. Nevertheless, with respect 

solely to the kickbacks from Scanlon to Abramoff, the Committee 

concludes that existing federal criminal statutes are sufficient to 

deter and punish such misconduct. 

Indeed, there is no better support for the Committee’s conclusion 

than Abramoff’s and Scanlon’s guilty pleas. On November 17, 2005, 

Scanlon pled guilty to, among other things, conspiracy (1) to defraud some of the Tribes under 18 U.S.C. §§ 1341 and 1343; and, 

(2) to defraud and deprive some of the Tribes of Abramoff’s honest 

services under 18 U.S.C. §§ 1341, 1343, and 1346. On January 3, 

2006, Abramoff pled guilty to, among other things, (1) conspiracy 

to commit mail and wire fraud under 18 U.S.C. §§ 1341 and 1343; 

(2) conspiracy to commit honest services wire and mail fraud, 

under 18 U.S.C. §§ 1341, 1343, and 1346; (3) honest services mail 

fraud under 18 U.S.C. §§ 1341 and 1346. 

That Abramoff and Scanlon perpetrated their kickback scheme 

against Indian tribes does not change the applicability or effectiveness of those statutes as tools to deter and punish such misconduct. 

The Committee sees no basis for treating Indian tribes differently 

than other similarly aggrieved parties in this respect. The Committee thus finds no reason or basis to carve out or create a special 

category for fraud against Indian tribes under federal law. 

2. Best Practices Recommendations 

Although the Committee does not believe that additional federal 

legislation is required to address Abramoff and Scanlon’s mis-
248 

conduct, it does recommend that tribes consider adopting their own 

laws to help prevent a similar tragedy. Over many years and innumerable scandals, the federal and state governments learned difficult lessons regarding appropriate decision-making processes 

when contracting for services. From these lessons a consensus has 

developed around core good governance principles. These principles 

embody a philosophy that focuses on providing sufficient information to constituents regarding the basis for decisions made by government officials, thereby fostering trust and confidence that governmental decisions are being made based on the best interests of 

the government and not of the individual decisionmakers. Accordingly, the federal and state governments have enacted laws and 

regulations addressing issues relating to contracting for services 

and conflicts of interests. 

Some Indian tribes have already adopted laws and regulations 

addressing some or all of these matters, while a significant number 

have not. The Committee strongly encourages those tribes that 

have not adopted such laws and regulations to enact laws and regulations that embrace the principles contained in the following recommendations. The Committee notes, however, that it is not recommending that Congress enact legislation mandating tribes to 

enact laws dealing with these subjects, but that the tribal governments themselves consider the following recommendations and determine for themselves whether enacting such laws might benefit 

the tribe and its members. Tribal governments, as the government 

closest and most responsive to tribal members, are best able to develop laws and regulations that appropriately take into account the 

unique history, cultural and legal authorities of a particular tribe. 

a. Contracting for legal, lobbying and other services should 

follow a specific, open and competitive process 

Tribal governments should consider adopting laws applicable to 

contracting for legal, lobbying or other professional services, at 

least when the cost of the services will exceed, or has the potential 

of exceeding, a certain threshold amount. Contracting for these 

services should not be an ad hoc decision of the tribal council or 

a tribal official but instead should follow a process that requires decision-makers to assess what it is that the tribe needs; determine 

the kinds of skills, experience and expertise the contractor must 

have in order to meet those needs; solicit contracting proposals 

from the applicable community of contractors or providers, based 

on a clearly articulated set of requirements; evaluate the responsive proposals in light of the stated requirements; perform appropriate background checks on responding contractors and providers; 

and document the contracting decision in writing. 

b. Contracting rules should be structured to prevent conflicts 

of interest 

Even a fair and open contracting process can be abused. Accordingly, contracting rules should include provisions calculated to prevent improper considerations in the contracting process—such as 

prohibitions against contracting decision-makers from receiving 

anything of value from persons or firms seeking to obtain or renew 

contracts with the tribe; requirements that tribal campaign con-
249 

tributions (including contributions of services or assistance) at or 

above a certain threshold dollar amount be publicly disclosed; or 

rules prohibiting tribal council members from voting on any measure relating to a contract where the contractor has contributed to 

his or her campaign for office. Tribes should consider examining 

whether, under any circumstances, a firm that provides legal, lobbying or other professional services to the tribe should ever be allowed to contribute money, services or anything of value to the 

campaign of anyone running for tribal office, or to provide professional services to a tribal official in his or her personal capacity 

apart from the services being provided to the tribe or to the official 

in his or her official capacity. 

c. Contracting and conflict of interests rules should include 

appropriate sanctions 

To ensure an adequate level of compliance with contracting and conflict of interests rules, there should be appropriate sanctions in 

place for violations of the rules. Apart from laws criminalizing the 

receipt of kickbacks and fraud (which many, if not most, tribes 

have already enacted), tribes should consider enacting laws that 

would render professional contracts awarded in violation of the contracting or conflict of interests rules to be void or voidable; subject 

a contractor found to have violated the rules to a contracting bar 

period or for egregious violations even a permanent bar; and make 

violation of the conflict of interests rules by a tribal official grounds 

for civil sanctions such a fines, suspension or even removal from office. 

d. Tribes should consider working with tribal organizations 

and educational institutions to develop model codes and 

education programs addressing contracting and conflicts 

of interests 

Tribes should consider working with their regional or national 

tribal organizations or with universities, colleges and law schools 

to develop model codes or laws to address contracting and conflict 

of interests issues, as well as ‘‘good government’’ education programs for elected and non-elected tribal officials designed to improve decision-making and avoid conflicts of interests in general 

but in the contracting process in particular. 

C. INTEGRITY OF TRIBAL ELECTIONS

In its investigation, the Committee determined that certain nontribal members insinuated themselves into and influenced tribal 

governmental elections. These non-tribal members did so with the 

intent or understanding that should their allies prevail, they would 

receive lucrative lobbying contracts from the respective tribe. Examples of these egregious actions include recruiting candidates for 

tribal governmental positions, organizing and funding comprehensive electioneering efforts, and providing monetary and other assistance to recall successful candidates who were unfavorable to 

the non-tribal members. 

Tribal elections are internal tribal governmental matters that 

are governed by the laws of each tribe. The Committee, however, 

is concerned that the economic success of certain tribes and the in-
250 

creasing number of contracts tribes enter into with outside entities 

may lead to an increase in the efforts of non-tribal members to 

interfere with or influence tribal elections. 

Based on these concerns, the Committee recommends that tribal 

governments should consider adopting or revising laws applicable 

to their elections that govern the scope of involvement by non-tribal 

members and entities. Tribal governments should consider adopting laws that address the following issues: 

• Whether, and to what extent, non-members may contribute 

to campaigns for tribal office. 

• Whether, and to what extent, non-members may provide 

non-monetary support in campaigns for tribal office. 

• Limitations on the amount of monetary contributions any 

person or entity can make to a tribal campaign. 

• Reporting requirements for donors and recipients of monetary contributions in tribal elections. 

• Prohibiting persons or entities that make monetary contributions to candidates in tribal elections from entering into contracts with the tribe for a specific period of time after the election. 

The Committee is aware that some tribes already have comprehensive election laws that address these issues, including prohibiting non-tribal members from making monetary contributions 

to tribal elections. The Committee commends these efforts as further examples of strong tribal governance and encourages tribes 

that have not yet adopted laws governing tribal elections to do so. 

D. TRIBAL POLITICAL CONTRIBUTIONS

Integral to Jack Abramoff’s lobbying practice were the substantial political contributions that he requested or directed his Tribal 

clients to make, and for which he and his team members attempted 

to take credit. Whenever he pitched his services, he would discuss 

the need for the Tribe to make substantial political contributions. 

Whether following Abramoff’s advice or not, Abramoff’s tribal clients made substantial political contributions during the time he 

represented them. The sizeable aggregate campaign contributions 

by some of Abramoff’s tribal clients has focused attention on the 

treatment of Indian tribes under campaign finance law. This has 

resulted in calls to restrict tribal campaign contributions. Proposals 

to limit contributions range from treating Indian tribes like ‘‘individuals’’ for purposes of imposing aggregate caps on their contributions from tribal funds, to treating tribes like corporations, which 

cannot use treasury funds for contributions but can instead establish separate segregated funds, also known as political action committees (‘‘PACs’’), to receive limited voluntary contributions. 

Many tribes object to these proposed restrictions on their political contributions, arguing that they are truly unique entities that 

should not be equated to individuals or corporations. They further 

argue that they are particularly impacted by Congressional actions, 

and must be afforded the opportunity to participate in the political 

process by using tribal funds for political contributions. 

On February 8, 2006, the Committee held an Oversight Hearing 

on Indian Tribes and the Federal Election Campaign Act to exam-
251 

ine this issue. The Federal Election Commission (‘‘FEC’’) testified 

at this hearing that Indian tribes are subject to the same contribution limitations and prohibitions in the federal campaign law as are 

other unincorporated associations. In instances where a tribe is acting through a corporation or federal government contractor, those 

tribal entities are governed by the same rules generally applicable 

to corporations and federal government contractors. Additionally, 

the FEC informed the Committee that political committees, including candidate and general party committees, must report contributions from Indian tribes. 

Concerns were raised by many of the witnesses testifying before the Committee about difficulties in researching and monitoring 

tribal political contributions. These difficulties do not appear to be 

unique to Indian tribes, but also exist with respect to researching 

and monitoring contributions from individual donors and other entities. 

The Committee believes that it is prudent to increase the level 

of transparency with regards to all political contributions, including 

those from Indian tribes. Thus, after considering the record before 

it, the Committee recommends, at a minimum, the following either 

be implemented by rule by the Federal Election Commission or law 

enacted by Congress. 

• Tribes should be required to register with the FEC, which will assign each tribe a unique identifier, for the purpose of 

better tracking tribal campaign contributions. 

• Contributions should be made only in the tribe’s name as it appears on its registration on file with the FEC. 

• The contributions must be reported by the recipient in the Tribe’s name. 

In the opinion of the Committee, based on the extensive legisla- tive record and the February 8, 2006, hearing, these public disclosure recommendations adequately protect the public trust and confidence in the Federal election system, without unduly excluding 

Indian tribes from participating in that system. 

E. REFERRALS TO OTHER COMMITTEES

1. Possible Misuse of Tax Exempt Organizations 

In the course of its investigation, this Committee uncovered nu- merous instances of nonprofit organizations that appeared to be involved in activities unrelated to their mission as described to the 

Internal Revenue Service. In addition, the Committee observed 

that a number of nonprofit organizations were used as instruments 

to channel money from one entity to another in an effort to obscure 

the source of funds, the eventual use of funds, and to evade tax liability on funds. Finally, the Committee also observed tax exempt 

organizations apparently serving as or being used as extensions of 

for-profit lobbying operations. 

Recognizing that oversight of nonprofit organizations under the 

Internal Revenue Code is not within the jurisdiction of the Senate 

Committee on Indian Affairs, the Committee, at the request of the 

Senate Committee on Finance, transmitted a number of relevant 

documents pertaining to this issue to the Senate Committee on Finance on February 9, 2006. Those documents are included in this 
252 

Report in the supporting documents following the text of the Report. 

The Committee believes that the evidence it uncovered raises serious issues involving nonprofit organizations, not only with regard 

to compliance with existing federal revenue laws, but also with regard to whether existing federal revenue laws should be altered to 

prevent or discourage such activity. The Committee therefore recommends that the Senate Committee on Finance investigate, hold 

hearings, and report to the Senate on its findings and recommendations on these issues. 
(253) 

PART FIVE—VIEWS 

ADDITIONAL VIEWS OF SENATOR DANIEL K. INOUYE 

INTRODUCTION

In the Recommendations section of the Report, ‘‘Gimme Five’’— 

Investigation of Tribal Lobbying Matters, the Committee discusses 

tribal political contributions and provides a proposed policy concept 

that it recommends be implemented either by rule by the Federal 

Election Commission or law enacted by Congress. I concur that 

more transparency is needed, however, I would clarify that the proposal should also apply to unincorporated associations. Although 

unincorporated associations are not within the jurisdiction of the 

Committee or this report, I would broaden this recommendation to 

ensure that unincorporated associations are included. 

DISCUSSION

As the Report accurately notes, the Committee held an Oversight 

Hearing on Indian Tribes and the Federal Election Campaign Act 

and received testimony from various witnesses, including the Federal Election Commission (FEC) and others. The Report notes that 

the FEC testified that Indian tribes are subject to the same contribution limitations and prohibitions in the Federal Election Campaign Act as are other unincorporated associations. Further, the report noted that many witnesses testified about the difficulty in researching and monitoring tribal political contributions from Indian 

tribes, individual donors and other entities. Consequently, the 

Committee put forth a policy recommendation for either the FEC 

or Congress. 

Although I agree with the Committee that this issue may need 

to be addressed, I must provide additional views to this particular 

recommendation as it could imply that the policy recommendation 

only applies to Indian tribes. Despite the Committee’s statement 

that the level of transparency with regards to all political contributions should be increased, the Report could be read to unfairly single out Indian tribes by proposing a recommendation that only addresses contributions by Indian tribes. 

In lieu of the Committee’s recommendation regarding tribal campaign contributions, I would propose a broader recommendation of 

the issue identified by the FEC and other witnesses—that this 

issue affects Indian tribes and other entities. Since the FEC noted 

that Indian tribes are subject to the same contribution limitations 

and prohibitions as other unincorporated associations, I believe 

that the recommendation should continue this similar treatment, 

without unfairly singling out Indian tribes, by suggesting the following: 
254 

• Each unincorporated association that intends to make a federal campaign contribution should be required to obtain a 

unique identifier for the purpose of better tracking campaign 

contributions from unincorporated associations. 

• For purposes of this policy only, Indian tribes shall be considered unincorporated associations. 

• All federal campaign contributions from unincorporated associations shall include the unique identifier. 

• The contributions must be reported by the recipient by the 

unique identifier as well as the name of the unincorporated association. 

While donations from individual donors are subject to the same 

confusion, my suggestion makes no attempt to address this issue 

because of the burden and confusion that it would likely impose on 

individual donors as well as the burden on the FEC to enforce such 

a provision. I am willing, however, to consider other suggestions on 

how to increase the transparency of these contributions. 
2553
2564
257
2586
2597
2608
2619
262 10
263 11
264 12
265 13
266 14
267 15
268 16
269 17
270 18
271 19
272 20
273 21
274 22
275 23
276 24
277 25
278 26
279 27
280 28
281 29
282 30
283 31
284 32
285 33
286 34
287 35
288 36
289 37
290 38
291 39
292 40
293 41
294 42
295 43
296 44
297 45
298 46
299 47
300 48
301 49
302 50
303 51
304 52
305 53
306 54
307 55
308 56
309 57
310 58
311 59
312 60
313 61
314 62
315 63
316 64
317 65
318 66
319 67
320 68
321 69
322 70
323 71
324 72
325 73
326 74
327 75
328 76
329 77
330 78
331 79
332 80
333 81
334 82
335 83
336 84
337 85
338 86
339 87
340 88
341 89
342 90
343 91
344 92
345 93
346 501
347 94
348 95
349 96
350 97
351 98
352 99
353 100
354 101
355 102
356 103
357 104
358 105
359 106
360 107
361 108
362 109
363 110
364 111
365 112
366 113
367 114
368 115
369 116
370 117
371 118
372 119
373 120
374 121
375 122
376 123
377 124
378 125
379 126
380 127
381 128
382 129
383 130
384 131
385 132
386 133
387 134
388 135
389 136
390 137
391 138
392 139
393 140
394 141
395 142
396 143
397 144
398 145
399 146
400 147
401 148
402 149
403 150
404 151
405 152
406 153
407 154
408 155
409 156
410 157
411 158
412 159
413 160
414 161
415 162
416 163
417 164
418 165
419 166
420 167
421 168
422 169
423 170
424 171
425 172
426 173
427 174
428 175
429 176
430 177
431 178
432 179
433 180
434 181
435 182
436 183
437 184
438 185
439 186
440 187
441 188
442 189
443 190
444 191
445 192
446 193
447 194
448 195
449 196
450 197
451 198
452 199
453 200
454 201
455 202
456 203
457 204
458 205
459 206
460 207
461 208
462 209
463 210
464 211
465 212
466 213
467 214
468 215
469 216
470 217
471 218
472 219
473 220
474 221
475 222
476 223
477 224
478 225
479 226
480 227
481 228
482 229
483 230
484 231
485 232
486 233
487 234
488 235
489 236
490 237
491 238
492 239
493 240
494 241
495 242
496 243
497 244
498 245
499 246
500 247
501 248
502 249
503 250
504 251
505 252
506 253
507 254
508 255
509 256
510 257
511 258
512 259
513 260
514 261
515 262
516 263
517 264
518 265
519 266
520 267
521 268
522 269
523 270
524 271
525 272
526 273
527 274
528 275
529 276
530 277
531 278
532 279
533 280
534 281
535 282
536 283
537 284
538 285
539 286
540 287
541 288
542 289
543 290
544 291
545 292
546 293
547 294
548 295
549 296
550 297
551 298
552 299
553 300
554 301
555 302
556 303
557 304
558 305
559 306
560 307
561 308
562 309
563 310
564 311
565 312
566 313
567 314
568 315
569 316
570 317
571 318
572 319
573 320
574 321
575 322
576 323
577 324
578 325
579 326
580 327
581 328
582 329
583 330
584 331
585 332
586 333
587 334
588 335
589 336
590 337
591 338
592 339
593 340
594 341
595 342
596 343
597 344
598 345
599 346
600 347
601 348
602 349
603 350
604 351
605 352
606 353
607 354
608 355
609 356
610 357
611 358
612 359
613 360
614 361
615 362
616 363
617 364
618 365
619 366
620 367
621 368
622 369
623 370
624 371
625 372
626 373
627 374
628 375
629 376
630 377
631 378
632 379
633 380
634 381
635 382
636 383
637 384
638 385
639 386
640 387
641 388
642 389
643 390
644 391
645 392
646 393
647 394
648 395
649 396
650 397
651 398
652 399
653 400
654 401
655 402
656 403
657 404
658 405
659 406
660 407
661 408
662 409
663 410
664 411
665 412
666 413
667 414
668 415
669 416
670 417
671 418
672 419
673 420
674 421
675 422
676 423
677 424
678 425
679 426
680 427
681 428
682 429
683 430
684 431
685 432
686 433
687 434
688 435
689 436
690 437
691 438
692 439
693 440
694 441
695 442
696 443
697 444
698 445
699 446
700 447
701 448
702 449
703 450
704 451
705 452
706 453
707 454
708 455
709 456
710 457
711 458
712 459
713 460
714 461
715 462
716 463
717 464
718 465
719 466
720 467
721 468
722 469
723 470
724 471
725 472
726 473
727 474
728 475
729 476
730 477
731 478
732 479
733 480
734 481
735 482
736 483
737 484
738 485
739 486
740 487
741 488
742 489
743 490
744 491
745 492
746 493
747 494
748 495
749 496
750 497
751 498
752 499
753 500
754 502
755 503
756 504
757 505
758 506
759 507
760 508
761 509
762 510
763 511
764 512
765 513
766 514
767 515
768 516
769 517
770 518
771 519
772 520
773 521
774 522
775 523
776 524
777 525
778 526
779 527
780 528
781 529
782 530
783 531
784 532
785 533
786 534
787 535
788 536
789 537
790 538
791 539
792 540
793 541
794 542
795 543
796 544
797 545
798 546
799 547
800 548
801 549
802 550
803 551
804 552
805 553
806 554
807 555
808 556
809 557
810 558
811 559
812 560
813 561
814 562
815 563
816 564
817 565
818 566
819 567
820 568
821 569
822 570
823 571
824 572
825 573
826 574
827 575
828 576
829 577
830 578
831 579
832 580
833 581
834 582
835 583
836 584
837 585
838 586
839 587
840 588
841 589
842 590
843 591
844 592
845 593
846 594
847 595
848 596
849 597
850 598
851 599
852 600
853 601
854 602
855 603
856 604
857 605
858 606
859 607
860 608
861 609
862 610
863 611
864 612
865 613
866 614
867 615
868 616
869 617
870 618
871 619
872 620
873 621
874 622
875 623
876 624
877 625
878 626
879 627
880 628
881 629
882 630
883 631
884 632
885 633
886 637
887 638
888 639
889 640
890 641
891 642
892 643
893 644
894 645
895 646
896 647
897 648
898 649
899 650
900 651
901 652
902 653
903 654
904 655
905 656
906 657
907 658
908 659
909 660
910 661
911 662
912 663
913 664
914 665
915 666
916 667
917 668
918 669
919 670
920 671
921 672
922 673
923 674
924 675
925 676
926 677
927 678
928 679
929 680
930 681
931 682
932 683
933 684
934 685
935 686
936 687
937 688
938 689
939 690
940 691
941 692
942 693
943 694
944 695
945 696
946 697
947 698
948 699
949 700
950 701
951 702
952 703
953 704
954 705
955 706
956 707
957 708
958 709
959 710
960 711
961 712
962 713
963 714
964 715
965 716
966 717
967 718
968 719
969 720
970 721
971 722
972 723
973 724
974 725
975 726
976 727
977 728
978 729
979 730
980 731
981 732
982 733
983 734
984 735
985 736
986 737
987 738
988 739
989 740
990 741
991 742
992 743
993 744
994 745
995 746
996 747
997 748
998 749
999 750
1000 751
1001 752
1002 753
1003 754
1004 755
1005 756
1006 757
1007 758
1008 759
1009 760
1010 761
1011 762
1012 763
1013 764
1014 765
1015 766
1016 767
1017 768
1018 769
1019 770
1020 771
1021 772
1022 773
1023 774
1024 775
1025 776
1026 777
1027 778
1028 779
1029 780
1030 781
1031 782
1032 783
1033 784
1034 785
1035 786
1036 787
1037 788
1038 789
1039 790
1040 791
1041 792
1042 793
1043 794
1044 795
1045 796
1046 797
1047 798
1048 799
1049 800
1050 801
1051 802
1052 803
1053 804
1054 805
1055 806
1056 807
1057 808
1058 809
1059 810
1060 811
1061 812
1062 813
1063 814
1064 815
1065 816
1066 817
1067 818
1068 819
1069 820
1070 821
1071 822
1072 823
1073 824
1074 825
1075 826
1076 827
1077 828
1078 829
1079 830
1080 831
1081 832
1082 833
1083 834
1084 835
1085 836
1086 837
1087 838
1088 839
1089 840
1090 841
1091 842
1092 843
1093 844
1094 845
1095 846
1096 847
1097 848
1098 849
1099 850
1100 851
1101 852
1102 853
1103 854
1104 855
1105 856
1106 857
1107 858
1108 859
1109 860
1110 861
1111 862
1112 863
1113 864
1114 865
1115 866
1116 867
1117 868
1118 869
1119 870
1120 871
1121 872
1122 873
1123 874
1124 875
1125 876
1126 877
1127 878
1128 879
1129 880
1130 881
1131 882
1132 883
1133 884
1134 885
1135 886
1136 887
1137 888
1138 889
1139 890
1140 891
1141 892
1142 893
1143 894
1144 895
1145 896
1146 897
1147 898
1148 899
1149 900
1150 901
1151 902
1152 903
1153 904
1154 905
1155 906
1156 907
1157 908
1158 909
1159 910
1160 911
1161 912
1162 913
1163 914
1164 915
1165 916
1166 917
1167 918
1168 919
1169 920
1170 921
1171 922
1172 923
1173 924
1174 925
1175 926
1176 927
1177 928
1178 929
1179 930
1180 931
1181 932
1182 933
1183 934
1184 935
1185 936
1186 937
1187 938
1188 939
1189 940
1190 941
1191 942
1192 943
1193 944
1194 945
1195 946
1196 947
1197 948
1198 949
1199 950
1200 951
1201 952
1202 953
1203 954
1204 955
1205 956
1206 957
1207 958
1208 959
1209 960
1210 961
1211 962
1212 963
1213 964
1214 965
1215 966
1216 967
1217 968
1218 969
1219 970
1220 971
1221 972
1222 973
1223 974
1224 975
1225 976
1226 977
1227 978
1228 979
1229 980
1230 981
1231 982
1232 983
1233 984
1234 985
1235 986
1236 987
1237 988
1238 989
1239 990
1240 991
1241 992
1242 993
1243 994
1244 995
1245 996
1246 997
1247 998
1248 999
1249000
1250001
1251002
1252003
1253004
1254005
1255006
1256007
1257008
1258009
1259010
1260011
1261012
1262013
1263014
1264015
1265016
1266017
1267018
1268019
1269020
1270021
1271022
1272023
1273024
1274025
1275026
1276027
1277028
1278029
1279030
1280031
1281032
1282033
1283034
1284035
1285036
1286037
1287038
1288039
1289040
1290041
1291042
1292043
1293044
1294045
1295046
1296047
1297048
1298049
1299050
1300051
1301052
1302053
1303054
1304055
1305056
1306057
1307058
1308059
1309060
1310061
1311062
1312063
1313064
1314065
1315066
1316067
1317068
1318069
1319070
1320071
1321072
1322073
1323074
1324075
1325076
1326077
1327078
1328079
1329080
1330081
1331082
1332083
1333084
1334085
1335086
1336087
1337088
1338089
1339090
1340091
1341092
1342093
1343094
1344095
1345096
1346097
1347098
1348099
1349100
1350101
1351102
1352103
1353104
1354105
1355106
1356107
1357108
1358109
1359110
1360111
1361112
1362113
1363114
1364115
1365116
1366117
1367118
1368119
1369120
1370121
1371122
1372123
1373124
1374125
1375126
1376127
1377128
1378129
1379130
1380131
1381132
1382133
1383134
1384135
1385136
1386137
1387138
1388139
1389140