U.S. GOVERNMENT PUBLISHING OFFICE

WASHINGTON : 

1 

69–006 

" ! HOUSE OF REPRESENTATIVES 115TH CONGRESS

1st Session 

REPORT

2017

115–272 

House Calendar No. 76 

IN THE MATTER OF ALLEGATIONS 

RELATING TO REPRESENTATIVE BEN RAY LUJA ́ N 

R E P O R T 

OF THE

COMMITTEE ON ETHICS 

AUGUST 1, 2017.—Referred to the House Calendar and ordered to be 

printed 


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(II) 

COMMITTEE ON ETHICS 

Susan W. Brooks, Indiana 

Chairwoman 

Patrick Meehan, Pennsylvania 

Trey Gowdy, South Carolina 

Kenny Marchant, Texas 

Leonard Lance, New Jersey 

Theodore E. Deutch, Florida 

Ranking Member 

Yvette D. Clarke, New York 

Jared Polis, Colorado 

Anthony Brown, Maryland 

Steve Cohen, Tennessee 

REPORT STAFF 

THOMAS A. RUST, Chief Counsel/Staff Director 

PATRICK M. MCMULLEN, Director of Investigations 

MEGAN H. SAVAGE, Counsel to the Chairwoman 

DANIEL J. TAYLOR, Counsel to the Ranking Member 

C. EZEKIEL ROSS, Counsel 

MOLLY N. MCCARTY, Investigator 

MICHAEL KOREN, Investigative Clerk 


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LETTER OF TRANSMITTAL 

HOUSE OF REPRESENTATIVES, 

COMMITTEE ON ETHICS, 

Washington, DC, August 1, 2017. 

Hon. KAREN L. HAAS, 

Clerk, House of Representatives, 

Washington, DC. 

DEAR MS. HAAS: Pursuant to clauses 3(a)(2) and 3(b) of rule XI 

of the Rules of the House of Representatives, we herewith transmit 

the attached report, ‘‘In the Matter of Allegations Relating to Representative Ben Ray Luja ́n.’’ 

Sincerely, 

SUSAN W. BROOKS, 

Chairwoman. 

THEODORE E. DEUTCH, 

Ranking Member. 


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C O N T E N T S 

I. INTRODUCTION .......................................................................................... 1 

II. PROCEDURAL BACKGROUND .................................................................. 2 

III. HOUSE RULES, LAWS, REGULATIONS, AND OTHER STANDARDS 

OF CONDUCT ............................................................................................ 2 

IV. BACKGROUND ............................................................................................. 4 

A. REPRESENTATIVE LUJA ́ N’S EMAIL TO A CAMPAIGN VOLUNTEER ......................................................................................... 5 

B. THE JUNE 22, 2016, CAMPAIGN EMAIL BY BOULDER 

STRATEGIES ................................................................................. 5 

C. THE JUNE 23, 2016, CAMPAIGN EMAIL BY BOULDER 

STRATEGIES ................................................................................. 7 

V. FINDINGS ...................................................................................................... 9 

A. SOLICITATION OF CAMPAIGN CONTRIBUTIONS AND 

OTHER CAMPAIGN ACTIVITY IN HOUSE BUILDINGS ........ 9 

1. REPRESENTATIVE LUJA ́ N’S EMAIL DID NOT SOLICIT 

CAMPAIGN CONTRIBUTIONS ................................................ 9 

2. THE RECORD DOES NOT SHOW THAT REPRESENTATIVE 

LUJA ́ N ENGAGED IN CAMPAIGN ACTIVITY IN A 

HOUSE BUILDING .................................................................... 10 

B. BOULDER STRATEGIES’ USE OF AN IMAGE OF THE 

HOUSE FLOOR IN THE JUNE 23, 2016, CAMPAIGN SOLICITATION ......................................................................................... 11 

VI. CONCLUSION ............................................................................................... 12 

VII. STATEMENT UNDER HOUSE RULE XIII, CLAUSE 3(C) ...................... 13 

APPENDIX 1: REPORT AND FINDINGS OF THE OFFICE OF CONGRESSIONAL ETHICS (REVIEW NO. 17–8362) ................................... 14 

APPENDIX 2: REPRESENTATIVE LUJA ́ N’S SUBMISSION .................. 242 

APPENDIX 3: EXHIBITS TO COMMITTEE REPORT ............................. 257 


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1OCE’s Referral at 1 (Appendix A). 

2 Id. at 1, 16. 3 Id. at 1. 

House Calendar No. 76 

115TH CONGRESS REPORT " ! HOUSE OF REPRESENTATIVES 1st Session 115–272 

IN THE MATTER OF ALLEGATIONS RELATING TO 

REPRESENTATIVE BEN RAY LUJA ́ N 

AUGUST 1, 2017.—Referred to the House Calendar and ordered to be printed 

Mrs. BROOKS of Indiana, from the Committee on Ethics, 

submitted the following 

R E P O R T 

In accordance with House Rule XI, clauses 3(a)(2) and 3(b), the 

Committee on Ethics (Committee) hereby submits the following Report to the House of Representatives: 

I. INTRODUCTION 

On May 11, 2017, the Office of Congressional Ethics (OCE) 

transmitted to the Committee a Report and Findings (OCE’s Referral) regarding Representative Ben Ray Luja ́n. OCE reviewed allegations that Representative Luja ́n violated laws, House rules, and 

other standards of conduct by (1) improperly conducting campaign 

or political activity from the floor of the House of Representatives; 

(2) improperly soliciting campaign contributions from a federal 

building; and (3) improperly using an image of a House of Representatives floor proceeding for campaign and political purposes.1

OCE found that there was ‘‘substantial reason to believe that 

Representative Luja ́n conducted campaign or political activity from 

the House Floor, solicited a campaign contribution from a federal 

building, or used an image of a House Floor proceeding for campaign or political purposes.’’ 2 For that reason, OCE recommended 

that the Committee further review these allegations.3 However, 

OCE acknowledged that ‘‘the evolving nature of electronic communications and campaign solicitations sometimes presents novel 

issues that are not directly addressed by the House Ethics Manual,’’ and that OCE’s review ‘‘raised difficult questions about the 


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4 Id. at 15. 5 Id. 

application of House rules to solicitations via email.’’ 4 OCE suggested that ‘‘Members may benefit from additional guidance regarding campaign activities and electronic communications.’’ 5

The Committee agreed that this was an area where additional 

guidance could be useful, and did further review the allegations. 

Following its review, the Committee concluded that the evidence is 

insufficient to warrant further action against Representative 

Luja ́n. Specifically, the Committee did not find that Representative 

Luja ́n engaged in campaign or political activity, or solicited campaign contributions, from the House Floor or any other federal 

building. The Committee did find that Representative Luja ́n’s campaign consultant used an image of House proceedings from the 

House recording system in a campaign communication, which was 

an inadvertent, technical violation of House Rule V, clause 2(c)(1). 

Members are ultimately responsible for actions taken in their name 

that they delegate to third parties. Thus, Members should take reasonable steps to ensure that their campaign committees or consultants comply with all applicable laws, rules, and regulations. However, given the limited nature of the violation, as well as Representative Luja ́n’s subsequent efforts to prevent any recurrence of 

this issue, the Committee did not find that a sanction was warranted. 

Accordingly, the Committee unanimously voted to dismiss this 

matter, publish this Report, and take no further action. Upon publication of this Report, the Committee considers the matter closed. 

II. PROCEDURAL BACKGROUND 

OCE commenced a preliminary review of this matter on February 4, 2017. On March 6, 2017, OCE initiated a second-phase review. On May 5, 2017, the OCE Board voted five to one to adopt 

the Findings and refer the matter to the Committee with a recommendation for further review. 

The Committee received OCE’s referral on May 11, 2017. The 

Committee issued voluntary requests for information to Representative Luja ́n, and he responded by voluntarily providing documents 

and other information to the Committee. In total, the Committee 

reviewed over 1,250 pages of materials, including the transcripts of 

four voluntary interviews. 

On July 27, 2017, the Committee unanimously voted to release 

this Report and take no further action with respect to Representative Luja ́n. 

III. HOUSE RULES, LAWS, REGULATIONS, AND OTHER 

STANDARDS OF CONDUCT 

Federal law, 18 U.S.C. § 607, makes it ‘‘unlawful for . . . Members of Congress, to solicit or receive a donation of money or other 

thing of value in connection with a Federal, State, or local election, 

while in any room or building occupied in the discharge of official 

duties by an officer or employee of the United States, from any person.’’ According to the House Ethics Manual, ‘‘[t]he prohibition 

against House Members or employees soliciting campaign or political contributions in or from House offices, rooms, or buildings is 


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6See House Ethics Manual (2008) (hereinafter ‘‘Ethics Manual’’) at 144. 7See id. at 144–45 (‘‘A telephone solicitation from a House office or building would not be permissible merely because the call is billed to a credit card of a political organization or to an 

outside telephone number, or because it is made using a cell phone in the hallway. Similarly, 

when a House Member or employee makes solicitation calls somewhere else, such as at one of 

the campaign committee offices, and has to leave a message, the individual should not leave 

his or her House office telephone number for the return call. In addition, a fundraising mailing 

should not be either prepared or assembled in a House room or office, even if no House equipment or supplies are used in the process.’’). 8 Id. at 126 (emphasis in original). 9 Id. at 145 (emphasis in original); see also id. (‘‘In addition, the rules issued by the House 

Office Building Commission concerning the use of the House office buildings prohibit the soliciting of contributions in the buildings other than for certain charitable purposes.’’) 10 Id. at 124 (emphasis in original). 11 Id. at 132–35. 

very broad.’’ 6 With one minor exception—an allowance for Members to solicit campaign contributions from other Members in 

House buildings—‘‘the prohibition applies to all forms of solicitations—solicitations made in person, over the telephone, or through 

the mail.’’ The Ethics Manual specifically notes that a Member may 

not prepare or make a campaign communication in a House building, even if the Member uses his own phone or other communications device.7

A separate statute, 31 U.S.C. § 1301(a), requires that ‘‘appropriations shall be applied only to the objects for which the appropriations were made except as otherwise provided by law.’’ Based on 

this statute, the Committee has long cautioned Members and 

House employees against the use of House buildings for unofficial 

activities. With respect to the use of official resources, including 

House buildings, for campaign or political activity, the Ethics Manual states that the statutory prohibition is absolute: 

A provision of the Members’ Handbook permits the incidental personal use of House equipment and supplies 

‘‘when such use is negligible in nature, frequency, time 

consumed, and expense.’’ However, this policy applies only 

to incidental personal use of those resources, and not to 

their use for campaign or political purposes.8

In addition, the Ethics Manual states that ‘‘the House rooms, offices, and buildings are considered official resources, and as such, 

they [should] not be used for the conduct of any campaign or political activity.’’ 9 ‘‘Among the specific activities that clearly may not 

be undertaken in a congressional office . . . are the solicitation of 

contributions; the drafting of campaign speeches, statements, press 

releases or literature; the completion of FEC reports; the creation 

or issuance of a campaign mailing; and the holding of a meeting 

on campaign business.’’ 10

The purpose of these laws and rules is generally to preclude campaign or political activity from taking place in a congressional office. However, the Committee has recognized that there are certain 

limited activities that, while related to a Member’s campaign, may 

properly take place in a congressional office. The Committee’s view 

has been that it would be impractical and unnecessary to attempt 

to prohibit these specific activities. In this regard, the Committee 

has long advised that certain very limited and very specific activities are permissible.11

The Committee’s jurisdiction is of current House Members, officers, and employees. However, many Members delegate certain 

campaign communications functions to outside entities. AnticiVerDate Sep 11 2014 08:02 Aug 03, 2017 Jkt 069006 PO 00000 Frm 00009 Fmt 6659 Sfmt 6602 E:\HR\OC\HR272.XXX HR272

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12 Id. at 123. 13 House Rule V. 14 Ethics Manual at 128. 15See Exhibit 5 to OCE’s Referral (attaching June 22, 2016, Boulder Strategies email explaining Representative Luja ́n’s call for action via the sit-in). 16 Representative Luja ́n’s June 22, 2016, calendar indicates that he was scheduled to take 

lunch at 11:30 AM, see Exhibit 7, and email correspondence from Representative Luja ́n’s staff 

indicates that he was ‘‘heading to the floor’’ at 12:13 PM, see Exhibit 8, and that he cancelled 

12:30 PM and 2:30 PM meetings to remain on the House Floor, see Exhibit 9. When questioned 

regarding what time he joined the sit-in on the House Floor, Representative Luja ́n stated that 

he could not recall the exact time but that it was around lunchtime. See Exhibit 1 to OCE’s 

Referral, Interview of Representative Luja ́n at 24. 17 Exhibit 1 to OCE’s Referral, Interview of Representative Luja ́n at 22–24; Exhibit 1 (6:32 

AM message indicating that Representative Luja ́n was still on the House Floor and had been 

asked to speak ‘‘during the 7 o’clock hour.’’). Emails produced by Representative Luja ́n also indicate that at 9:37 AM on June 23, 2016, he was en route to a meeting at the offices of the Democratic Congressional Campaign Committee (hereinafter ‘‘DCCC’’), and he arrived there shortly 

after 9:45 AM. See Exhibit 2 & Exhibit 4. 18 Exhibit 1 to OCE’s Referral, Interview of Representative Luja ́n, at 23–25. 19 Id. at 23–24. 20 Id. at 24. 21 Id. 

pating this practical reality, the Ethics Manual states that ‘‘under 

these rules, a Member or employee must take reasonable steps to 

ensure that any outside organization over which he or she exercises 

control—including the individual’s own authorized campaign committee or, for example, a ‘leadership PAC’—operates in compliance 

with applicable law.’’ 12

With respect to use of images from the House Floor, House Rule 

V, clause 1, provides that ‘‘[t]he Speaker shall administer, direct, 

and control a system for close-circuit viewing of floor proceedings 

of the House,’’ and clause 2(c) states that ‘‘[c]overage made available under this clause, including any recording thereof—(1) may 

not be used for any partisan political campaign purpose.’’ 13 The 

Ethics Manual further explains that ‘‘[b]roadcast coverage and recordings of House Floor proceedings may not be used for any political purpose under House Rule V, clause 2(c)(1).’’ 14

IV. BACKGROUND 

On June 22 and June 23, 2016, Representative Ben Ray Luja ́n, 

Representative for New Mexico’s 3rd District, participated in a sitin on the House Floor. The sit-in was an organized attempt by 

Democratic Members to force a vote on the ‘‘No Fly No Buy’’ bill 

prior to adjourning for the July 4th recess.15 Representative Luja ́n 

joined the sit-in around midday on June 22, 2016,16 and participated in the sit-in until he left and went home after 7:00 AM on 

June 23.17 According to Representative Luja ́n, he did not remain 

on the House Floor throughout the entire sit-in. Instead, he recalls 

leaving the House Floor for a pre-scheduled ‘‘lunch or [] meeting 

outside of the building.’’ 18 Representative Luja ́n also stated that he 

‘‘left for a bit of time and then [] came back to the floor during the 

night,’’ 19 and recalled leaving the House Floor to take bathroom 

breaks and to walk ‘‘outside to the front of the building of the Capitol, just [to] get a breath of air.’’ 20 In addition, Representative 

Luja ́n told OCE that ‘‘[t]here were people gathering outside the 

Capitol, so members would leave periodically to go and either just 

stand with the crowd or speak to the crowd.’’ 21


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22 Exhibit 2 to OCE’s Referral. 23 Id. 24 Campaign Volunteer is the Chief of Staff for the DCCC, but Representative Luja ́n has asserted that he was acting in his personal capacity in assisting Representative Luja ́n’s campaign. 

See June 2, 2017, Letter from Representative Luja ́n to Chairwoman Brooks and Ranking Member Deutch (hereinafter ‘‘Representative Luja ́n Submission’’), at 6. During the course of the sitin, it appears Campaign Volunteer’s email correspondence with Boulder Strategies, Representative Luja ́n, and Representative Luja ́n’s campaign committee was limited to emails from his personal email account. 25 Exhibit 2 to OCE’s Referral. 26 Exhibit 1 to OCE’s Referral, Interview of Representative Luja ́n at 34–35; Exhibit 2 to OCE’s 

referral. 27While it is unclear where Representative Luja ́n was located at 4:02 PM, Representative 

Luja ́n’s submissions indicate he was conferring with staff members regarding sit-in related 

interviews sometime between 3:35 PM and 3:58 PM. See Exhibit 3; Exhibit 1 to OCE’s Referral, 

Interview of Representative Luja ́n at 34 (‘‘I was in and out of the Capitol quite a bit. I don’t 

remember exactly where I was when I sent [the 4:02 PM email to Campaign Volunteer]’’.). 28 Exhibit 1 to OCE’s Referral, Interview of Representative Luja ́n at 6. 29 Exhibit 3 to OCE’s Referral, Interview of DCCC Chief of Staff at 17–18. 30 Exhibit 1 to OCE’s Referral, Interview of Representative Luja ́n at 9; Exhibit 3 to OCE’s Referral, Interview of DCCC Chief of Staff at 20 (‘‘It wasn’t just solicitations. It was—it was just 

content delivery as well.’’). 31 Exhibit 1 to OCE’s Referral, Interview of Representative Luja ́n at 31–32 (‘‘I don’t know that 

it’s up to Aaron to make a decision of whether something is a petition or if it’s an online solicitation for money. That’s what Boulder Strategies was hired to do and that’s their job.’’); Exhibit 

3 to OCE’s Referral, Interview of DCCC Chief of Staff at 56 (‘‘They were in charge of his entire 

Continued 

A. REPRESENTATIVE LUJA ́ N’S EMAIL TO A CAMPAIGN VOLUNTEER

On June 22, 2016, at 3:00 PM, while Representative Lujan was 

on or near the House Floor for the sit-in, he received an email from 

Representative Michelle Lujan Grisham’s campaign committee. The 

email stated that Representative Lujan Grisham was ‘‘literally on 

the House floor,’’ and requested that the recipients ‘‘add your name 

to this petition,’’ which related to the ‘‘No Fly No Buy’’ bill.22 The 

email did not request a campaign contribution.23

At 4:02 PM, Representative Luja ́n forwarded Representative 

Lujan Grisham’s email to a volunteer for his campaign (Campaign 

Volunteer),24 with a one-sentence email stating ‘‘Get something 

out.’’ 25 The email was sent from Representative Luja ́n’s personal 

email account to Campaign Volunteer’s personal email account, and 

the email did not provide additional details regarding what Representative Luja ́n wanted to ‘‘get out.’’ 26 Representative Luja ́n does 

not recall whether he was on the House Floor, inside the Capitol, 

or inside any other federal building at the time he forwarded the 

email to Campaign Volunteer.27

B. THE JUNE 22, 2016, CAMPAIGN EMAIL BY BOULDER STRATEGIES

Representative Luja ́n’s principal campaign committee, People for 

Ben, contracted with Boulder Strategies, a private political consulting firm, to handle campaign solicitations and petitions through 

‘‘[o]nline fund-raising and digital strategy.’’ 28 Boulder Strategies’ 

responsibilities included creating a calendar of when to send targeted email correspondence based on current events, the news 

cycle, and items relevant to Representative Luja ́n’s voting base.29

Boulder Strategies sent both ‘‘solicitations for contributions and 

also [] emails that were petitions, asking people to sign on with different policy issues’’ to Representative Luja ́n’s supporters throughout the 2016 election cycle.30 Representative Luja ́n left the decision 

whether a particular occasion called for a petition or a solicitation 

up to Boulder Strategies because Boulder Strategies was using a 

technology called HubSpot.31 HubSpot is a marketing software 


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e-mail program. They are the people who physically clicked ‘send’ with their technology HubSpot 

or whatever they used to, like, message test and see which e-mails get more clicks and less 

clicks and how to include e-mail solicitations and all that other stuff, right. They were sort of 

the keeper of the keys when it came to that kind of stuff.’’). 32 Exhibit 3 to OCE’s Referral, Interview of DCCC Chief of Staff at 21 (‘‘they had a technology 

called HubSpot that basically they would like message test things . . . and from whatever technology that they had they could decide like, wow, people are really paying attention to, like, 

you know, this issue or that issue or whatever.’’); id. at 22 (‘‘It was kind of like a known fact 

that if an e-mail came across . . . if it had a solicitation within it that they had already identified that that was a subject matter via this technology HubSpot, that could potentially yield a 

good amount of campaign donations online.’’). 33 Id. at 71–72 (‘‘[B]ased on what was happening I knew that there, that they were already 

doing their thing here to create content, and so I, I didn’t do anything.’’). 34 Id. at 31–36, 46–47. 35 Boulder Strategies sent their emails on Representative Luja ́n’s behalf from their offices in 

Boulder, Colorado. Id. at 67. 36 Exhibit 5 to OCE’s Referral. 37 Exhibit 4 to OCE’s Referral, Interview of President of Boulder Strategies at 6. 38 Id. 39 Id. at 8. 40 Exhibit 1 to OCE’s Referral, Interview of Representative Luja ́n at 36–37 (explaining that 

Representative Luja ́n played no role in the drafting or editing of the email); see also id. at 16– 

17 (explaining that Boulder Strategies sent Representative Luja ́n drafts of solicitations and petitions for the first few months of 2016, but stopped sending drafts after that and ‘‘[a]s far as 

editing or drafting or anything like that, I had—I never did that.’’); id. at 22 (‘‘I think early 

on, I may have received them. But later, E-mails would get sent out to whatever list Boulder 

Strategies had, without me seeing them or editing them at all.’’). 41See Exhibit 10. 

platform that was used by Boulder Strategies to test the type of 

messages and content that best captured public attention, and to 

determine which messages were ideal for generating fundraising 

revenue.32

Campaign Volunteer told OCE he viewed Representative Luja ́n’s 

email to ‘‘Get something out’’ as a suggestion and did not convey 

the message to Boulder Strategies because Boulder Strategies already had email correspondence addressing the ‘‘No Fly No Buy’’ 

bill scheduled to be released on June 22, 2016.33 Indeed, after the 

Orlando shooting prompted the 2016 ‘‘No Fly No Buy’’ bill, Boulder 

Strategies scheduled multiple emails to be released on Representative Luja ́n’s behalf regarding the bill, bill-related events, and the 

general issue of gun violence in America.34

On June 22, 2016, at 7:11 PM, the President of Boulder Strategies sent an email 35 to Representative Luja ́n’s campaign committee 

staff and to Campaign Volunteer, requesting that they review a 

draft message on behalf of People for Ben.36 According to the President of Boulder Strategies, the ‘‘e-mail was a continuation of a series of e-mails [Boulder Strategies had] been doing on [the] No Fly 

No Buy’’ bill.37 Boulder Strategies ‘‘simply took an e-mail that was 

already in the pipeline,’’ which they ‘‘were already planning to 

send,’’ and ‘‘inserted the first line of the e-mail that talked about 

[Representative Luja ́n] being on the floor to make it relevant for 

the day’s topic.’’ 38

The message included a link redirecting recipients to a contribution page allowing them ‘‘to make a contribution if they so 

choose.’’ 39 Representative Luja ́n told OCE that he did not review 

the draft, propose any language with respect to the draft, or participate in the decision whether to include the contribution link.40

Neither OCE nor the Committee obtained any information to the 

contrary. 

The email was ultimately sent at approximately 8:15 PM on June 

22, 2016,41 to People for Ben supporters, with the following text included: 


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42 Exhibit 6 to OCE’s Referral. 43 Id. 44 Exhibit 3 to OCE’s Referral, Interview of DCCC Chief of Staff at 74–75 (‘‘before [T] the 

news cycle moved to another subject which it often does very quickly I had suggested to them 

that we should probably send out another e-mail based on everything that was going on because 

the news cycle was probably about to shift.’’). 45See Exhibit 11 (Boulder Strategies’ email confirming that the June 23, 2016, ‘‘Email is out’’). 

Boulder Strategies sent their emails on Representative Luja ́n’s behalf from their offices in Boulder, Colorado. See Exhibit 3 to OCE’s Referral, Interview of DCCC Chief of Staff at 67. 46 Exhibit 3 to OCE’s Referral, Interview of DCCC Chief of Staff at 66. 

Friend, 

Today I join countless colleagues on the House floor to 

demand action that will make our country safer. 

Facts matter—and the facts are that right now a suspected terrorist can go into a gun store and purchase a 

military-style assault rifle. In what world do we think 

that’s a good idea? 

Sign our pledge if you demand a vote on the bipartisan 

No Fly, No Buy bill. 

My Republican colleagues would rather go on a 4th of 

July recess before voting on this time-sensitive bill. That’s 

why we’re on the House floor demanding action. 

Enough is enough—no bill, no break. Full stop. SIGN 

HERE. 

I’m a strong believer in our Second Amendment rights to 

bear arms, but also recognize that our system is broken 

when it’s too easy for a powerful gun to get in the hands 

of someone who wants to hurt us. 

The Orlando shooter, who was interviewed by the FBI 

just a couple years earlier, was able to legally purchase an 

AR–15, military-grade assault rifle. 

Stand up if you support our sit-in. 

At a minimum, we must come together, put aside our 

politics, and pass this commonsense measure. 

Thank you, 

Ben Ray 

CONTRIBUTE 

Paid for and authorized by People for Ben. 

Based on all of the evidence the Committee collected, it is not 

clear where Representative Luja ́n was physically located when 

Boulder Strategies released this message. 

C. THE JUNE 23, 2016, CAMPAIGN EMAIL BY BOULDER STRATEGIES

On June 23, 2016, at 9:29 AM, Campaign Volunteer sent an 

email to the President of Boulder Strategies and the People for Ben 

campaign staff.42 The email stated ‘‘[p]lease get another email 

ready for this morning. The members will have been on the floor 

for 24 hours, as of 11:00 this morning. We need to do a $$ ask on 

this.’’ 43 Campaign Volunteer’s request was based on a perceived 

impending shift in the news cycle away from the sit-in and the ‘‘No 

Fly No Buy’’ bill.44

Boulder Strategies complied with the request, and the June 23, 

2016, email was sent to a campaign distribution list at 11:11 AM.45

The email contained an image of the House Floor that was obtained from an Associated Press news article.46 The original source 

of the image appears to be the House Broadcast network; Boulder 


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47 Exhibit 4 to OCE’s Referral, Interview of President of Boulder Strategies at 12. 48 Exhibit 1 to OCE’s Referral, Interview of Representative Luja ́n at 22–24; Exhibit 1 (6:32 

AM message indicating that Representative Luja ́n was still on the House Floor and had been 

asked to speak ‘‘during the 7 o’clock hour.’’); Exhibit 2. 49See Exhibits 2 & 4. 50See Exhibit 4 (9:37 AM email indicating that Representative Luja ́n was heading to a meeting at the DCCC office building but would ‘‘be a few minutes late to the 9:45’’ AM meeting). 51See Exhibit 2. 52 Exhibit 1 to OCE’s Referral, Interview of Representative Luja ́n at 38–39. 

Strategies included a citation to the image that stated ‘‘Credit to 

House Television via AP.’’ 47

The email from Boulder Strategies read as follows: 

Friend, 

As we pass the 11 am hour in Washington DC, my 

Democratic colleagues and I have now been on the House 

floor for greater than 24-hours, staging a sit-in to demand 

a vote on the bi-partisan No Fly, No Buy bill. 

Despite the fact that Speaker Ryan has turned off the 

cameras and the microphones, I will stand with my colleagues to call for a vote on commonsense legislation that 

keeps guns out of the hands of those on the FBI Terrorist 

Watch List. 

Do you stand with us? Chip in $24 towards our emergency fundraising goal—$1 for every hour we’ve been in 

the well of the House Chamber demanding action. 

A moment of silence on the House floor is simply not 

enough to honor the lives of those we have lost. We need 

action to keep guns out of the hands of suspected terrorists 

and it begins with a vote right here on the House floor. 

Tell the GOP: It’s simple—No Fly, No Buy, No Break. 

Click to contribute $24 (or whatever you can) right now to 

show your support! 

As I said in my email last night, this is a matter of national security. We must come together to pass this commonsense bill. 

Thanks for having our back, 

—Ben Ray 

Representative Luja ́n left the Capitol around 7:00 AM on June 

23, 2016, and went home to sleep.48 An email from Representative 

Luja ́n’s staff at 9:37 AM indicated he was on his way from his 

home to a meeting off the Capitol grounds at the DCCC office 

building.49 Based on this and other contemporaneous emails, it 

does not appear that Representative Luja ́n was in a federal building when Campaign Volunteer sent his email to Boulder Strategies.50 It is possible that Representative Luja ́n was on the House 

Floor at 11:11 AM on June 23rd, when Boulder Strategies sent the 

second sit-in related email to supporters; the email suggested that 

he was ‘‘now’’ on the Floor, and communications between Representative Luja ́n’s staff indicated that he was hoping to return to 

the floor after his 9:45 AM meeting at the DCCC.51 However, given 

that Representative Luja ́n did not actually write, review, or send 

the June 23 email to his supporters,52 the statement that he was 

‘‘now’’ on the Floor may have been mere puffery, or based on an 

expectation of what Representative Luja ́n would do, rather than 

his actual movements. And the internal communications between 


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53 House Rule XXIII, clause 2, requires Members to adhere to the spirit as well as the letter 

of the Rules of the House. 54See Exhibit 4 to OCE’s Referral, Interview of President of Boulder Strategies at 6 (‘‘We had 

done a series of emails about this topic already. Then when the sit-in began on the House floor, 

we simply took an email that was already in the pipeline, we were already planning to send 

an email of this type, and we simply inserted the first line of the email that talked about him 

being on the floor to make it relevant for the day’s topic.’’). 55 Exhibit 3 to OCE’s Referral, Interview of DCCC Chief of Staff at 58–60 (‘‘Did you have any 

communication with Representative Luja ́n before you sent that communication to Boulder Strategies about another e-mail? [Answer]: No. Mr. Payne: So for two days you had no communication with [T] Representative Luja ́n? [Answer]: That’s correct.’’). 56 Exhibit 4 to OCE’s Referral, Interview of President of Boulder Strategies at 7–11 (indicating 

that the President of Boulder Strategies crafted the language of the June 22 and June 23 emails 

himself, without input from Representative Luja ́n, that Representative Luja ́n was not provided 

drafts of the emails, and that Representative Luja ́n did not sign-off on the messages). 57See Committee on Standards of Official Conduct, Investigation of Alleged Improper Political 

Solicitation, 99th Cong., 1st Sess. 19 (1985) (‘‘In view of the foregoing, since the DCCC had no 

knowledge of Wilhelm’s actions on its behalf, it follows that the DCCC should not be held liable 

for whatever actions Wilhelm took vis-a`-vis the solicitation efforts, particularly as regards any 

alleged violation of 18 U.S.C. 602 or 607. From this it, therefore, also follows that, absent any 

Continued 

Representative Luja ́n’s staff do not indicate whether he actually returned to the Floor before the sit-in concluded. 

V. FINDINGS 

A. SOLICITATION OF CAMPAIGN CONTRIBUTIONS AND OTHER CAMPAIGN

ACTIVITY IN HOUSE BUILDINGS

1. Representative Luja ́n’s email did not solicit campaign contributions 

As previously discussed, Representative Luja ́n did not personally 

send the June 22 and June 23, 2016, emails to supporters that 

were the subject of OCE’s Referral. Instead, Representative Luja ́n’s 

campaign consultant, Boulder Strategies, sent the two messages to 

supporters on behalf of Representative Luja ́n’s campaign committee, People for Ben. However, if the Committee found that Representative Luja ́n, while on the House Floor, directed a third-party 

to solicit campaign contributions, such conduct would raise serious 

questions about compliance with at least the spirit of 18 U.S.C. § 

607, which prohibits the solicitation of campaign contributions from 

a federal building.53 However, in this case, the evidence does not 

establish any improper conduct by Representative Luja ́n with respect to either the June 22 or June 23 emails from Boulder Strategies. 

As a threshold matter, it does not appear that either campaign 

email was actually sent at the direction of Representative Luja ́n. 

Boulder Strategies told OCE that the June 22 email to supporters 

was already planned and largely prepared at the time Representative Luja ́n told Campaign Volunteer to ‘‘Get something out.’’ 54

While the June 23 email was not planned and prepared in advance 

of the sit-in, it was created at the direction of Campaign Volunteer, 

with no input or direction from Representative Luja ́n.55 Boulder 

Strategies did send drafts of the June 22 and June 23 emails to 

Representative Luja ́n’s campaign committee before releasing them, 

but it does not appear that those drafts were shared with Representative Luja ́n.56 This is significant because campaign committees are permitted to work, independently but simultaneously, on 

campaign matters while a Member is working on official House 

business.57


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DCCC responsibility for the solicitations, the respondents should similarly not be held liable for 

Wilhelm’s actions.’’). 58See Exhibit 2 to OCE’s Referral. 59 Exhibit 1 to OCE’s Referral, Interview of Representative Luja ́n at 9, 31–32; Exhibit 3 to 

OCE’s Referral, Interview of DCCC Chief of Staff at 56. 60 Ethics Manual at 123. 61See id. at 126. 62See Exhibit 2 to OCE’s Referral. 

Further, the evidence does not show that when Representative 

Luja ́n gave the direction to ‘‘Get something out,’’ he meant that his 

campaign consultants should send a solicitation for campaign 

funds. Representative Luja ́n forwarded an email that another 

Member sent to supporters with a petition related to the ‘‘No Fly 

No Buy’’ bill. The other Member’s email did not include any solicitation of campaign contributions.58 Thus, to the extent Representative Luja ́n intended his campaign to ‘‘get out’’ a similar petition, 

there would be no solicitation, and no violation of 18 U.S.C. § 607. 

It is worth noting that Representative Luja ́n gave Boulder Strategies the discretion to determine whether any particular email they 

sent from his campaign committee would be a solicitation or something else.59 Thus, he created a condition in which an ambiguous 

instruction to Boulder Strategies could be read, and implemented, 

either way. Moreover, as previously discussed, the Committee holds 

Members responsible for ensuring that campaign consultants who 

work on their behalf follow all applicable laws, rules, regulations, 

and other standard of conduct.60 In this case, however, there is no 

evidence that Representative Luja ́n expected, or should have expected, that when he forwarded a petition from another Member’s 

campaign to his own campaign consultants, that would result in a 

campaign solicitation. 

Accordingly, the Committee did not find that Representative 

Luja ́n violated either the letter or the spirit of the federal law prohibiting the solicitation of campaign donations from a federal building. 

2. The record does not show that Representative Luja ́n engaged in 

campaign activity in a House building 

While the evidence does not establish that Representative 

Luja ́n’s email to ‘‘Get something out’’ solicited campaign contributions, there is a separate question whether, by sending the email, 

he engaged in any campaign or political activity from a House 

building. Doing so would violate both a federal statute, 31 U.S.C. 

§ 1301(a), and regulations from the Committee on House Administration (CHA). As previously discussed, the Committee and CHA 

have made clear that even ‘‘incidental’’ campaign or political activity in a House building is not permitted.61

Representative Luja ́n’s email, on June 22, 2016, to Campaign 

Volunteer, with the direction to ‘‘Get something out’’ about the sitin was clearly campaign or political activity. This inference is supported by the message that Representative Luja ́n forwarded with 

his direction, which was a petition about the sit-in from another 

Member’s campaign to her supporters,62 and by Campaign Volunteer’s role with Representative Luja ́n’s campaign, and as a conduit 

between Representative Luja ́n and the paid campaign consultants 

at Boulder Strategies. 


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63See id. 64 Representative Luja ́n recalled that he was on and off the House Floor, and in and out of 

the Capitol building, during the sit-in. See Exhibit 1 to OCE’s Referral, Interview of Representative Luja ́n, at 23–25. 65 Ethics Manual at 132–35. 66This image was not sourced from C–SPAN’s rebroadcast of images that House Members 

were broadcasting from their phones, using third-party, nonofficial mobile applications, after the 

House Floor cameras were turned off. Rather, as previously discussed, the still image that Boulder Strategies used came from an Associated Press article, which included a screen shot from 

the cameras that are part of the House broadcasting system. 67 Representative Luja ́n Submission at 9–10. 68 House Rule V, Clause 2(c). 

However, any allegation that Representative Luja ́n engaged in 

campaign or political activity from a federal building would require 

proof that Representative Luja ́n was on the House Floor or in another federal space when he sent out his sole email at issue here, 

the instruction to ‘‘Get something out.’’ 63 After reviewing all of the 

available evidence, including C–SPAN footage of the sit-in, Representative Luja ́n’s testimony to OCE,64 and contemporaneous 

emails and text messages from and between the Member and his 

staff, the Committee could not establish Representative Luja ́n’s location when he forwarded another Member’s petition to Campaign 

Volunteer. Without some proof of Representative Luja ́n’s location, 

the Committee will not find that he violated the letter or spirit of 

federal law or House regulations regarding campaign activity in 

House buildings. 

Nonetheless, the Committee cautions all Members that drafting, 

editing, commenting on, or sending campaign or political communications from a House building is not permitted. The Committee 

has long recognized that there are certain limited campaign or political activities that, while related to a Member’s campaign, may 

properly take place in a congressional office.65 However, sending a 

direction to a campaign consultant or volunteer to ‘‘Get something 

out’’ does not fall within the very limited and very specific exceptions to the general rule. In this age of always-on mobile communications, Members may find it impractical or unreasonable to have 

to exit a House building before sending a three-word campaign 

email. However, that is what the relevant law, rules, and regulations require. 

B. BOULDER STRATEGIES’ USE OF AN IMAGE OF THE HOUSE FLOOR IN

THE JUNE 23, 2016, CAMPAIGN SOLICITATION

The Committee found that Boulder Strategies’ use of a still 

image of the House Floor 66 in campaign correspondence on behalf 

of People for Ben was a technical violation of House Rule V, clause 

2(c)(1), which prohibits partisan use of the ‘‘system for close-circuit 

viewing of floor proceedings of the House,’’ which the Speaker administers, directs, and controls. 

While Representative Luja ́n’s submission to the Committee argues that Rule V only prohibits use of video footage from floor proceedings and not still images,67 this interpretation finds no support 

in the express language of Rule V or the guidance historically dispensed by the Committee. House Rule V prohibits the use of 

‘‘[c]overage made available under this clause, including any recording thereof.’’ 68 Limiting the term ‘‘coverage’’ to video recordings 

when the provision expressly lists ‘‘recording[s]’’ as simply one example of coverage would be inconsistent. Further, in a 2014 ‘‘Pink 


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69See Memorandum from the Committee to all Members, ‘‘Campaign Activity Guidance,’’ Aug. 

15, 2014, at 16 (available at http://ethics.house.gov/sites/ethics.house.gov/files/ 

20140815%20Pink%20Sheet.pdf). 70 Exhibit 4 to OCE’s Referral, Interview of President of Boulder Strategies at 12. 71While a draft of the June 23, 2016, email including the image of the House Floor was circulated to Campaign Volunteer and Representative Luja ́n’s campaign committee approximately 

thirty minutes before its release, there is no evidence that Representative Luja ́n’s campaign 

committee reviewed the message before it was released, and Campaign Volunteer appears to 

have provided an expedited sign-off on the draft message. 72See Ethics Manual at 123. 73 In a likely oversight, Representative Luja ́n’s agreement with Boulder Strategies includes a 

provision that Boulder Strategies shall ‘‘comply with the applicable Federal Election Commission regulations, as well as any other applicable federal or state laws,’’ but does not contain a 

similar requirement with respect to compliance with House rules. See Exhibit 5. 74 Exhibit 6; Exhibit 4 to OCE’s Referral, Interview of President of Boulder Strategies at 12 

(after a follow-up conversation, ‘‘[w]e agreed not to use further images from the house floor, regardless of their sourcing, going forward’’). 75OCE’s Referral at 15. 

Sheet’’ distributed to all Member offices, the Committee made clear 

that Members may not re-use an image of floor proceedings published by a third-party, if the Member could not use that image in 

the first instance.69

Representative Luja ́n’s submission to the Committee indicates 

that the image was originally sourced from the House Broadcast 

network, although the video capture was made by the Associated 

Press and published by them as a still image. Thus, Representative 

Luja ́n’s campaign committee and consultant did not directly source 

the image from the House recording system, but made derivative 

use of it.70 However, the Committee’s guidance has made clear that 

such a derivative use is not permissible. 

Representative Luja ́n has presented evidence that he was not 

aware that Boulder Strategies would include a still image of the 

House Floor in its email correspondence, and that he played no 

part in creating or reviewing the correspondence.71 The Committee 

has long held that Members of the House are responsible for ensuring that individuals speaking on their behalf comply with applicable House rules.72 The Committee believes such a Rule is necessary 

to ensure that individuals do not rely upon third parties to circumvent relevant House rules.73 In this case, the Committee is satisfied that, after Boulder Strategies sent the email that was the 

subject of OCE’s Referral, Representative Luja ́n took steps to prevent a recurrence of this issue, by instructing Boulder Strategies 

that ‘‘[a]s a standing rule from here out,’’ ‘‘[w]e will not be using 

any images of the [H]ouse floor in any of our emails.’’ 74 In addition, while the Committee disapproves of any violation of House 

rules, given the totality of the circumstances here, this is not the 

type of conduct that would merit any further action. Indeed, the 

Committee regularly addresses allegations of violations of House 

Rule V in an advisory manner, rather than investigating each such 

allegation. 

VI. CONCLUSION 

As noted by OCE, ‘‘the evolving nature of electronic communications and campaign solicitations sometimes presents novel issues 

that are not directly addressed by the House Ethics Manual.’’ 75

The Committee agreed that this is an area where additional guidance could be useful. 

Although the Committee did not conclude that Representative 

Luja ́n made, or directed the making of, campaign solicitations from 


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the House Floor or any federal building, the Committee cautions all 

Members that use of a third party to send campaign correspondence does not absolve them of their responsibility to ensure campaign correspondence complies with applicable laws and House 

rules. A Member’s campaign committee or consultants may release 

campaign correspondence on the Member’s behalf at any time, regardless of where the Member is. However, Members are reminded 

that, subject to very limited exceptions, they may not conduct campaign or political activity from a House building, whether hallway, 

office, or cafeteria, and thus, they may not draft, edit, or send campaign communications, or direct the drafting, editing, or sending of 

such communications, from a House building. This rule, which is 

embodied in federal law, applies even where the Member is using 

a personal or campaign communications device, and even if they 

are not using the House internet system. 

With respect to the use of a screen shot sourced from the House 

recording system, the Committee found that the campaign consultant’s actions did violate House Rule V, and that Representative 

Luja ́n is ultimately responsible for that violation. However, there 

is no evidence that Representative Luja ́n was aware of the decision 

to use the image before it was included in a campaign solicitation, 

and Representative Luja ́n and his campaign have taken steps to 

prevent any recurrence of this issue in the future. For these reasons, the Committee does not believe that any sanction of Representative Luja ́n would be appropriate. 

The Committee has determined to take no further action in this 

matter, and upon publication of this Report, considers the matter 

closed. 

VII. STATEMENT UNDER HOUSE RULE XIII, CLAUSE 3(c) 

The Committee made no special oversight findings in this Report. 

No budget statement is submitted. No funding is authorized by any 

measure in this Report. 


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SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 143 here HR272.125
139 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 144 here HR272.126
140 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 145 here HR272.127
141 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 146 here HR272.128
142 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 147 here HR272.129
143 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 148 here HR272.130
144 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 149 here HR272.131
145 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 150 here HR272.132
146 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 151 here HR272.133
147 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 152 here HR272.134
148 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 153 here HR272.135
149 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 154 here HR272.136
150 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 155 here HR272.137
151 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 156 here HR272.138
152 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 157 here HR272.139
153 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 158 here HR272.140
154 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 159 here HR272.141
155 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 160 here HR272.142
156 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 161 here HR272.143
157 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 162 here HR272.144
158 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 163 here HR272.145
159 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 164 here HR272.146
160 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 165 here HR272.147
161 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 166 here HR272.148
162 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 167 here HR272.149
163 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 168 here HR272.150
164 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 169 here HR272.151
165 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 170 here HR272.152
166 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 171 here HR272.153
167 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 172 here HR272.154
168 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 173 here HR272.155
169 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 174 here HR272.156
170 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 175 here HR272.157
171 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 176 here HR272.158
172 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 177 here HR272.159
173 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 178 here HR272.160
174 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 179 here HR272.161
175 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 180 here HR272.162
176 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 181 here HR272.163
177 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 182 here HR272.164
178 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 183 here HR272.165
179 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 184 here HR272.166
180 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 185 here HR272.167
181 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 186 here HR272.168
182 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 187 here HR272.169
183 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 188 here HR272.170
184 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 189 here HR272.171
185 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 190 here HR272.172
186 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 191 here HR272.173
187 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 192 here HR272.174
188 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 193 here HR272.175
189 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 194 here HR272.176
190 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 195 here HR272.177
191 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 196 here HR272.178
192 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 197 here HR272.179
193 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 198 here HR272.180
194 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 199 here HR272.181
195 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 200 here HR272.182
196 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 201 here HR272.183
197 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 202 here HR272.184
198 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 203 here HR272.185
199 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 204 here HR272.186
200 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 205 here HR272.187
201 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 206 here HR272.188
202 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 207 here HR272.189
203 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 208 here HR272.190
204 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 209 here HR272.191
205 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 210 here HR272.192
206 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 211 here HR272.193
207 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 212 here HR272.194
208 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 213 here HR272.195
209 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 214 here HR272.196
210 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 215 here HR272.197
211 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 216 here HR272.198
212 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 217 here HR272.199
213 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 218 here HR272.200
214 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 219 here HR272.201
215 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 220 here HR272.202
216 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 221 here HR272.203
217 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 222 here HR272.204
218 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 223 here HR272.205
219 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 224 here HR272.206
220 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 225 here HR272.207
221 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 226 here HR272.208
222 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 227 here HR272.209
223 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 228 here HR272.210
224 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 229 here HR272.211
225 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 230 here HR272.212
226 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 231 here HR272.213
227 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 232 here HR272.214
228 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 233 here HR272.215
229 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 234 here HR272.216
230 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 235 here HR272.217
231 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 236 here HR272.218
232 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 237 here HR272.219
233 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 238 here HR272.220
234 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 239 here HR272.221
235 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 240 here HR272.222
236 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 241 here HR272.223
237 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 242 here HR272.224
238 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 243 here HR272.225
239 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 244 here HR272.226
240 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 245 here HR272.227
241 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 246 here HR272.228
242 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 247 here HR272.229
243 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 248 here HR272.230
244 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 249 here HR272.231
245 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 250 here HR272.232
246 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 251 here HR272.233
247 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 252 here HR272.234
248 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 253 here HR272.235
249 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 254 here HR272.236
250 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 255 here HR272.237
251 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 256 here HR272.238
252 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 257 here HR272.239
253 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 258 here HR272.240
254 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 259 here HR272.241
255 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 260 here HR272.242
256 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 261 here HR272.243
257 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 262 here HR272.244
258 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 263 here HR272.245
259 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 264 here HR272.246
260 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 265 here HR272.247
261 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 266 here HR272.248
262 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 267 here HR272.249
263 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 268 here HR272.250
264 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 269 here HR272.251
265 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 270 here HR272.252
266 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 271 here HR272.253
267 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 272 here HR272.254
268 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 273 here HR272.255
269 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 274 here HR272.256
270 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 275 here HR272.257
271 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 276 here HR272.258
272 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 277 here HR272.259
273 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 278 here HR272.260
274 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 279 here HR272.261
275 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 280 here HR272.262
276 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 281 here HR272.263
277 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 282 here HR272.264
278 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 283 here HR272.265
279 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 284 here HR272.266
280 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 285 here HR272.267
281 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 286 here HR272.268
282 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 287 here HR272.269
283 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 288 here HR272.270
284 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 289 here HR272.271
285 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 290 here HR272.272
286 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 291 here HR272.273
287 


SSpencer on DSKBBV9HB2PROD with REPORTSInsert offset folio 292 here HR272.274