" ! HOUSE OF REPRESENTATIVES 

112TH CONGRESS

1st Session 

REPORT

112–195 

House Calendar No. 69 

IN THE MATTER OF ALLEGATIONS 

RELATING TO 

REPRESENTATIVE JEAN SCHMIDT 

R E P O R T 

OF THE

COMMITTEE ON ETHICS 

AUGUST 5, 2011.—Referred to the House Calendar and ordered to be 

printed 


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IN THE MATTER OF ALLEGATIONS RELATING TO REPRESENTATIVE 

JEAN SCHMIDT 


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1 

67–754 

" ! HOUSE OF REPRESENTATIVES 

112TH CONGRESS

1st Session 

REPORT

2011

112–195 

House Calendar No. 69 

IN THE MATTER OF ALLEGATIONS 

RELATING TO 

REPRESENTATIVE JEAN SCHMIDT 

R E P O R T 

OF THE

COMMITTEE ON ETHICS 

AUGUST 5, 2011.—Referred to the House Calendar and ordered to be 

printed 


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(II) 

COMMITTEE ON ETHICS 

JO BONNER, Alabama 

Chairman 

MICHAEL T. MCCAUL, Texas 

K. MICHAEL CONAWAY, Texas 

CHARLES W. DENT, Pennsylvania 

GREGG HARPER, Mississippi 

LINDA T. SA ́ NCHEZ, California 

Ranking Member 

JOHN A. YARMUTH, Kentucky 

DONNA F. EDWARDS, Maryland 

PEDRO R. PIERLUISI, Puerto Rico 

JOE COURTNEY, Connecticut 

REPORT STAFF

DANIEL A. SCHWAGER, Chief Counsel/Staff Director 

DEBORAH SUE MAYER, Director of Investigations 

KELLE A. STRICKLAND, Counsel to the Chairman 

DANIEL J. TAYLOR, Counsel to the Ranking Member 

THOMAS A. RUST, Senior Counsel 


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(III)

LETTER OF TRANSMITTAL 

U.S. HOUSE OF REPRESENTATIVES, 

COMMITTEE ON ETHICS, 

Washington, DC, August 5, 2011. 

Hon. KAREN L. HAAS, 

Clerk, U.S. 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 Regarding Allegations Relating 

to Representative Jean Schmidt.’’ 

Sincerely, 

JO BONNER, 

Chairman. 

LINDA T. SA ́ NCHEZ, 

Ranking Member. 


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(V) 

C O N T E N T S 

Page 

I. Introduction ...................................................................................................... 1 

II. Background ....................................................................................................... 4 

III. Findings and Conclusions ................................................................................ 11 

IV. Statement Under Rule 13, Clause 3(c) of the Rules of the House of 

Representatives ............................................................................................. 20 

Appendix A: Report and Findings of the Office of Congressional Ethics Regarding Representative Jean Schmidt (Review No. 11–6574) .......................... 21 

Appendix B: Representative Jean Schmidt’s Response to the Report and Findings of the Office of Congressional Ethics .......................................................... 475 


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112TH CONGRESS REPORT " ! HOUSE OF REPRESENTATIVES 1st Session 112–195 

IN THE MATTER REGARDING ALLEGATIONS RELATING 

TO REPRESENTATIVE JEAN SCHMIDT 

AUGUST 5, 2011.—Referred to the House Calendar and ordered to be printed 

Mr. BONNER, from the Committee on Ethics, 

submitted the following 

R E P O R T 

I. INTRODUCTION 

The Committee on Ethics submits this Report pursuant to Rule 

XI, clause 3(a)(2), of the Rules of the U.S. House of Representatives 

(House Rules), which authorizes the Committee to investigate any 

alleged violation by a Member, officer, or employee of the House of 

Representatives, of the Code of Official Conduct or any law, rule, 

regulation, or other standard applicable to the conduct of such 

Member, officer, or employee. 

Since the spring of 2009, Representative Jean Schmidt has been 

involved in litigation regarding statements made about her by 

David Krikorian, an opponent in her 2008 re-election campaign. 

That dispute has involved proceedings before an Ohio state agency, 

in Ohio state court, and in federal court. 

In a letter dated September 17, 2009, Representative Jean 

Schmidt first sought guidance related to payment of legal services 

provided to her in the state agency and state court proceedings by 

lawyers associated with the Turkish American Legal Defense Fund 

(TALDF). On February 26, 2010, the Committee provided guidance 

on the possible use of a legal expense fund or of campaign funds 

to pay for legal work already completed in those proceedings. The 

Committee’s letter did not formally approve a legal expense fund 

pursuant to the Committee’s written guidance on legal expense 

funds, because Representative Schmidt had not yet asked the Committee for such approval. 

In letters dated July 19, 2010, August 9, 2010, and August 11, 

2010, Representative Schmidt sought approval from the Committee 

of a legal expense fund, a contingency fee arrangement, and further 

guidance related to payment of legal services provided to her in the 

state agency and state court proceedings, as well as a federal court 

proceeding. Since first seeking the Committee’s guidance, RepreVerDate Mar 15 2010 07:18 Aug 10, 2011 Jkt 067754 PO 00000 Frm 00009 Fmt 6659 Sfmt 6602 E:\HR\OC\HR195.XXX HR195

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1 Report and Findings in the Matter of Representative Jean Schmidt, OCE Review No. 11– 

6574, May 18, 2011. A copy of OCE’s Report and Findings is attached as Appendix A to this 

report. 2Letter from Representative Schmidt to Committee, May 27, 2011. A copy of Representative 

Schmidt’s response to OCE’s Report and Findings is attached as Appendix B to this report. 3Pursuant to Committee Rule 3(j), the Committee will not release any of its letters to Representative Schmidt at this time. 

sentative Schmidt has worked in good faith with the Committee’s 

Office of Advice and Education to resolve any outstanding issues 

regarding the payment of legal services to the lawyers associated 

with TALDF. 

On May 18, 2011, the Committee formally received a referral 

from the Office of Congressional Ethics (OCE), recommending further review of allegations that Representative Schmidt: ‘‘(1) accepted legal services from TALDF without establishing a legal expense 

fund; and (2) failed to report the legal services on her financial disclosure statements for calendar years 2008 and 2009.’’ 1 Upon receipt of OCE’s Report and Findings (Report and Findings), the 

Committee sent a copy of the Report and Findings to Representative Schmidt and offered her an opportunity to respond. Representative Schmidt submitted a response to OCE’s Report and Findings 

on May 27, 2011.2 On July 1, 2011, the Chairman and Ranking 

Member of the Committee jointly decided to extend the Committee’s review of the OCE referral regarding Representative Schmidt 

pursuant to House Rule XI, clause 3(a)(8)(A), and Committee Rules 

17A(b)(1)(A) and 17A(c)(1). Unless the Committee voted to empanel 

an investigative subcommittee, those rules required the Committee 

to release OCE’s Report and Findings no later than August 16, 

2011. 

The Committee conducted an independent investigation into the 

matters in the OCE referral pursuant to House Rule XI, clause 

3(b)(1)(B)(ii), and Committee Rule 18(a), which authorize the 

Chairman and Ranking Member to jointly gather additional information concerning an alleged violation by a Member, officer, or employee unless and until an investigative subcommittee has been established. 

Based on the Committee’s investigation and nearly two years of 

guidance to Representative Jean Schmidt through the Committee’s 

Office of Advice and Education, the Committee voted unanimously 

on August 1, 2011, to resolve the issues surrounding Representative Schmidt’s outstanding requests for guidance from the Committee and the allegations regarding Representative Schmidt by 

OCE, by issuing a letter to Representative Schmidt and releasing 

this Report.3 The Committee further determined that it was appropriate to publicly release OCE’s Report and Findings, along with 

Representative Schmidt’s response to the Report and Findings, 

through this Report. 

With respect to Representative Schmidt’s request for guidance 

from the Committee, the Committee in its guidance, issued contemporaneously with this Report, approved the use of funds from the 

Jean Schmidt Legal Expense Trust to pay legal bills incurred in 

connection with her complaint before the Ohio Elections Commission and the defamation action, subject to certain restrictions discussed below. The Committee denied the use of funds from the 

Jean Schmidt Legal Expense Trust to pay legal bills incurred in 

connection with amicus briefs filed in Krikorian v. Ohio Elections 


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3 

Commission. Additionally, the Committee has determined that 

Representative Schmidt’s use of campaign funds to pay for the 

Ohio Elections Commission matter, the defamation action, and the 

amicus briefs filed in Krikorian v. Ohio Elections Commission 

would not violate House rules, subject to certain restrictions discussed below. However, the Committee advised Representative 

Schmidt to consult with the Federal Election Commission (FEC) 

before using campaign funds for any of these purposes. Finally, the 

Committee denied permission to enter into a so-called ‘‘contingency 

fee’’ arrangement. 

With respect to the referral from OCE, it appears that, based on 

the evidence examined by the Committee, unbeknownst to Representative Schmidt or the Committee, Representative Schmidt’s 

lawyers were not employees of TALDF, or the related entity, the 

Turkish Coalition of America (TCA), and were not planning to send 

her a bill for attorneys’ fees at the conclusion of the matter, but instead her lawyers were outside counsel to TCA who have sent 

monthly bills to TCA for their TALDF-related legal representation 

of Representative Schmidt, which TCA has paid on an ongoing 

basis. According to OCE’s referral, between 2008 and 2010 TCA actually paid the TALDF lawyers approximately $500,000 for legal 

services provided to Representative Schmidt. Neither the Committee nor, according to the evidence, Representative Schmidt was 

aware of these payments when the Committee provided advice to 

Representative Schmidt regarding her options for paying legal fees 

in the various proceedings. 

Despite Representative Schmidt’s apparent lack of knowledge of 

this arrangement, it was in fact improper and constituted an impermissible gift from TCA to Representative Schmidt. Thus, the 

Committee has decided that it will not dismiss the allegations in 

the OCE referral. However, the Committee does not see the need 

to empanel an investigative subcommittee at this time. The Committee does not believe that further fact-gathering is necessary, 

and, given the evidence that Representative Schmidt lacked knowledge of the arrangement, the Committee does not believe that any 

sanction is necessary. In addition, the Committee notes that Representative Schmidt has been working in good faith with the Committee since 2009 to ascertain the appropriate means by which to 

pay her attorneys. 

However, Representative Schmidt must disclose and repay the 

improper gift. Thus, Representative Schmidt must ensure that TCA 

does not pay for any further legal services on her behalf, and, 

subject to the guidance below, Representative Schmidt must pay, 

from a permissible source, the lawyers associated with TALDF for 

all legal services they performed on her behalf; Representative 

Schmidt must also amend her annual Financial Disclosure Statements for calendar years 2009 and 2010 to disclose the gifts from 

TCA; and finally, Representative Schmidt must disclose the remaining unpaid legal fees from TCA as liabilities on her future Financial Disclosure Statements, until the lawyers associated with 

TALDF have been repaid in full, for all services provided, including 

those they originally billed to TCA. 


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4 Complaint, ¶3, Jean Schmidt v. Mr. David Krikorian, Ohio Elections Commission, 2009E– 

003, April 29, 2009 (Ohio Elections Commission Complaint). 5Transcript of Interview of Barry Bennett, at 5 (Bennett Tr.). 

6Transcript of Interview of Bruce Fein, at 15 (Fein Tr.). 

7Fein Tr. at 31. 

8 Id. at 16. 9See Ohio Rev. Code § 3517.21. 10Ohio Elections Commission Complaint. 11 Id. 12Deposition of Bruce Fein, August 31, 2009 (Fein Deposition). 

II. BACKGROUND 

Based on OCE’s referral, the Committee’s independent investigation, and nearly two years of guidance to Representative Schmidt 

through the Committee’s Office of Advice and Education, the following is the background on this matter. 

A. LITIGATION INVOLVING MR. KRIKORIAN

Representative Schmidt currently represents the 2nd District of 

Ohio. In the 2008 general election cycle, Mr. David Krikorian ran 

for her congressional seat as an independent.4 In the final days of 

the 2008 election cycle, Mr. Krikorian distributed materials accusing Representative Schmidt of accepting a $30,000 bribe from the 

Government of Turkey in exchange for denying the genocide of Armenians in Turkey during World War I. The campaign materials 

also called for Representative Schmidt’s immediate resignation 

from her congressional seat and/or her defeat at the polls in the 

2008 general election. Representative Schmidt was reelected in the 

November 2008 general election. 

Shortly after the 2008 election, Representative Schmidt was contacted by Mr. Bruce Fein and Mr. David Saltzman, who introduced 

themselves as lawyers with TALDF.5 At that time, Mr. Fein and 

Mr. Saltzman offered to represent Representative Schmidt in a 

lawsuit challenging Mr. Krikorian’s claims about her. At that time, 

Representative Schmidt expressed some interest in Mr. Fein and 

Mr. Saltzman representing her, but she stated that she wanted it 

to be done on whatever terms were consistent with the House ethics rules.6 At some point, Mr. Fein suggested using a contingency 

fee arrangement, in which the lawyers associated with TALDF 

would not charge Representative Schmidt for legal services, but she 

would split the proceeds of any damage award that resulted from 

their representation.7 However, Representative Schmidt and the 

lawyers associated with TALDF never came to a final understanding of how she would pay for their legal services. 

In April 2009, Mr. Fein and Mr. Saltzman filed a complaint on 

Representative Schmidt’s behalf against Mr. Krikorian with the 

Ohio Elections Commission.8 The Ohio Elections Commission has 

jurisdiction over false campaign statements under Ohio law.9 Representative Schmidt filed the complaint as a candidate and used 

her campaign committee address.10 The complaint sought: (1) a 

finding by the Ohio Elections Commission that Mr. Krikorian violated Ohio law by making false campaign statements; (2) a public 

reprimand of Mr. Krikorian; and (3) any other appropriate relief.11

On August 31, 2009, Mr. Fein was deposed in the Ohio Elections 

Commission matter.12 Later that day, Representative Schmidt’s 

then-Chief of Staff, Barry Bennett, was also deposed in the Ohio 


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13Deposition of Barry Bennett, August 31, 2009 (Bennett Deposition). 14Fein Deposition at 60. 15 Bennett Deposition at 49. 16 Id. 17 Committee Telephone Inquiries Log, September 10, 2009, 3:11:17 p.m. (Sept. 10 Phone Log). 18 Id. 19 Bennett Tr. at 6–7. 20Sept. 10 Phone Log. 21Schmidt Letter to Committee, September 17, 2009. 22 Email from Barry Bennett to Committee counsel, October 2, 2009. 23Letter from Barry Bennett to Committee counsel, October 8, 2009. 24Letter from Bruce Fein and David Saltzman to Representative Schmidt, undated. 

Elections Commission matter.13 Lawyers representing Mr. 

Krikorian asked Mr. Fein and Mr. Bennett about the arrangement 

for payment of Mr. Fein’s and Mr. Saltzman’s attorneys’ fees for 

representing Representative Schmidt. In response to the question 

of whether TALDF had charged Representative Schmidt’s campaign for legal services to her, Mr. Fein stated, ‘‘The answer is no. 

We stated that we would do this and we would not charge them 

legal fees.’’ 14 Mr. Bennett was asked if there was an ‘‘ethics issue 

associated with [TALDF] paying for Ms. Schmidt’s legal fees?’’ 15

Mr. Bennett responded, ‘‘No, not that I’m aware of.’’ 16

According to Committee records, Mr. Bennett first called the 

Committee on or around September 10, 2009, to ask the Committee’s guidance regarding the payment of legal fees incurred on Representative Schmidt’s behalf in the course of pursuing the complaint against Mr. Krikorian before the Ohio Elections Commission.17 In that telephone call Mr. Bennett discussed a possible contingency fee agreement.18 Committee counsel asked Mr. Bennett if 

Representative Schmidt had considered using a legal expense fund, 

and Mr. Bennett said that this was the first time he had considered it.19 Committee counsel instructed Mr. Bennett that Representative Schmidt should submit a letter to the Committee to get 

formal guidance on these issues.20 Representative Schmidt first 

submitted a letter to the Committee on September 17, 2009, seeking formal guidance.21

In October 2009, Representative Schmidt received a finding of 

fact from the Ohio Elections Commission that there was clear and 

convincing evidence that Mr. Krikorian made false statements with 

malice.22 Mr. Krikorian filed an appeal in Ohio state court seeking 

to overturn the administrative ruling by the Ohio Elections Commission, which was denied. On October 8, 2009, Representative 

Schmidt’s office responded to requests from Committee counsel by 

providing the Committee with information related to her September 17, 2009, request.23 These materials included a letter in 

which Mr. Fein and Mr. Saltzman stated that they ‘‘have agreed 

to represent [Representative Schmidt] as attorneys . . . for a contingency fee of one-third of any recovery, plus out-of-pocket expenses.’’ 24 Mr. Bennett believed it was unlikely that a contingency 

fee arrangement would be approved, and understood from his conversations with Committee counsel that it appeared that the Committee had not previously approved a contingency fee arrangement. 

Representative Schmidt subsequently amended her request to omit 

the request for approval of a contingency fee arrangement. 

On January 21, 2010, Mr. Krikorian filed a civil suit in federal 

court against the Ohio Elections Commission that challenged the 

constitutionality of Section 3517.21(B)(10) of the Ohio Revised 

Code, which prohibits a candidate from making ‘‘a false statement 


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25 Complaint, Krikorian v. Ohio Elections Commission, 1:10–cv–00720–TSB (S.D. Ohio Jan. 

21, 2010). 26 Amicus Brief, Krikorian v. Ohio Elections Commission, 1:10–cv–00720–TSB (S.D. Ohio Jan. 

29, 2010). 27Letter from Committee to Representative Schmidt, February 26, 2010. 28 Id. The Committee had not been previously aware that Representative Schmidt’s intention 

to participate in the federal court matter had changed. 29 Complaint, Schmidt v. Krikorian, et al., 2010–cvc–1217 (June 8, 2010). 30 Id. 31 Id. 

concerning a candidate, either knowing the same to be false or with 

reckless disregard of whether it was false or not, if the statement 

is designed to promote the election, nomination, or defeat of the 

candidate.’’ 25 Mr. Krikorian also contended the statute is preempted by the Federal Elections Campaign Act of 1971 (as amended). He sought a declaratory judgment that the Ohio statute is unconstitutional and an injunction against its enforcement against 

him. Representative Schmidt was not a named party to this federal 

court case. On January 29, 2010, Representative Schmidt filed an 

amicus brief in the federal court action in support of the Ohio Elections Commission.26 The brief was prepared for Representative 

Schmidt by the lawyers associated with TALDF. 

On February 26, 2010, the Committee sent a response to Representative Schmidt’s September 17, 2009, letter.27 This letter provided guidance on the possible use of a legal expense fund or of 

campaign funds to pay for legal work already completed during the 

Ohio Elections Commission proceedings and future work on Representative Schmidt’s behalf in the appellate case in Ohio state 

court. The Committee’s letter did not formally approve a legal expense fund pursuant to the Committee’s written guidance on legal 

expense funds, because Representative Schmidt had not yet asked 

the Committee for such approval. The letter noted Mr. Krikorian’s 

civil suit in federal court against the Ohio Elections Commission, 

but stated that Representative Schmidt was ‘‘not a named party to 

this federal court case and [did] not anticipate any involvement in 

that separate litigation.’’ 28

On June 8, 2010, lawyers associated with TALDF filed a defamation action on Representative Schmidt’s behalf against Mr. 

Krikorian in the Ohio Court of Common Pleas.29 Representative 

Schmidt’s complaint in the defamation action alleges that Mr. 

Krikorian made defamatory statements similar to those made in 

the campaign and republished the defamatory statements made 

during the campaign when interviewed by Asbarez.com in June 

2009.30 Representative Schmidt alleges he made further defamatory statements in The Armenian Reporter and The Armenian Mirror-Spectator in August 2009 and again in a televised interview in 

September 2009.31

On July 13, 2010, Mr. Krikorian filed a complaint regarding Representative Schmidt with the Office of Congressional Ethics. Mr. 

Krikorian asserted that Representative Schmidt’s acceptance of 

legal services from the TALDF attorneys may have violated the 

House gift rule, and alleged possible violations of the Ethics in 

Government Act, the False Statements Accountability Act, and 

other House Rules. In the complaint, Mr. Krikorian stated ‘‘while 

purely an estimate on my part, I believe the total fees and expenses associated with the OEC Action exceeded $200,000 and may 

have ranged up to $500,000.’’ The complaint also stated that pubVerDate Mar 15 2010 07:18 Aug 10, 2011 Jkt 067754 PO 00000 Frm 00014 Fmt 6659 Sfmt 6602 E:\HR\OC\HR195.XXX HR195

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32Motion for Admission Pro Hac Vice for Bruce Fein of Bruce E. Fein & Associates, Inc., 

Schmidt v. Krikorian, et al., 2010–cvc–1217 (September 27, 2010). 33Memorandum in Opposition to Motion for Admission Pro Hac Vice for Bruce Fein of Bruce 

E. Fein & Associates, Inc., Schmidt v. Krikorian, et al., 2010–cvc–1217 (October 22, 2010). 34 Id. at 4. 35 Id. at 7. 36 Reply Memorandum of Plaintiff Jean Schmidt in Support of Motion for Admission Pro Hac 

Vice for Bruce Fein, Schmidt v. Krikorian, et al., 2010–cvc–1217 (November 11, 2010), at 13. 37 Id. at 14. 38 Id. at 14–15. 39 Id. at 14. 40Order, Decision and Entry Denying Plaintiff’s Motion to Admit Pro Hac Vice Bruce Fein, 

Esq., Schmidt v. Krikorian, et al., 2010–cvc–1217 (April 4, 2011). 

licly available records showed no payments from her campaign for 

the legal services or the establishment of a legal defense fund. 

On July 19, August 9, and August 11, 2010, Representative 

Schmidt wrote letters to the Committee seeking approval of the 

Jean Schmidt Legal Expense Trust. She sought to use the fund to 

pay for legal expenses incurred in the Ohio Elections Commission 

matter and the federal court litigation to which she was not a 

party. Representative Schmidt also resubmitted a request for approval of a contingency fee arrangement to pay for the defamation 

action. 

On September 27, 2010, Mr. Fein filed a motion to be admitted 

pro hac vice in the Ohio Court of Common Pleas for Representative 

Schmidt’s defamation action.32 On October 22, 2010, the defendants in the defamation matter filed a legal brief opposing Mr. 

Fein’s admission pro hac vice.33 In the opposition brief, defendants 

asserted that Mr. Fein was a ‘‘necessary witness’’ in the matter, 

and had potentially perjured himself, because: 

Mr. Fein testified under oath that the Turkish American 

Legal Defense Fund (‘‘TALDF’’)—an entity that is part of 

the Turkish Coalition of America (‘‘TCA’’)—was paying 

Plaintiff Schmidt’s legal fees during the pendency of the 

Ohio Elections Commission that serve as a basis of this instant case.34

The opposition brief further asserted that Mr. Fein may have a 

conflict of interest in the case because ‘‘it is also very likely Mr. 

Fein advised Plaintiff Schmidt that their arrangement regarding 

not charging her, her congressional office, or her campaign was 

perfectly legal without any disclosure.’’ 35

Representative Schmidt’s lawyers filed a reply brief in the matter 

which asserted that ‘‘Mr. Fein’s statements during his deposition 

were accurate and consistent with the information available to him 

at the time they were made.’’ 36 The reply brief further stated that 

‘‘Mr. Fein has testified under oath that he never provided free legal 

services to plaintiff.’’ 37 Instead, the brief stated that ‘‘[t]he Turkish 

Coalition of America . . . has consistently funded Fein’s representation of Jean Schmidt as senior counsel at the Turkish American 

Legal Defense Fund . . . for the duration of her several legal actions against Defendant Krikorian.’’ 38 Finally, the reply brief stated that ‘‘Mr. Fein did not advise Plaintiff Schmidt rules [sic] governing the receipt of free legal services by members of Congress.’’ 39

Following oral argument, the Ohio Court of Common Pleas 

issued an order denying Mr. Fein’s motion.40 As part of its support 

for this ruling, the court stated: 


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41 Id. at 3. 42Schmidt Letter to Committee, May 27, 2011. 43Fein Tr. at 17. 44 Bennett Tr. at 7. 45 Bennett Deposition at 49 (‘‘Q. And there’s no ethics issue associated with Turkish American 

Legal Defense Funds paying for Ms. Schmidt’s legal fees? A. No, not that I’m aware of.’’). See 

below on pages 11–12 for a further discussion of this potential inconsistency. 46 Bennett Tr. at 17. 47Report and Findings In the Matter of Representative Jean Schmidt, OCE Review No. 11– 

6574, May 18, 2011. 48 Id. 49 Id. 50Schmidt Letter to Committee, May 27, 2011. 

First, the defense has raised a material issue as to who(m) 

is paying for the legal fees for Plaintiff Schmidt during the 

pendency of the Ohio Elections Commission [sic]. In an 

earlier deposition, Attorney Bruce Fein said that the Turkish American Legal Defense Fund (‘‘TALDF’’) was paying 

for Schmidt’s legal fees, and Plaintiff Schmidt denied that 

same statement. The issue of who is paying for these fees 

is material in regards to the matter before the Court.41

The Committee was unaware that Mr. Krikorian had opposed 

Mr. Fein’s appearance in the case or of the basis for his objection. 

The Committee learned these facts in the spring of 2011 from news 

reports. 

None of the lawyers associated with TALDF have submitted any 

bills to Representative Schmidt for any of the matters in which 

they represented her.42 This was true even with regard to the five 

months that the lawyers associated with TALDF represented Representative Schmidt before she sought the Committee’s guidance on 

how to pay for their legal services.43 Mr. Bennett told the Committee that before Representative Schmidt initially sought the 

Committee’s guidance in September 2009, she had intended to pay 

for her legal bills using campaign resources once the matter was 

complete.44 While this appears to be potentially inconsistent with 

Mr. Bennett’s deposition testimony in the matter before the Ohio 

Elections Commission,45 he told the Committee that Representative 

Schmidt’s practice in prior matters before the Ohio Elections Commission was to pay legal expenses at the end of the matter using 

campaign funds.46 No written fee agreement had been entered into 

by Representative Schmidt’s campaign for payment of the legal fees 

as of September 2009. 

B. OCE AND COMMITTEE INVESTIGATIONS

OCE commenced its initial review of this matter on January 25, 

2011.47 OCE voted to initiate a second-phase review on February 

22, 2011, and voted to extend the second-phase review on April 23, 

2011.48 OCE voted to refer the matter to the Committee on April 

29, 2011, and transmitted its Report and Findings to the Committee on May 18, 2011.49 Upon receipt of OCE’s Report and Findings, the Committee sent a copy of the Report and Findings to Representative Schmidt and offered her an opportunity to respond. 

Representative Schmidt submitted a response to OCE’s Report and 

Findings on May 27, 2011.50

The Committee conducted an independent investigation into the 

matters in the OCE referral pursuant to House Rule XI, clause 

3(b)(1)(B)(ii), and Committee Rule 18(a), which authorizes the 


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51Fein Tr. at 3. 52 Id. 53Lobbying Disclosure Act filings reflect individuals registered to lobby on behalf of TCA in 

2008, but that registration was terminated as of December 31, 2008. 54Fein Tr. at 6. 55 Id. at 12–13. 56 Id. at 3. 57 Id. 58 Id. 59 Id. 60 Id. at 4. 61 Id. at 14–15. 62 Id. at 9. 63 Id. at 4. 64 Id. at 5. 65 Id. at 8. 66 Id. at 9. 67 Id. 

Chairman and Ranking Member to jointly gather additional information concerning such an alleged violation by a Member, officer, 

or employee unless and until an investigative subcommittee has 

been established. 

The investigations by OCE and the Committee revealed that 

TALDF was first formed around 2007, but it is not an independent 

corporate entity.51 Instead, TALDF is under the umbrella of TCA.52

TCA is an Internal Revenue Code section 501(c)(3) organization, 

which has employed registered federal lobbyists under the Lobbying Disclosure Act in the past.53 Lawyers associated with TALDF 

have represented between six and twelve clients in TALDF-related 

matters since its inception in 2007.54 The lawyers associated with 

TALDF have had retainer agreements with each of these clients, 

except for Representative Schmidt.55

Mr. Fein and Mr. Saltzman are the primary attorneys associated 

with TALDF.56 Occasionally, TALDF will use additional lawyers, if, 

for example, the representation requires local counsel.57 Mr. Fein 

and Mr. Saltzman used local counsel in their work for Representative Schmidt.58 Mr. Fein and Mr. Saltzman are not employees of 

TALDF or TCA, and they do not receive a salary from either entity.59 They each work for their own law firms: Bruce Fein & Associates and Saltzman & Evinch, P.C., respectively.60 This appears to 

be inconsistent with the statement in the reply brief supporting 

Mr. Fein’s admission pro hac vice that Mr. Fein was a ‘‘senior counsel at the Turkish American Legal Defense Fund.’’ 61

Mr. Fein and Mr. Saltzman have never charged the people whom 

they have represented in their TALDF-related matters for their 

legal services.62 Instead, Mr. Fein and Mr. Saltzman send monthly 

bills to TCA for their TALDF-related legal work through their respective law firms.63 This is the standard arrangement for all 

TALDF-related legal work.64 Occasionally, Mr. Fein and Mr. 

Saltzman will enter into what Mr. Fein described as a ‘‘contingency 

fee arrangement’’ with the people whom they have represented in 

their TALDF-related matters.65 Under these agreements, TALDF 

and the individual represented by Mr. Fein and Mr. Saltzman 

agree to split the proceeds of any damage award received as a result of a lawsuit brought by Mr. Fein and Mr. Saltzman.66 Because 

TALDF is not a separate corporate entity, its portion of any award 

would go to TCA.67 In this context, however, the phrase ‘‘contingency fee’’ is a misnomer as Mr. Fein’s and Mr. Saltzman’s receipt 

of their fees is never contingent on the outcome of a matter, but 


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68 Id. 69 Id. at 31. 70Fein Tr. at 17–18; Bennett Tr. at 17. 71See House Comm. on Standards of Official Conduct, In the Matter of the Investigation into 

Officially Connected Travel of House Members to Attend the Carib News Foundation Multinational Business Conferences in 2007 and 2008, H. Rep. 111–422, 111th Cong., 2d Sess. 2 

(2010). 72 Bennett Tr. at 19. 73 Id. at 5. 74 Id. 75 Bennett Deposition at 49 (‘‘Q. And there’s no ethics issue associated with Turkish American 

Legal Defense Funds paying for Ms. Schmidt’s legal fees? A. No, not that I’m aware of.’’). 76 Bennett Tr. at 22. 

would be paid as billed by Mr. Fein and Mr. Saltzman on an ongoing basis, regardless of the result of the action.68 It was this arrangement that Mr. Fein suggested to Representative Schmidt in 

2009,69 and for which Representative Schmidt sought Committee 

approval. The Committee did not understand the nature of the misnamed ‘‘contingency fee’’ arrangement until its interview of Mr. 

Fein following the referral of the matter by OCE. 

Both Representative Schmidt and Mr. Bennett told the Committee that she was never made aware of this payment arrangement with TCA, and Mr. Fein confirmed that he never discussed 

the payment arrangement with Representative Schmidt or any 

member of her staff.70 Thus, the evidence suggests that Representative Schmidt did not have knowledge of the details of TCA’s financial relationship with Mr. Fein and Mr. Saltzman, or the fact that 

the contingency fee proposal did not actually cover the lawyer’s 

fees, at any time prior to the Committee’s discovery of the relationship following the referral of the matter by OCE. The fact of the 

payment arrangement was material to the Committee’s guidance 

on this matter, and if the Committee had given Representative 

Schmidt guidance without being aware of this arrangement, the 

guidance would not have been correct or binding on the Committee.71

Mr. Bennett told the Committee that he never viewed a contingency fee arrangement to be a realistic possibility.72 Instead, Mr. 

Bennett stated that in Representative Schmidt’s prior matters before the Ohio Elections Commission, the ordinary practice had been 

for the law firm representing Representative Schmidt to not provide monthly or quarterly bills, but instead to submit one bill at 

the end of the proceeding.73 Mr. Bennett stated that he had no reason to suspect that the billing arrangement for this matter would 

be any different.74 This appears to be inconsistent with Mr. Bennett’s deposition testimony in the matter before the Ohio Elections 

Commission.75 However, during the Committee’s independent investigation, he explained that he never meant to imply that Representative Schmidt was not planning to pay the lawyers’ fees.76

Instead, Mr. Bennett stated: 

No. I take from [the deposition testimony] that [TALDF] 

were clearly covering costs, like any law firm would cover 

costs. And then you get a bill. You know, every lawyer I 

know gets paid every 2 weeks whether or not his client has 

paid or not. So I take that to mean yes, you know, they 

are covering these costs or whatever, and they are going 

to bill us for them. Now it’s illogical that I could ever think 

that they were going to do this for free . . . [b]ecause it 


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77 Id. 78The legal services provided by the lawyers associated with TALDF were not provided on a pro bono basis, and were not contingent on the outcome of the case. Thus, the Committee does 

not express an opinion on whether the services could be provided on a pro bono basis or under 

a contingency fee agreement, as the underlying facts would not support either arrangement. 79See House Rule 25, clause 5(a)(3)(E). See generally 2008 House Ethics Manual at 63–65. 80LEF Regulations ¶¶1, 11. 

would clearly be either use of House money to furtherance 

[sic] your official capacity, an illegal campaign contribution, or some hybrid of both.77

III. FINDINGS AND CONCLUSIONS 

Following the Committee’s investigation and nearly two years of 

guidance to Representative Jean Schmidt through the Committee’s 

Office of Advice and Education, the Committee reached the following findings and conclusions. 

A. COMMITTEE’S RESPONSE TO REQUESTS FOR GUIDANCE

Based on Representative Schmidt’s statements to the Committee, 

the evidence gathered by OCE, and the Committee’s independent 

investigation, the Committee approved the use of funds from the 

Jean Schmidt Legal Expense Trust to pay legal bills incurred in 

connection with Representative Schmidt’s complaint before the 

Ohio Elections Commission and the defamation action, subject to 

certain restrictions discussed below. However, the Committee denied the use of funds from the Jean Schmidt Legal Expense Trust 

to pay legal bills incurred in connection with amicus briefs filed in 

Krikorian v. Ohio Elections Commission. Additionally, the Committee has determined that Representative Schmidt’s use of campaign funds to pay for the Ohio Elections Commission matter, the 

defamation action, and the amicus briefs filed in the Krikorian v. 

Ohio Elections Commission matter would not violate the House 

rules, subject to the restrictions below. However, the Committee 

advised Representative Schmidt to consult with the Federal Election Commission before using campaign funds for any of these purposes.78 Finally, the Committee denied permission to enter into the 

so-called ‘‘contingency fee’’ arrangement. 

1. Legal Expense Trust Fund 

a. Legal background 

Under a provision of the gift rule, a Member, officer, or employee 

may accept ‘‘a contribution or other payment to a legal expense 

fund established for the benefit of [the official] that is otherwise 

lawfully made in accordance with the restrictions and disclosure requirements of the Committee on Ethics.’’ 79 Under the Committee’s 

Legal Expense Fund Regulations (LEF Regulations), a Member 

may not receive or solicit donations to such a fund without prior 

approval of the trust agreement by the Committee.80

Under the Committee’s LEF Regulations, a fund may be established only when the legal expenses arise in connection with one 

of the following matters: 

• The individual’s candidacy for or election to federal office; 

• The individual’s official duties or position in Congress (including a matter before the Ethics Committee); 

• A criminal prosecution; or 


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81LEF Regulations ¶2. 82LEF Regulations ¶3. 83LEF Regulations ¶11. 84LEF Regulations ¶¶5–6. 85LEF Regulations ¶7. 86LEF Regulations ¶¶8–9. 87LEF Regulations ¶7. 88LEF Regulations ¶11. 89LEF Regulations ¶12. 90LEF Regulations ¶13. 

• A civil matter bearing on the individual’s reputation or fitness for office.81

The Committee will not grant permission to establish a fund 

when legal expenses arise in connection with a matter that is primarily personal in nature, such as a matrimonial action.82 The 

rules governing the operation of a legal expense fund include: • No contribution may be solicited for or accepted by a fund 

prior to the Committee’s written approval of the completed 

trust document and the trustee; 83

• A fund must be established as a trust, administered by a 

trustee who is entirely independent of the Member and has no 

family, business, or employment relationship with the Member; 84

• Trust funds may be used only to pay legal expenses, or the 

expenses incurred in soliciting for or administering the trust; 85

• A fund may not accept more than $5,000 in a calendar 

year from any individual or organization, but, in accordance 

with the gift rule, no contribution may be accepted from a registered lobbyist or foreign agent; 86

• Excess funds must be returned to the contributors; 87 and • A fund may not pay for legal services for anyone other 

than the named beneficiary except with the Committee’s written permission. Written Committee permission is also required 

for any amendment of the trust document and any change in 

the trustee.88

Once a legal expense trust agreement has been approved by the 

Committee, the Member must file an executed copy with the Legislative Resource Center of the Office of the Clerk, for placement on 

the public record.89 In addition, Members must file quarterly reports on the public record regarding certain contributions and expenditures under the LEF Regulations.90

b. Analysis 

The trustee named in the agreement for the Jean Schmidt Legal 

Expense Trust is Mr. Larry Neuman, Esq., of Cincinnati, Ohio. According to Representative Schmidt’s representations to the Committee, Representative Schmidt has no family, business, or employment relationship with Mr. Neuman. Representative Schmidt’s representations to the Committee further indicate that the trust funds 

will be used to pay legal expenses incurred in connection with a 

legal action directly related to Representative Schmidt’s candidacy 

for federal office in 2008 and matters bearing upon her reputation 

and fitness for office. Recital A of the trust agreement indicates 

that the purpose of the Legal Expense Fund is to pay expenses incurred in connection with Representative Schmidt’s official duties 

and position in Congress and matters bearing on her reputation 

and fitness for office. Pursuant to Representative Schmidt’s corVerDate Mar 15 2010 07:18 Aug 10, 2011 Jkt 067754 PO 00000 Frm 00020 Fmt 6659 Sfmt 6602 E:\HR\OC\HR195.XXX HR195

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91See Federal Election Commission, AO 1997–27, at 3 (February 23, 1998). ‘‘For example, to 

the extent that the effect of the charitable deduction would provide more that 100 percent offset 

to the additional taxable income, that part of the deduction may not be taken.’’ 

respondence with the Committee, it is the Committee’s understanding that the specific purpose of the trust is to pay legal expenses that Representative Schmidt incurred by filing a complaint 

with the Ohio Elections Commission regarding false campaign 

statements and her amicus filing in Krikorian v. Ohio Elections 

Commission. 

The Committee therefore approved the use of funds from the 

Jean Schmidt Legal Expense Trust provided by Representative 

Schmidt to pay for the legal expenses incurred in filing the complaint before the Ohio Elections Commission and the appeal of that 

decision in the Ohio state courts. 

The Committee denied the use of funds from the Jean Schmidt 

Legal Expense Trust to pay for legal costs incurred filing amicus 

briefs in the federal court action. At its core, Mr. Krikorian’s legal 

action was a constitutional challenge to a state statute. Mr. 

Krikorian wanted permission to utter any statement regarding any 

opponent in the course of an election campaign because he viewed 

it as political speech. As Representative Schmidt noted in the Complaint in her defamation action, Mr. Krikorian also made controversial statements regarding his opponent during the course of the 

2010 Democratic primary campaign. If Mr. Krikorian’s case had 

survived, the Court would ultimately have decided if the statute 

was constitutional and if it was preempted by federal law. Representative Schmidt’s 2008 election and the statements Mr. 

Krikorian made about her were only relevant in this matter as factual background, and they were not part of the core legal issues to 

be decided. As a result, the legal expenses related to this matter 

were not incurred adjudicating matters in connection with her candidacy for office, her official duties, or her reputation and fitness 

for office, and a legal expense trust may not be used. 

Representative Schmidt’s defamation action is related to her election for office and reputation and fitness as a Member of Congress. 

As a result, Representative Schmidt met the first criterion to use 

a legal expense fund under the LEF Regulations and House Rules. 

There is, however, a challenge to using a legal expense fund to pay 

expenses related to the defamation case in that Representative 

Schmidt is seeking monetary damages in her personal capacity. 

Seeking monetary damages makes it appear as if the suit is personal in nature. The Committee believes this defect can be cured. 

The Committee will approve Representative Schmidt’s use of a 

legal expense fund to pay for expenses related to the defamation 

action under the following conditions: (1) any damages award will 

first be used to defray the cost of litigation; (2) any remaining damages award will be used to repay donors to the Jean Schmidt Legal 

Expense Trust; (3) any additional amount will be donated to a nonprofit organization organized under § 501(c)(3) of the Internal Revenue Code; and (4) Representative Schmidt represents to the Committee in writing that she will receive no direct or indirect financial 

benefit from the lawsuit.91

In accordance with paragraph 12 of the LEF Regulations, Representative Schmidt must file a copy of the executed trust agreement with the Legislative Resource Center (B–106 Cannon House 


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92See Comm. on Standards of Official Conduct, Advisory Opinion No. 6, reprinted in Appendix 

to 2008 House Ethics Manuat at 375, 376. 93 House Select Comm. on Ethics, Final Report, H. Rep. 95–1837, 95th Cong., 2d Sess. 16 

(1979). 94See 2008 House Ethics Manual at 156–57. 

Office Building) within one week of Committee approval. In accordance with LEF Regulation 13, Representative Schmidt (not the 

trustee) is responsible for filing quarterly reports with the Committee regarding certain receipts and expenditures. The original 

version of Representative Schmidt’s quarterly reports must be filed 

with the Committee and a copy must also be filed with the Legislative Resource Center for public disclosure. In addition to the quarterly reports, any contributions of more than $350 in a calendar 

year from a single source (other than a relative) must also be disclosed on Schedule VI of Representative Schmidt’s annual Financial Disclosure Statement. 

2. Campaign Funds 

a. Legal background 

The Committee has long advised Members to consult with the 

Committee prior to using campaign funds for legal expenses to ensure that the legal services are ones that the Member may properly 

pay with campaign funds. House Rule 23, clause 6, provides as follows: 

A Member, Delegate, or Resident Commissioner— 

(a) shall keep the campaign funds of such individual separate from the personal funds of such individual; 

(b) may not convert campaign funds to personal use in excess 

of an amount representing reimbursement for legitimate and 

verifiable campaign expenditures; and 

(c) except as provided in clause 1(b) of rule [24], may not expend funds from a campaign account of such individual that 

are not attributable to bona fide campaign or political purposes. 

While the rule permits the use of campaign funds for ‘‘bona fide 

campaign or political purposes,’’ it does not include a definition of 

that phrase. The Committee has long advised that Members have 

wide discretion to determine whether any particular expenditure 

would serve such purposes, provided that the Member does not convert campaign funds to personal or official uses (other than as permitted by House Rule 24, clause 1(b)).92 Put another way, the rule 

is not interpreted ‘‘to limit the use of campaign funds strictly to a 

Member’s reelection campaign,’’ but instead is interpreted ‘‘broadly 

to encompass the traditional politically-related activities of Members of Congress.’’ 93

In accordance with these principles, the Committee has determined that it is generally permissible under House rules for a 

Member to use campaign funds to pay for the Member’s own legal 

fees which arise in connection with the Member’s campaign, election, or the performance of official duties.94

Pursuant to the Federal Election Campaign Act, the FEC administers a separate set of restrictions on the use of campaign funds. 

Although our understanding is that the FEC generally permits the 

use of campaign funds and the establishment of legal expense 

funds for legal expenses arising out of a Member’s congressional 


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95See Federal Election Commission, AO 1997–27 (February 23, 1998). 96See id. at 3. ‘‘For example, to the extent that the effect of the charitable deduction would 

provide more that 100 percent offset to the additional taxable income, that part of the deduction 

may not be taken.’’ 

campaign and official duties, interpretation of FEC regulations is 

outside this Committee’s jurisdiction. As a result, the Committee 

traditionally encourages all Members to consult with the FEC to 

determine whether use of campaign funds is permissible under the 

applicable law and regulations. 

b. Analysis 

The Ohio Elections Commission matter and Representative 

Schmidt’s defamation action are related to her election for office 

and reputation and fitness as a Member and, as a result, Representative Schmidt met that criterion to use campaign funds 

under the House rules. With respect to the defamation matter, 

however, Representative Schmidt faces the same challenge to using 

campaign funds to pay expenses that she has with the use of a 

legal expense fund in that Representative Schmidt is seeking monetary damages in her personal capacity. Seeking monetary damages makes it appear as if Representative Schmidt would be converting campaign funds for her personal use. 

The Committee notes that in 1998, Representative John Boehner 

sought an opinion from the FEC regarding the use of campaign 

funds to pay for legal expenses incurred in connection with his lawsuit against Representative James McDermott, in which he was 

seeking monetary damages.95 The FEC permitted Representative 

Boehner to pay his legal expenses with campaign funds under the 

following conditions: (1) any damages award first defrayed the cost 

of litigation; (2) any additional amount be donated to charity; and 

(3) Representative Boehner had to represent he would receive no 

direct or indirect financial benefit from the lawsuit.96

The Committee notes that Representative Schmidt may be able 

to reach a similar arrangement with the FEC in this instance. 

Committee staff has been informed by FEC staff that that they do 

not provide the advisory opinion given to Representative Boehner 

to other individuals because it is so fact specific that it should not 

be relied on by anyone other than Representative Boehner. As a result, the Committee strongly urges Representative Schmidt to seek 

an advisory opinion from the FEC before using campaign funds to 

pay legal expenses related to the defamation action. 

With respect to the amicus brief filed in Krikorian v. Ohio Elections Commission, although the Committee does not perceive that 

matter as either pertaining to Representative Schmidt’s candidacy 

for federal office or bearing on her reputation and fitness for office, 

this view may not be shared by the FEC and would not foreclose 

Representative Schmidt’s ability to seek an FEC advisory opinion 

regarding whether one may use campaign funds to pay for legal expenses related to this matter. If Representative Schmidt wanted to 

proceed with using campaign funds to pay for this action, the Committee strongly urges Representative Schmidt to seek an advisory 

opinion from the FEC before doing so. 


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97 It is not necessary for Representative Schmidt to file an actual amended Financial Disclosure Statement. Instead, it would be acceptable for her to submit a letter to the Clerk detailing 

the source, description, and value of the legal services. This is an option available to any filer 

when amending their Financial Disclosure Statement. 98 House Rule 25, cl. 5(a)(1)(A)(i); see also House Rule 23, cl. 4. 99 As a general matter, the amount of any discount on the cost of legal fees offered to a Member based on that individual’s official status would be deemed a gift for purposes of the gift rule. 

See House Rule 25, cl. 5(a)(2)(A). 

B. COMMITTEE’S DISPOSITION OF THE OCE REFERRAL

Based on the evidence examined by the Committee, it appears 

that the arrangement whereby the lawyers associated with TALDF 

sent bills for their legal representation of Representative Schmidt 

to TCA, which TCA then paid, constituted an improper gift from 

TCA to Representative Schmidt. According to OCE’s referral, between 2008 and 2010 TCA actually paid the TALDF lawyers approximately $500,000 for legal services provided to Representative 

Schmidt. Neither the Committee nor, according to the evidence, 

Representative Schmidt was aware of these payments when the 

Committee provided advice to Representative Schmidt regarding 

her options for paying legal fees in the various proceedings. 

Thus, the Committee will not dismiss the allegations in the OCE 

referral. As explained below, however, the Committee does not see 

the need to empanel an investigative subcommittee at this time. 

The Committee does not believe that further fact-gathering is necessary, and, given the evidence that Representative Schmidt did 

not know of the payment arrangement between TCA and the lawyers associated with TALDF, the Committee does not believe that 

any sanction is necessary. 

However, in order to remedy the actual, even if unknown, receipt 

of an impermissible gift, both disclosure and repayment of the gift 

are necessary. Thus, Representative Schmidt must ensure that 

TCA does not pay for any additional future legal services on her 

behalf. In addition, subject to the guidance below, Representative 

Schmidt must pay the lawyers associated with TALDF, from a permissible source, for all legal services they have performed on her 

behalf to date. Furthermore, this remedy will only be sufficient if 

Mr. Fein and Mr. Saltzman and any other attorney who was actually paid with TCA funds, first agree that, as Representative 

Schmidt pays them directly, they will repay to TCA the fees TCA 

originally paid to them for their representation of Representative 

Schmidt. Such an agreement must be in writing and submitted to 

the Committee. Representative Schmidt must also amend her annual Financial Disclosure Statements for calendar years 2009 and 

2010 to disclose the gifts from TCA. Finally, Representative 

Schmidt must disclose any gifts from TCA on her future Financial 

Disclosure Statements, until the lawyers associated with TALDF 

have been repaid in full.97

1. Improper Gift 

As noted above, Members may not accept any gift, except as specifically permitted by House rules.98 The definition of gift expressly 

includes gifts of services, and thus the value of legal services provided to a Member at no cost would be deemed to be a gift under 

the gift rule.99 Each time TCA paid the legal fees of the lawyers 

associated with TALDF in connection with their representation of 

Representative Schmidt, that payment was a gift to her. There is 


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100Fein Tr. at 17–18. 101 Id. at 17. 102 Id. at 31. 103 Bennett Tr. at 17. 104 Id. 105 Id. 

no exception to the gift rule that would permit Representative 

Schmidt to accept this gift, and thus this arrangement was a violation of House Rules. Indeed, even if Representative Schmidt had 

reimbursed TCA the next day for its payment to the lawyers associated with TALDF for their representation of her, TCA’s payments 

would be considered a loan, and thus an improper gift. 

However, the evidence indicates that Representative Schmidt did 

not have knowledge of the specific payment arrangement between 

TCA and the lawyers associated with TALDF. Both Representative 

Schmidt and Mr. Bennett told the Committee that she was never 

made aware of the payment arrangement, and Mr. Fein confirms 

that he never discussed the payment arrangement with Representative Schmidt or any member of her staff.100 Furthermore, the 

Committee has not seen any document suggesting that Representative Schmidt or her staff knew of the payment arrangement. 

The Committee further notes, however, that none of the lawyers 

associated with TALDF submitted any bills to Representative 

Schmidt. This was true even during the five months that the lawyers associated with TALDF represented Representative Schmidt 

before she sought the Committee’s guidance on how to pay for their 

legal services.101 Mr. Fein stated that he has never billed the individuals he represents in TALDF-related matters, and that he always submits those legal bills to TCA. Mr. Fein further stated it 

was his intention not to charge Representative Schmidt for the 

TALDF-related legal services, and that instead, TALDF would accept half of any damages award she received, as part of a ‘‘contingency fee’’ arrangement.102 Mr. Bennett, however, stated that he 

never viewed a contingency fee arrangement to be a realistic possibility.103 Instead, Mr. Bennett stated that in Representative 

Schmidt’s prior matters before the Ohio Elections Commission, the 

practice had been for the law firm representing Representative 

Schmidt to not provide monthly or quarterly bills, and instead to 

submit one bill at the end of the proceeding.104 Mr. Bennett stated 

that he had no reason to suspect that this matter would be any different.105

The Committee is troubled that the lawyers associated with 

TALDF never disclosed their payment arrangement with TCA to 

Representative Schmidt. Such disclosure likely would have made 

this investigation unnecessary. While the Committee believes that 

the payment arrangement between TCA and Representative 

Schmidt’s lawyers should have been disclosed from the beginning 

of their representation of her, the Committee is particularly concerned that Representative Schmidt’s lawyers did not disclose the 

payment arrangement to her even after Mr. Krikorian’s lawyers 

raised the issue of TALDF providing Representative Schmidt free 

legal services, or after the Ohio Court of Common Pleas denied Mr. 

Fein’s motion to be admitted pro hac vice. 

These legal maneuverings should have prompted Representative 

Schmidt’s lawyers to have a fuller discussion with her regarding 

the payment arrangements for their legal services. However, it 


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106 Id. at 14–15. 107The Committee notes that shortly after Mr. Krikorian’s lawyers raised the issue of TALDF 

(not TCA) providing free legal services to Representative Schmidt, she sought the guidance of 

the Committee regarding this issue. 108 2008 House Ethics Manual at 157. 109See House Comm. on Standards of Official Conduct, In the Matter of the Investigation into 

Officially Connected Travel of House Members to Attend the Carib News Foundation Multinational Business Conferences in 2007 and 2008, H. Rep. 111–422, 111th Cong., 2d Sess. 2 

(2010). 

does not appear that Mr. Krikorian’s allegations that TALDF was 

offering free legal services should have put Representative Schmidt 

on notice that her lawyers were not employees of TALDF or TCA 

and were instead outside counsel submitting regular bills to TCA. 

Mr. Krikorian only asserted that Representative Schmidt’s arrangement with her lawyers was improper because her lawyers had 

not yet provided Representative Schmidt with a legal bill. And 

when Mr. Krikorian made this allegation in the depositions of Mr. 

Fein and Mr. Bennett, Representative Schmidt appropriately responded by seeking the guidance of the Committee. Thus, Representative Schmidt was aware that she had not yet received a bill 

because she was working in good faith with the Committee to ascertain the appropriate means by which to pay her attorneys. Further, Mr. Fein and Representative Schmidt’s other lawyers did not 

state that they were not employees of TALDF or TCA and were instead outside counsel submitting regular bills to TCA. Instead, they 

specifically asserted that they were ‘‘senior counsel at the Turkish 

American Legal Defense Fund[.]’’ 106 This statement appears to be 

inconsistent with the fact that Representative Schmidt’s lawyers 

were not employees of TALDF or TCA and were instead outside 

counsel submitting regular bills to TCA. 

The Committee notes that Representative Schmidt never finalized an engagement agreement with the lawyers associated with 

TALDF, including in the five months before she sought the Committee’s guidance.107 Such an agreement may have provided further clarity regarding the relationships between Representative 

Schmidt’s lawyers, TALDF, and TCA. It would have been preferable, in this case, for Representative Schmidt to have (1) entered 

into a written agreement with her lawyers at the beginning of each 

matter; or (2) absent such an agreement, inquired of her lawyers 

about the payment for ongoing legal services. It is for this reason, 

among others, that the Committee strongly encourages all Members to enter into written agreements with lawyers representing 

Members, and for Members to seek the guidance of both the Committee and the FEC before spending campaign funds on legal representation.108

Even if Representative Schmidt did not know that TCA was paying these legal fees on her behalf, the payments still constituted 

gifts to her. The Committee was not aware that TCA was paying 

legal fees on Representative Schmidt’s behalf until it conducted an 

independent investigation following the OCE referral. If the Committee had given Representative Schmidt guidance regarding the 

payment of these legal expenses based on an incorrect understanding of the nature of the fee arrangement, the Committee’s 

guidance would have been invalid and would not have protected 

Representative Schmidt from a charge that she received an improper gift.109


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110 41 CFR § 102–42.10 (2011). 111The Committee notes that Representative Schmidt would also be permitted to pay for any 

of these legal services with her own personal funds. 112Minimal value for purposes of disclosure under EIGA is the same as that for the Foreign 

Gifts and Decorations Act, 5 U.S.C. § 7342(a)(5). Pursuant to that statute, the General Services 

Administration sets the minimal value every three years. Minimal value for calendar years 2008 

until 2011 was $335. See 73 Fed. Reg. 7475 (Feb. 8, 2008). Minimal value for calendar years 

2011 until 2014 is $350. See 76 Fed. Reg. 30551 (May 26, 2011). 

Representative Schmidt and her staff have consistently stated 

that it is her intention to pay the legal fees of the lawyers associated with TALDF.110 The Committee has now given her guidance 

on permissible methods to pay for the TALDF-related legal fees.111

While it was appropriate for Representative Schmidt not to pay the 

legal fees while she was waiting for guidance from the Committee, 

those fees must now be paid. Furthermore, because it is inappropriate for TCA to pay legal fees on Representative Schmidt’s behalf 

and then be reimbursed by her, Representative Schmidt’s payments must be made directly to the lawyers associated with 

TALDF for all fees incurred in their representation of her. 

The Committee recognizes that the lawyers associated with 

TALDF have been representing Representative Schmidt for more 

than two years, in at least three different legal proceedings, and 

the legal fees for this work are substantial. For this reason, the 

Committee does not expect Representative Schmidt to fully pay the 

lawyers associated with TALDF immediately. However, Representative Schmidt must ensure that TCA does not make any further 

payments on her behalf to the lawyers associated with TALDF, and 

Representative Schmidt must begin paying the lawyers associated 

with TALDF as soon as funds are available. Furthermore, this remedy will only be sufficient if Mr. Fein and Mr. Saltzman and any 

other attorney actually paid with TCA funds, first agree to repay 

all TCA funds as they receive Representative Schmidt’s payments. 

Additionally, the Committee notes that it did not approve the use 

of LEF funds for fees related to the amicus brief. Thus, Representative Schmidt must pay for any fees the attorneys billed and TCA 

paid for work on the amicus brief using appropriate funds other 

than the LEF funds. She must pay those fees immediately and provide the Committee with a cancelled check as proof of payment of 

the legal services related to the amicus brief. Until Representative 

Schmidt has paid the lawyers associated with TALDF for all fees 

originally paid by TCA, Representative Schmidt must disclose on 

Schedule V of her annual Financial Disclosure Statement all outstanding TALDF-related fees which were originally paid by TCA. 

2. Disclosure of Improper Gifts 

The Ethics in Government Act (EIGA) requires disclosure of gifts 

received during the year, from someone other than a relative, 

whose aggregate value exceeds ‘‘minimal value,’’ as defined by that 

statute. For 2009 and 2010, ‘‘minimal value’’ was defined as $335, 

but gifts valued below $134 need not be counted towards the 

limit.112 This disclosure is made on Schedule VI of a Member’s annual Financial Disclosure Statement. TCA’s payment of legal services on Representative Schmidt’s behalf was a gift whose aggregate 

value exceeded $335. These payments were not disclosed on Representative Schmidt’s Financial Disclosure Statements covering calendar years 2009 and 2010. Given that Representative Schmidt 


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113See House Rule XI, clauses 3(a)(2) and 3(b). 

was not aware of the gifts, it is not surprising that she did not disclose them. However, now that Representative Schmidt is aware of 

the gifts, she must amend her Financial Disclosure Statements to 

disclose the payments by TCA of legal services on her behalf. 

The Committee directed the Chairman, upon providing the notices required pursuant to House Rule XI, clause 3(b)(8)(A), and 

Committee Rule 17A(b)(2), to file this Report with the House, and 

copies of OCE’s Report and Findings in this matter, along with any 

response filed, all of which are made a part of this Report and appended hereto.113 The filing of this Report, along with its publication on the Committee’s Web site, shall serve as publication of 

OCE’s Report and Findings in this matter, pursuant to House Rule 

XI, clause 3(b)(8)(A), and Committee Rule 17A(b)(3) and 17A(c)(2). 

IV. STATEMENT UNDER RULE 13, CLAUSE 3(c) OF THE 

RULES OF THE HOUSE OF REPRESENTATIVES 

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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jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 35 here HR195.009
30 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 36 here HR195.010
31 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 37 here HR195.011
32 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 38 here HR195.012
33 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 39 here HR195.013
34 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 40 here HR195.014
35 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 41 here HR195.015
36 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 42 here HR195.016
37 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 43 here HR195.017
38 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 44 here HR195.018
39 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 45 here HR195.019
40 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 46 here HR195.020
41 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 47 here HR195.021
42 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 48 here HR195.022
43 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 49 here HR195.023
44 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 50 here HR195.024
45 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 51 here HR195.025
46 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 52 here HR195.026
47 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 53 here HR195.027
48 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 54 here HR195.028
49 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 55 here HR195.029
50 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 56 here HR195.030
51 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 57 here HR195.031
52 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 58 here HR195.032
53 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 59 here HR195.033
54 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 60 here HR195.034
55 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 61 here HR195.035
56 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 62 here HR195.036
57 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 63 here HR195.037
58 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 64 here HR195.038
59 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 65 here HR195.039
60 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 66 here HR195.040
61 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 67 here HR195.041
62 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 68 here HR195.042
63 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 69 here HR195.043
64 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 70 here HR195.044
65 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 71 here HR195.045
66 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 72 here HR195.046
67 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 73 here HR195.047
68 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 74 here HR195.048
69 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 75 here HR195.049
70 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 76 here HR195.050
71 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 77 here HR195.051
72 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 78 here HR195.052
73 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 79 here HR195.053
74 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 80 here HR195.054
75 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 81 here HR195.055
76 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 82 here HR195.056
77 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 83 here HR195.057
78 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 84 here HR195.058
79 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 85 here HR195.059
80 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 86 here HR195.060
81 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 87 here HR195.061
82 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 88 here HR195.062
83 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 89 here HR195.063
84 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 90 here HR195.064
85 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 91 here HR195.065
86 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 92 here HR195.066
87 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 93 here HR195.067
88 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 94 here HR195.068
89 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 95 here HR195.069
90 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 96 here HR195.070
91 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 97 here HR195.071
92 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 98 here HR195.072
93 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 99 here HR195.073
94 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 100 here HR195.074
95 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 101 here HR195.075
96 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 102 here HR195.076
97 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 103 here HR195.077
98 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 104 here HR195.078
99 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 105 here HR195.079
100 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 106 here HR195.080
101 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 107 here HR195.081
102 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 108 here HR195.082
103 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 109 here HR195.083
104 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 110 here HR195.084
105 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 111 here HR195.085
106 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 112 here HR195.086
107 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 113 here HR195.087
108 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 114 here HR195.088
109 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 115 here HR195.089
110 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 116 here HR195.090
111 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 117 here HR195.091
112 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 118 here HR195.092
113 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 119 here HR195.093
114 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 120 here HR195.094
115 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 121 here HR195.095
116 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 122 here HR195.096
117 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 123 here HR195.097
118 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 124 here HR195.098
119 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 125 here HR195.099
120 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 126 here HR195.100
121 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 127 here HR195.101
122 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 128 here HR195.102
123 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 129 here HR195.103
124 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 130 here HR195.104
125 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 131 here HR195.105
126 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 132 here HR195.106
127 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 133 here HR195.107
128 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 134 here HR195.108
129 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 135 here HR195.109
130 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 136 here HR195.110
131 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 137 here HR195.111
132 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 138 here HR195.112
133 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 139 here HR195.113
134 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 140 here HR195.114
135 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 141 here HR195.115
136 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 142 here HR195.116
137 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 143 here HR195.117
138 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 144 here HR195.118
139 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 145 here HR195.119
140 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 146 here HR195.120
141 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 147 here HR195.121
142 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 148 here HR195.122
143 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 149 here HR195.123
144 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 150 here HR195.124
145 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 151 here HR195.125
146 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 152 here HR195.126
147 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 153 here HR195.127
148 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 154 here HR195.128
149 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 155 here HR195.129
150 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 156 here HR195.130
151 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 157 here HR195.131
152 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 158 here HR195.132
153 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 159 here HR195.133
154 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 160 here HR195.134
155 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 161 here HR195.135
156 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 162 here HR195.136
157 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 163 here HR195.137
158 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 164 here HR195.138
159 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 165 here HR195.139
160 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 166 here HR195.140
161 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 167 here HR195.141
162 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 168 here HR195.142
163 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 169 here HR195.143
164 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 170 here HR195.144
165 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 171 here HR195.145
166 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 172 here HR195.146
167 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 173 here HR195.147
168 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 174 here HR195.148
169 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 175 here HR195.149
170 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 176 here HR195.150
171 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 177 here HR195.151
172 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 178 here HR195.152
173 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 179 here HR195.153
174 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 180 here HR195.154
175 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 181 here HR195.155
176 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 182 here HR195.156
177 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 183 here HR195.157
178 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 184 here HR195.158
179 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 185 here HR195.159
180 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 186 here HR195.160
181 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 187 here HR195.161
182 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 188 here HR195.162
183 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 189 here HR195.163
184 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 190 here HR195.164
185 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 191 here HR195.165
186 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 192 here HR195.166
187 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 193 here HR195.167
188 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 194 here HR195.168
189 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 195 here HR195.169
190 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 196 here HR195.170
191 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 197 here HR195.171
192 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 198 here HR195.172
193 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 199 here HR195.173
194 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 200 here HR195.174
195 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 201 here HR195.175
196 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 202 here HR195.176
197 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 203 here HR195.177
198 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 204 here HR195.178
199 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 205 here HR195.179
200 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 206 here HR195.180
201 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 207 here HR195.181
202 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 208 here HR195.182
203 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 209 here HR195.183
204 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 210 here HR195.184
205 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 211 here HR195.185
206 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 212 here HR195.186
207 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 213 here HR195.187
208 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 214 here HR195.188
209 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 215 here HR195.189
210 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 216 here HR195.190
211 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 217 here HR195.191
212 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 218 here HR195.192
213 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 219 here HR195.193
214 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 220 here HR195.194
215 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 221 here HR195.195
216 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 222 here HR195.196
217 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 223 here HR195.197
218 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 224 here HR195.198
219 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 225 here HR195.199
220 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 226 here HR195.200
221 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 227 here HR195.201
222 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 228 here HR195.202
223 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 229 here HR195.203
224 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 230 here HR195.204
225 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 231 here HR195.205
226 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 232 here HR195.206
227 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 233 here HR195.207
228 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 234 here HR195.208
229 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 235 here HR195.209
230 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 236 here HR195.210
231 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 237 here HR195.211
232 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 238 here HR195.212
233 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 239 here HR195.213
234 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 240 here HR195.214
235 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 241 here HR195.215
236 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 242 here HR195.216
237 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 243 here HR195.217
238 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 244 here HR195.218
239 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 245 here HR195.219
240 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 246 here HR195.220
241 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 247 here HR195.221
242 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 248 here HR195.222
243 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 249 here HR195.223
244 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 250 here HR195.224
245 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 251 here HR195.225
246 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 252 here HR195.226
247 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 253 here HR195.227
248 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 254 here HR195.228
249 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 255 here HR195.229
250 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 256 here HR195.230
251 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 257 here HR195.231
252 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 258 here HR195.232
253 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 259 here HR195.233
254 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 260 here HR195.234
255 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 261 here HR195.235
256 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 262 here HR195.236
257 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 263 here HR195.237
258 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 264 here HR195.238
259 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 265 here HR195.239
260 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 266 here HR195.240
261 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 267 here HR195.241
262 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 269 here HR195.243
263 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 268 here HR195.242
264 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 270 here HR195.244
265 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 271 here HR195.245
266 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 272 here HR195.246
267 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 273 here HR195.247
268 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 274 here HR195.248
269 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 275 here HR195.249
270 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 276 here HR195.250
271 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 277 here HR195.251
272 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 278 here HR195.252
273 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 279 here HR195.253
274 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 280 here HR195.254
275 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 281 here HR195.255
276 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 282 here HR195.256
277 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 283 here HR195.257
278 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 284 here HR195.258
279 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 285 here HR195.259
280 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 286 here HR195.260
281 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 287 here HR195.261
282 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 288 here HR195.262
283 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 289 here HR195.263
284 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 290 here HR195.264
285 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 291 here HR195.265
286 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 292 here HR195.266
287 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 293 here HR195.267
288 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 294 here HR195.268
289 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 295 here HR195.269
290 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 296 here HR195.270
291 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 297 here HR195.271
292 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 298 here HR195.272
293 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 299 here HR195.273
294 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 300 here HR195.274
295 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 301 here HR195.275
296 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 302 here HR195.276
297 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 303 here HR195.277
298 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 304 here HR195.278
299 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 305 here HR195.279
300 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 306 here HR195.280
301 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 307 here HR195.281
302 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 308 here HR195.282
303 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 309 here HR195.283
304 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 310 here HR195.284
305 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 311 here HR195.285
306 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 312 here HR195.286
307 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 313 here HR195.287
308 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 314 here HR195.288
309 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 315 here HR195.289
310 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 316 here HR195.290
311 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 317 here HR195.291
312 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 318 here HR195.292
313 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 319 here HR195.293
314 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 320 here HR195.294
315 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 321 here HR195.295
316 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 322 here HR195.296
317 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 323 here HR195.297
318 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 324 here HR195.298
319 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 325 here HR195.299
320 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 326 here HR195.300
321 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 327 here HR195.301
322 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 328 here HR195.302
323 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 329 here HR195.303
324 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 330 here HR195.304
325 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 331 here HR195.305
326 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 332 here HR195.306
327 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 333 here HR195.307
328 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 334 here HR195.308
329 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 335 here HR195.309
330 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 336 here HR195.310
331 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 337 here HR195.311
332 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 338 here HR195.312
333 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 339 here HR195.313
334 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 340 here HR195.314
335 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 341 here HR195.315
336 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 342 here HR195.316
337 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 343 here HR195.317
338 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 344 here HR195.318
339 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 345 here HR195.319
340 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 346 here HR195.320
341 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 347 here HR195.321
342 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 348 here HR195.322
343 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 349 here HR195.323
344 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 350 here HR195.324
345 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 351 here HR195.325
346 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 352 here HR195.326
347 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 353 here HR195.327
348 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 354 here HR195.328
349 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 355 here HR195.329
350 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 356 here HR195.330
351 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 357 here HR195.331
352 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 358 here HR195.332
353 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 359 here HR195.333
354 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 360 here HR195.334
355 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 361 here HR195.335
356 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 362 here HR195.336
357 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 363 here HR195.337
358 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 364 here HR195.338
359 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 365 here HR195.339
360 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 366 here HR195.340
361 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 367 here HR195.341
362 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 368 here HR195.342
363 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 369 here HR195.343
364 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 370 here HR195.344
365 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 371 here HR195.345
366 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 372 here HR195.346
367 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 373 here HR195.347
368 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 374 here HR195.348
369 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 375 here HR195.349
370 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 376 here HR195.350
371 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 377 here HR195.351
372 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 378 here HR195.352
373 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 379 here HR195.353
374 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 380 here HR195.354
375 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 381 here HR195.355
376 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 382 here HR195.356
377 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 383 here HR195.357
378 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 384 here HR195.358
379 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 385 here HR195.359
380 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 386 here HR195.360
381 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 387 here HR195.361
382 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 388 here HR195.362
383 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 389 here HR195.363
384 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 390 here HR195.364
385 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 391 here HR195.365
386 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 392 here HR195.366
387 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 393 here HR195.367
388 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 394 here HR195.368
389 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 395 here HR195.369
390 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 396 here HR195.370
391 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 397 here HR195.371
392 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 398 here HR195.372
393 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 399 here HR195.373
394 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 400 here HR195.374
395 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 401 here HR195.375
396 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 402 here HR195.376
397 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 403 here HR195.377
398 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 404 here HR195.378
399 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 405 here HR195.379
400 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 406 here HR195.380
401 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 407 here HR195.381
402 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 408 here HR195.382
403 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 409 here HR195.383
404 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 410 here HR195.384
405 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 411 here HR195.385
406 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 412 here HR195.386
407 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 413 here HR195.387
408 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 414 here HR195.388
409 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 415 here HR195.389
410 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 416 here HR195.390
411 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 417 here HR195.391
412 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 418 here HR195.392
413 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 419 here HR195.393
414 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 420 here HR195.394
415 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 421 here HR195.395
416 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 422 here HR195.396
417 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 423 here HR195.397
418 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 424 here HR195.398
419 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 425 here HR195.399
420 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 426 here HR195.400
421 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 427 here HR195.401
422 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 428 here HR195.402
423 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 429 here HR195.403
424 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 430 here HR195.404
425 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 431 here HR195.405
426 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 432 here HR195.406
427 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 433 here HR195.407
428 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 434 here HR195.408
429 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 435 here HR195.409
430 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 436 here HR195.410
431 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 437 here HR195.411
432 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 438 here HR195.412
433 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 439 here HR195.413
434 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 440 here HR195.414
435 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 441 here HR195.415
436 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 442 here HR195.416
437 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 443 here HR195.417
438 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 444 here HR195.418
439 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 445 here HR195.419
440 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 446 here HR195.420
441 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 447 here HR195.421
442 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 448 here HR195.422
443 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 449 here HR195.423
444 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 450 here HR195.424
445 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 451 here HR195.425
446 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 452 here HR195.426
447 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 453 here HR195.427
448 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 454 here HR195.428
449 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 455 here HR195.429
450 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 456 here HR195.430
451 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 457 here HR195.431
452 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 458 here HR195.432
453 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 459 here HR195.433
454 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 460 here HR195.434
455 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 461 here HR195.435
456 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 462 here HR195.436
457 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 463 here HR195.437
458 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 464 here HR195.438
459 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 465 here HR195.439
460 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 466 here HR195.440
461 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 467 here HR195.441
462 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 468 here HR195.442
463 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 469 here HR195.443
464 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 470 here HR195.444
465 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 471 here HR195.445
466 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 472 here HR195.446
467 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 473 here HR195.447
468 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 474 here HR195.448
469 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 475 here HR195.449
470 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 476 here HR195.450
471 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 477 here HR195.451
472 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 478 here HR195.452
473 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 479 here HR195.453
474 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 480 here HR195.454
475 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 481 here HR195.455
476 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 482 here HR195.456
477 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 483 here HR195.457
478 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 484 here HR195.458
479 


jbell on DSKDVH8Z91PROD with REPORTSInsert offset folio 485 here HR195.459