" ! HOUSE OF REPRESENTATIVES 

111TH CONGRESS

1st Session 

REVIEW NO. 

09–2222 

OFFICE OF CONGRESSIONAL ETHICS 

UNITED STATES HOUSE OF 

REPRESENTATIVES 

————— 

Report and Findings 

Transmitted to the 

Committee on Standards of Official Conduct 

on June 8, 2009 

and released publicly pursuant to H. Res. 895 of the 

110th Congress as amended 

June 2009 


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House of Representatives Office of Congressional Ethics Review No. 09–2222 


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U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON : 

1 

54–329 

" ! HOUSE OF REPRESENTATIVES 

111TH CONGRESS

1st Session 

REVIEW NO. 

2009

09–2222 

OFFICE OF CONGRESSIONAL ETHICS 

UNITED STATES HOUSE OF 

REPRESENTATIVES 

————— 

Report and Findings 

Transmitted to the 

Committee on Standards of Official Conduct 

on June 8, 2009 

and released publicly pursuant to H. Res. 895 of the 

110th Congress as amended 

June 2009 


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(II) 

OFFICE OF 

CONGRESSIONAL ETHICS 

BOARD 

UNITED STATES HOUSE OF REPRESENTATIVES

ONE HUNDRED ELEVENTH CONGRESS

DAVID SKAGGS, Chair 

PORTER GOSS, Co-Chair 

YVONNE BURKE 

KAREN ENGLISH 

ALLISON HAYWARD 

JAY EAGEN 

WILLIAM FRENZEL 

ABNER MIKVA 

Leo J. Wise, Chief Counsel & Staff Director 

Elizabeth Horton, Investigative Counsel 

Omar Ashmawy, Investigative Counsel 


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REPORT 

Review No. 09–2222 

The Board of the Office of Congressional Ethics, by a vote of no 

less than four members, on May 29, 2009, adopted the following report and ordered it to be transmitted to the Committee on Standards of Official Conduct of the U.S. House of Representatives. 

SUBJECT: Representative Bennie Thompson 

NATURE OF THE ALLEGED VIOLATION: There is substantial 

reason to believe that Congressman Bennie Thompson’s participation in the 13th Annual Caribbean Multi-National Business Conference in St. Maarten, N.A. from November 6–9, 2008, his acceptance of reimbursement of expenses to attend that conference and 

the Member Post Travel Disclosure Form he filed violated various 

provisions of House Rule XXV Section 5(b). 

RECOMMENDATION: The Board of the Office of Congressional 

Ethics recommends that the Committee on Standards of Official 

Conduct further review the above described allegations concerning 

Congressman Thompson. 

VOTES IN THE AFFIRMATIVE: 6 

VOTES IN THE NEGATIVE: 0 

MEMBER OF THE BOARD OR STAFF DESIGNATED TO 

PRESENT THIS REPORT TO THE STANDARDS COMMITTEE: 

Leo Wise, Staff Director & Chief Counsel. 


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TABLE OF CONTENTS 

I. INTRODUCTON ............................................................................................ 5 

A. Summary of Allegations ................................................................... 5 

C. Jurisdictional Statement .................................................................. 7 

D. Procedural History ............................................................................ 7 

II. MULTIPLE ENTITIES, INCLUDING CARIB NEWS (THE NEWSPAPER), THE GOVERNMENT OF ST. MAARTEN AND SEVERAL 

CORPORATIONS, SPONSORED REPRESENTATIVE THOMPSON 

TRIP ............................................................................................................ 8 

A. Representative Thompson’s Knowledge of The Involvement of 

These Corporations in the Conference .......................................... 9 

B. CARIB NEWS also Sponsored Congressman Thompson’s Travel 13 

C. Corporate Donations Were Earmarked for the Conference ........... 13 

D. Because Entities that Employ or Retain Lobbyists Sponsored 

the Event, Congressman Thompson’s Involvement Should Have 

Been Limited to One Day .............................................................. 17 

E. The Government of St. Maarten Made In-Kind Donations to 

the 2008 Conference and Played a Significant Role in Planning, Organizing and Conducting the 2008 Conference .............. 18 

III. ROLE OF THE CHAIR’S COUNSEL IN THE APPROVAL OF THE 

12TH ANNUAL CARIBBEAN MULTI-NATIONAL BUSINESS CONFERENCE IN 2007 .................................................................................... 20 

IV. THE VALUE OF THE TRIP REPORTED ON THE MEMBER’S POSTTRAVEL DISCLOSURE FORM ................................................................ 36 

A. Representations from Carib News Foundation .............................. 37 

B. Information Required from the Congressional Traveler ................ 38 

V. CARIB NEWS FOUNDATION, AS A PRIVATE FOUNDATION, WAS 

PROHIBITED FROM PAYING FOR CONGRESSMAN THOMPSON’S 

TRAVEL ...................................................................................................... 39 


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FINDINGS OF FACT AND CITATIONS TO LAW 

Review No. 09–2222 

On May 29, 2009 the Board of the Office of Congressional Ethics 

(hereafter the ‘‘Board’’) adopted the following findings of fact and 

accompanying citations to law, regulations, rules and standards of 

conduct (in italics). The Board notes that these findings do not constitute a determination of whether or not a violation actually occurred. 

I. INTRODUCTON 

1. Congressman Bennie Thompson attended the 13th Annual 

Caribbean Multi-National Business Conference in St. Maarten, 

N.A., from November 6–9, 2008. Congressman Thompson received 

funds from a private source to participate in the conference. 

A. SUMMARY OF ALLEGATIONS

2. There is substantial reason to believe that Congressman 

Thompson violated the requirement that he identify the ‘‘true, correct and accurate’’ sponsor of his travel ‘‘to the best of his knowledge’’ on his Member Post Travel Disclosure Form. While forms 

submitted to his office and the Standards Committee before the 

conference identified one entity as the sponsor—the Carib News 

Foundation—once at the conference, Congressman Thompson was 

presented with indications that other corporations—including 

Citigroup, IBM, AT&T, Pfizer, Macy’s and Verizon Foundation— 

were also sponsors. Those indications proved to be true—the corporations were in fact sponsors of Congressman Thompson’s travel 

according to House travel rules because the corporations had donated funds specifically for the conference (i.e. earmarked funds). 

Further, events that occurred in 2007 affected the Standards Committee’s ability to determine whether these corporations were sponsors in 2008: 

a. In 2007, the House of Representatives changed the rules 

governing travel. Those changes placed limitations on the number of days Members of Congress could participate in events 

(such as conferences) when their travel was sponsored by an 

entity that employs or retains a lobbyist. These changes affected the annual Caribbean Multi-National Business Conference. In 2007, the Carib News Foundation continued to 

identify various corporations as sponsors on the conference 

agenda and on a draft version of the Private Sponsor Travel 

Certification Form prepared for submission to the Standards 

Committee for approval. However, after interacting with the 

counsel to the then-Chair of the Standards Committee, and apparently without the knowledge of the staff attorney reviewing 


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the trip, the documents identifying these corporations as ‘‘sponsors’’ were changed and their sponsorship was not disclosed. 

b. The 2007 conduct and attendant misrepresentations appear to have directly influenced what occurred in 2008. When 

the Carib News Foundation submitted materials to the Standards Committee for their approval of the 2008 conference, the 

Carib News Foundation took the same approach as in 2007 

and did not disclose the role of the corporate sponsors on the 

forms they submitted to the Standards Committee. 

3. There is substantial reason to believe that Congressman 

Thompson violated House Rule 25, clause 5(b)(1)(C) by accepting 

trip-related reimbursements from entities that employ or retain 

lobbyists for participating in an event for more than one day. 

4. There is substantial reason to believe that Congressman 

Thompson violated House Rule 25 clause 5(h)(i)(1)(B) by underreporting the value of the travel reimbursements he received to attend the 13th Annual Caribbean Multi-National Business Conference. 

5. There is substantial reason to believe that the Carib News 

Foundation’s payment of travel expenses for Representative 

Thompson and his acceptance of payment violated the Internal 

Revenue Code. As stated above, Carib News Charities, the name 

previously held by the 501(c) organization now known as the Carib 

News Foundation, is listed as a private foundation in the Internal 

Revenue’s cumulative list of charitable organizations, Publication 

78. Therefore, the Standards Committee should not have approved 

the trip because the funds came from a prohibited source. 

B. A NOTE ON CULPABILITY

6. These findings fall into four categories: (1) the sponsor or 

sponsors, as the case appears to be, of the conference; (2) the intervention of the counsel to the former Chair of the Standards Committee in the Standards Committee’s review process of the conference in 2007 and how it affected the information before the 

Standards Committee in 2008; (3) the accuracy of the value of the 

reimbursement submitted by Congressman Thompson and (4) 

whether, because of its tax status, the Carib News Foundation 

could lawfully pay for Congressman Thompson’s conference-related 

expenses. 

7. While all these topics are relevant, the Board notes that they 

do not all involve conduct by Congress Thompson to the same degree. 

a. As to topic 1, determining the identity of the true sponsor 

or sponsors implicates the conduct of both Congressman 

Thompson and the Standards Committee. Congressman 

Thompson told the OCE he relied on the Standards Committee 

to make that determination. It is the Board’s view that the 

Member’s approach is reasonable to a point. Once Congressman Thompson arrived at the conference, however, he was confronted with information that other corporations were co-sponsors. That information, at least in 2008, does not appear to 

have been before the Standards Committee when they initially 

approved the 2008 travel. 


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1 House Resolution 895 of the 110th Congress, Section 1(e). 

2 A preliminary review is ‘‘requested’’ in writing by members of the Board of the OCE. The 

request for a preliminary review is ‘‘received’’ by the OCE on a date certain. According to H. 

Res. 895 of the 110th Congress (hereafter ‘‘the Resolution’’), the timeframe for conducting a preliminary review is 30 days from the date of receipt of the Board’s request. 3 According to the Resolution, the Board must vote on whether to conduct a second-phase review in a matter before the expiration of the 30-day preliminary review. If the Board votes for 

Continued 

b. As to topic 2, the intervention of the counsel to the former 

Chair of the Standards Committee in the Standards Committee’s review of the 2007 conference did not involve Congressman Thompson. Nonetheless, it directly bears on whether and 

to what extent the Standards Committee could determine the 

true sponsor of the conference in 2008. 

c. As to topic 3, the accuracy of the information Congressman 

Thompson provided as to the value of the reimbursement of his 

conference-related expenses most directly implicates his conduct. The post-travel disclosure form that all Members must 

file when they accept privately sponsored travel is signed and 

certified by Members. The form puts the obligation on Members, not staff ‘‘true, accurate and complete’’ to the ‘‘best of the 

Member’s knowledge.’’ Congressman Thompson saw the value 

of his travel and retained copies of documents that showed its 

true value in his office files. Nonetheless, he certified inaccurate information on the post-travel disclosure form. 

d. As to topic 4, limitations on Carib News Foundation’s ability to pay for overseas travel of government officials, Congressman Thompson told the OCE he was unaware of any such limitations. The Board finds this statement to be credible. Nonetheless, the law prohibits such payments. Therefore, the Board 

feels compelled to include a discussion of this issue in this referral. 

C. JURISDICTIONAL STATEMENT

8. The allegations that are the subject of this review concern 

Representative Bennie Thompson, a Member of the United States 

House of Representatives from the 2nd District of Mississippi. The 

Resolution the United States House of Representatives adopted creating the Office of Congressional Ethics directs that, ‘‘[n]o review 

shall be undertaken . . . by the board of any alleged violation that 

occurred before the date of adoption of this resolution.’’ 1 The House 

adopted this Resolution on March 11, 2008. Because the conduct 

under review occurred or relates to actions taken after March 11, 

2008, review by the Office of Congressional Ethics is in accordance 

with the Resolution. 

D. PROCEDURAL HISTORY

9. The OCE received a written request for a preliminary review 

in this matter signed by at least two members of the Board on 

March 6, 2009. The preliminary review commenced on this date.2

The preliminary review was scheduled to end on April 5, 2009. 

10. At least three members of the Board voted to initiate a second-phase review in this matter on March 27, 2009. The secondphase review commenced on April 6, 2009.3 The second-phase review was scheduled to end on May 21, 2009. 


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a second-phase, the second-phase begins when the preliminary review ends. The second-phase 

review does not begin on the date of the Board vote. 4 House Rule 25(5)(h)(i)(1)(B) directs the Standards Committee to establish, ‘‘regulations describing the information it will require individuals subject to this clause to submit to the committee in order to obtain the prior approval of the committee for any travel covered by this 

clause . . .’’ On February 20, 2007, the Committee issued guidelines and regulations concerning 

the travel restrictions and requirements. 

11. The Board voted to extend the 45-day second-phase review by 

an additional 14 days, as provided for under the Resolution, on 

April 24, 2009. Following the extension, the second-phase review 

was scheduled to end on June 5, 2009. 

12. The second-phase review ended on May 26, 2009. 

13. The Board voted to refer the matter to the Standards Committee for further review on May 29, 2009. 

14. The OCE requested documents from and interviews with representatives of: 

(1) Representative Sheila Jackson-Lee’s Congressional office; 

(2) the Verizon Foundation; 

(3) Citibank; 

(4) American Airlines; 

(5) IBM; 

(6) Macy’s, Inc; 

(7) Pfizer; 

(8) AT&T; 

(9) Representative Kilpatrick’s Congressional office; 

(10) Representative Payne’s Congressional office; 

(11) Representative Rangel’s Congressional office; 

(12) Representative Thompson’s Congressional office; 

(13) Delegate Christensen’s Congressional office; 

(14) The Carib News; and 

(15) The Carib News Foundation 

II. MULTIPLE ENTITIES, INCLUDING CARIB NEWS (THE NEWSPAPER), THE GOVERNMENT OF ST. MAARTEN AND SEVERAL CORPORATIONS, SPONSORED REPRESENTATIVE THOMPSON TRIP

15. Under House Rule 25 clause 5(d), Members are required to obtain prior approval of the Standards Committee for trips where the 

Member’s travel expenses will be reimbursed by a private source. 

The Standards Committee has adopted regulations, pursuant to 

House Rule 25 clause 5(h)(i)(1)(B) 4 that requires Members to identify the ‘‘sponsor(s),’’ i.e. the party reimbursing travel expenses, for 

any trip where the payor is a private entity. 

16. There is substantial reason to believe that Congressman 

Thompson violated the requirement that he identify the ‘‘true, correct and accurate’’ sponsor of his travel ‘‘to the best of his knowledge’’ on his Member Post Travel Disclosure Form. While forms 

submitted to his and the Standards Committee before the conference identified one sponsor—the Carib News Foundation—once 

at the conference, Congressman Thompson was presented with evidence that other corporations were also sponsors. As will be discussed below, those indications proved to be true—these corporations were in fact sponsors of Congressman Thompson’s travel according to House travel rules because these corporations had donated funds specifically for the conference (i.e. earmarked funds). 


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5The ‘‘Member/Officer Post-Travel Disclosure Form’’ asks the filer at question 5, ‘‘Sponsor(s) 

(who paid for the trip).’’ This in turn raises the question is a conference a ‘‘trip’’ or is a trip 

limited to the travel expenses associated with attending the trip, e.g., transportation, lodging 

and meal expenses? The House Ethics manual and the relevant forms use the terms ‘‘travel’’ 

and ‘‘trip’’ interchangeably. For example, the relevant form is called a Member/Officer PostTravel Disclosure Form’’ (emphasis added). The introductory paragraph on the form provides, 

‘‘[t]his form is for disclosing the receipt of travel expenses from a private source for meetings, 

speaking engagements, fact-finding trips or similar events in connection with official duties’’ 

(emphasis added). However, question 9 on the form asks the filer to detail, ‘‘TRIP EXPENSES’’ 

and uses as an example, ‘‘registration fees.’’ Registration fees are not ‘‘travel’’ expenses unless 

one defines travel (or a trip) to include participating in a conference. The Board uses the term 

‘‘trip’’ to include the conference. The Board also notes that the Standards Committee treated 

the conference as the ‘‘trip’’ in its letter pre-approving Congressman Thompson’s trip. 6Member/Officer Post-Travel Disclosure Form signed by Representative Bennie G. Thompson 

(Dec. 5, 2008) (Exhibit 1 at 09–2222—2). 7 Id. at 09–2222—3. 

A. REPRESENTATIVE THOMPSON’S KNOWLEDGE OF THE INVOLVEMENT

OF THESE CORPORATIONS IN THE CONFERENCE

17. On his Member Post-Travel Disclosure Form, Congressman 

Thompson listed Carib News Foundation as the only sponsor of the 

13th Annual Caribbean Multi-National Business Conference in St. 

Maarten, N.A. (hereafter ‘‘the trip’’ or ‘‘conference’’ 5) in December 

2008.6

18. Congressman Thompson certified that this information was 

‘‘true, correct and complete’’ to the ‘‘best of [his] knowledge.’’ 7


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8Memorandum of Interview of Representative Bennie Thompson (May 6, 2009) (Exhibit 2 at 

09–2222—27). 9Private Sponsor Travel Certification Form signed by Karl A. Rodney (Oct. 3, 2008) (Exhibit 

1 at 09–2222—8). 10 Id. 11 Id. at 09–2222—10. 

19. In an interview with the OCE, Congressman Thompson confirmed he signed this document.8

20. Prior to the conference, Karl Rodney, the CEO of the Carib 

News Foundation, submitted a Private Sponsor Travel Certification 

Form to Congressman Thompson, which he in turn submitted to 

the Standards Committee that identified the Carib News Foundation as the sponsor of the trip.9

21. Later, on that same form, Mr. Rodney represented that ‘‘the 

trip sponsor(s) [had] not accepted from any other source funds earmarked directly or indirectly to finance any aspect of the trip.’’ 10

22. Rodney also certified that the information was ‘‘true, complete, and correct.’’ 11


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12Letter from the Committee on Standards of Official Conduct to Representative Bennie G. 

Thompson (Oct. 20, 2008) (Exhibit 1 at 09–2222—4). 13Photographs taken at the 13th Annual Caribbean Multi-National Business Conference (Exhibit 5 at 09–2222—62–70) (The Board notes that the source of this information may have a 

bias, interest, or motive in this matter.). 14Transcript of Recording of November 7, 2008 AM Session of the 13th Annual Caribbean 

Multi-National Business Conference (Exhibit 3 at 09–2222—30–32) (The Board notes that the 

source of this information may have a bias, interest, or motive in this matter.). 15 Id. at 09–2222—30. 16 Id. at 09–2222—32. 17 Id. at 09–2222—47. 

23. Prior to the conference, the Standards Committee approved 

the reimbursement of Congressman Thompson’s expenses by the 

Carib News Foundation.12

24. At the conference, several corporations, including Citibank, 

IBM, AT&T, and others, were identified as ‘‘sponsors.’’ 13

25. On November 7, 2008, the conference’s organizer, Karl Rodney, began the first morning program by thanking Citigroup, 

Pfizer, Macy’s, IBM, AT&T, the Verizon Foundation and American 

Airlines, as well as their executives by name, who were present.14

This morning session was recorded by an individual attending the 

conference and the recording was subsequently transcribed. The 

OCE obtained a copy of the transcript. Mr. Rodney described AT&T 

as ‘‘support[ing] the Conference all 13 years’’ (this was the thirteenth annual conference).15

26. Michael Flanigan, an executive from Citibank, spoke immediately after Mr. Rodney and described Citibank as the ‘‘lead sponsor of the premier event.’’16

27. Following Mr. Flanigan’s remarks, and the remarks of several other speakers, Representative Carolyn Cheeks Kilpatrick 

spoke. At the end of her remarks she stated, ‘‘[a]nd to the sponsors, 

by the way, all of you, we couldn’t do this, be with you, help Karl 

if you weren’t here with us so we say thank you very much, you 

are so important. To all of the sponsors, thank you very much.’’ 17


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18Memorandum of Interview of Representative Bennie Thompson (May 6, 2009) (Exhibit 2 at 

09–2222—26). 19Photographs taken at the 13th Annual Caribbean Multi-National Business Conference (Exhibit 5 at 09–2222—62). 20Memorandum of Interview of Representative Bennie Thompson (May 6, 2009) (Exhibit 2 at 

09–2222—28). 21 Id. at 09–2222—27. 

28. In an interview with the OCE, Congressman Thompson confirmed he attended this session of the conference.18

29. In addition to these comments, signs for the conference displayed these corporations’ logos, including signs hung behind the 

speaker’s podium.19

30. In an interview with the OCE, Congressman Thompson stated that he relied on the entity that invited his to the conference, 

the Carib News Foundation, to identify the sponsor of his trip and, 

further, that he relied on the Standards Committee, who pre-approved his trip, to determine if that information was accurate.20 As 

a result, Congressman Thompson told the OCE that the involvement of these corporations in the conference did not raise questions 

in his mind about whether the Carib News Foundation was the 

sole sponsor of the conference.21

31. The Board notes that the practice of relying entirely on the 

Standards Committee to determine the sponsor of a Member’s travel carries with it a degree of risk. Further, while Members are required to receive pre-approval from the Standards Committee before they travel, it is the Member, and not the Standards Committee, that is ultimately accepting the travel from a private sponsor. The Board reads the pre-clearance process as a free-standing 

requirement the House adopted in 2007. There is no indication that 

the House intended it to supplant, or at the very least to completely supplant, Members’ responsibility to abide by the travel 

rules when they accept privately sponsored travel. As a result, it 

is the Board’s view that a reasonable reading of the travel rules 

places responsibility for identifying the sponsor with both the Member and the Standards Committee and not the Standards Committee alone. This shared responsibility also reflects the practical 

reality that, because the Member actually takes the trip, and the 

Standards Committee does not, the Member may, in certain cirVerDate Aug 31 2005 14:27 Mar 09, 2010 Jkt 054329 PO 00000 Frm 00012 Fmt 6601 Sfmt 6601 P:\54-329\REVIEW~1\54-329.TXT 54-329

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22Private Sponsor Travel Certification Form signed by Karl Rodney (Oct. 3, 2008) (Exhibit 

1 at 09–2222—10). 23Letter from Joel Cohen, Counsel for Karl Rodney (May 18, 2009) (Exhibit 6 at 09–2222— 

72). 24Letter from Carib News Foundation to Mr. Eric Eve, Citigroup, Inc. (Apr. 4, 2008) (Exhibit 

7 at 09–2222—77–78) (a nearly identical letter was sent to IBM, AT&T, Pfizer, Verizon Foundation and others). 

cumstances, have access to information about the trip not available 

to the Standards Committee. In this instance, the Member’s had 

information about the sponsors of the conference not available to 

the Standards Committee, namely that numerous corporations 

were identified as sponsors of the conference. 

32. Further, as described below, these other entities were, in fact, 

sponsors of the conference. 

B. CARIB NEWS ALSO SPONSORED CONGRESSMAN THOMPSON’S TRAVEL

33. Karl Rodney is the publisher of the CARIB NEWS, a weekly 

newspaper published in New York. He also identified himself as 

the CEO of the Carib News Foundation on the Private Sponsor 

Travel Certification described above.22

34. According to Mr. Rodney, ‘‘general funds’’ of CARIB NEWS 

were ‘‘pooled’’ with payments from corporate sponsors, made both 

to CARIB NEWS and the Carib News Foundation and fees from 

attendees at the conference to pay conference expenses including 

‘‘travel’’ and ‘‘hotel payments.’’23

35. Therefore, CARIB NEWS was also effectively a sponsor of 

Congressman Thompson’s trip. 

C. CORPORATE DONATIONS WERE EARMARKED FOR THE CONFERENCE

36. According to the House Ethics Manual: 

The rule and implementing regulations are concerned with the 

organization(s) or individual(s) that actually pay for travel. 

Thus, for example, when a nonprofit organization pays for travel with donations that were earmarked, either formally or informally, for the trip, each such donor is deemed a—private source 

for the trip and (1) must be publicly disclosed as a trip sponsor 

on the applicable travel forms and (2) must itself be required 

to satisfy the above standards on proper sources of travel expenses. 

37. In the course of conducting its review, the OCE has learned 

that the Carib News Foundation solicited earmarked funds for the 

conference. For example, Carib News Foundation sent a solicitation 

letter to Citigroup, Inc.24


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25 Id. at 09–2222—79–94. 26 Id. at 09–2222—87–90. 

38. Attached to this solicitation letter was a PowerPoint presentation.25 The presentation solicits money only for the conference 

and not for any other purpose, outlining the benefits of each level 

of sponsorship—Platinum, Gold, and Silver, along with lesser levels 

of sponsorship—in terms of the conference.26 In each instance, the 

sponsorship covers travel related expenses such as gala events and 

meals. 


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27Letter from IRS to OCE (April 17, 2009) (Exhibit 8 at 09–2222—98–115). 28 Id. at 09–2222—98–115. 29Memorandum of Interview of Representative of IBM (May 8, 2009) (Exhibit 9 at 09–2222— 

119). 30Documents submitted to the OCE by Citigroup (Exhibit 7 at 09–2222—76). 

39. The OCE also learned that at least four of the corporations 

identified at the conference did in fact, make payments to the 

Carib News Foundation and CARIB NEWS (the newspaper) earmarked for the conference. The Carib News Foundation itself appears to be nothing more than a conduit in this case, and a partial 

one at that, for payments from corporations to support the conference. There is no evidence that the organization has filed a tax 

return with the IRS, under either Carib News Foundation or Carib 

News Charities, since 2005.27 On its 2005 Form 990, the Carib 

News Foundation is shown as having no assets, no income and no 

expenses.28 Not a single witness from a sponsor interviewed by the 

OCE knew of any other work of the Foundation. Indeed one witness, from IBM, was not aware that the Foundation played a role 

in the conference.29

40. Citigroup. Citigroup made a $75,000 payment to the CARIB 

NEWS for the conference.30


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31Mr. Rodney accepted corporate payments under the names of three entities: The Carib 

News, the Carib News Foundation, and the Carib News Charities. According to the Secretary 

of State for the State of New York, the organization that currently operates as the Carib News 

Foundation originally operated under the name the Carib News Charities. 32Documents Submitted to the OCE by the Verizon Foundation (Exhibit 10 at 09–2222—122). 33Memorandum of Interview of Representative 1 of Verizon Foundation (Mar. 23, 2009) (Exhibit 11 at 09–2222—128). 34Documents submitted by IBM to the OCE (Exhibit 13 at 09–2222—142). 

41. Verizon Foundation. Verizon Foundation made a $35,000 

payment to the Carib News Charities 31 for the conference.32

42. Representative 1 of the Verizon Foundation said the Verizon 

Foundation funded the Carib News Foundation for the first time in 

2008 and that the grant was issued to provide funding for the 13th 

Annual Caribbean Multi-National Business Conference.33

43. IBM. IBM made a $20,000 payment to Carib News Foundation for the conference as indicated on the invoice that CARIB 

NEWS, INC. (not Carib News Foundation) sent IBM.34


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35Memorandum of Interview of Representative 1 of Macy’s (Exhibit 20 at 09–2222—236). 36 Interview with Investigative Counsel on May 22, 2009. 37Documents submitted by American Airlines to the OCE (Exhibit 14 at 09–2222—145) and 

OCE Investigative Counsel interview with American Airlines Representative (Mar. 5, 2009) 

(American Airlines provided an in-kind contribution in the form of ten roundtrip tickets to be 

used by Carib News in any manner they chose with the exception that no ticket could be used 

for an elected official or the official’s staff or family. The estimated value of their contribution 

was between $6,200 and $7,500). 

44. Macy’s. Macy’s made a $35,000 payment to CARIB NEWS 

for the conference.35

45. Pfizer. Pfizer made a $25,000 payment to CARIB NEWS for 

the conference.36

46. Only American Airlines explicitly limited their sponsorship of 

the conference to individuals who were not elected officials, prohibiting CARIB NEWS from using any part of their sponsorship on 

Members of Congress and other government officials and their 

staff.37 No other sponsor with whom we spoke placed restrictions 

on how or on whom their contribution could be spent. The only expectation was that the contribution would be used for expenses associated with the conference. 

D. BECAUSE ENTITIES THAT EMPLOY OR RETAIN LOBBYISTS SPONSORED THE EVENT, CONGRESSMAN THOMPSON’S INVOLVEMENT

SHOULD HAVE BEEN LIMITED TO ONE DAY

47. According to the House Ethics Manual: 

One-Day Event Trip. The sole exception to the general prohibition on accepting officially-connected travel from a private 

source that retains or employs lobbyists or agents of a foreign 

principal is for trips involving attendance at or participation in 

one-day event (exclusive of travel time and an overnight stay). 

Under the rule, it is permissible for a Member or staff person 

to accept and meals related to a single night’s lodging and 

meals related to the trip, if offered by the trip sponsor. Members 

and staff must limit their involvement in connection with the 

event to a single calendar day, exclusive of travel time and 

an overnight stay. A Member or staff person may therefore atVerDate Aug 31 2005 14:27 Mar 09, 2010 Jkt 054329 PO 00000 Frm 00017 Fmt 6601 Sfmt 6601 P:\54-329\REVIEW~1\54-329.TXT 54-329

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38 House Ethics Manual at 92–93 (citing House Rule 25, clause 5(b)(1)(C)) (emphasis in original)). 39 Clerk of the House of Representatives Lobbying Disclosure Report 2008 (excerpt attached 

hereto as ‘‘Exhibit 15’’ at 09–2222—151–156). 40Member/Officer Post-Travel Disclosure Form signed by Representative Bennie G. Thompson 

(Dec. 5, 2008) (Exhibit 1 at 09–2222—2). 41 In 2007, the ‘‘host’’ of the conference was the Government of Antigua and Barbuda. In the 

event that the Government of Antigua and Barbuda provided the same support as St. Maarten 

did in 2008, then the members may have accepted gifts from a foreign government which would 

have been reportable under the Foreign Gift and Decorations Act. In addition, if the Government of Antigua provided these gifts to the Members, and if they were more than $335 in value, 

then the Members should have disclosed them on their financial disclosure form for 2007, which 

was filed in May 2008. 42Letter from Karl Rodney to Commissioner Sarah Wescott-Williams (Aug. 13, 2008) (Exhibit 

16 at 09–2222—158). 

tend only a single day of a multiple-day conference, forum, or 

other event that is being hosted primarily for individuals other 

than congressional invitees. 

Under the Committee’s travel regulations and guidelines implementing the travel provisions of the gift rule, the Committee 

may permit a second night’s stay when determined—on a 

case-by-case basis to be practically required to participate in the 

one-day event (House Rule 25, clause 5(b)(1)(C)). Some circumstances in which the Committee may permit a second 

night’s stay are for certain long-distance trips, when a Member 

or staff person is participating in a full day’s worth of officiallyconnected activities such that a second night’s stay is necessary 

to accomplish the purpose of the trip, or other exceptional circumstances that are described in detail by the traveler. The 

traveler will be personally responsible for any expenses incurred 

beyond those allowed by the Committee in connection with the 

second night’s stay.38

48. Citigroup, IBM and Verizon employ or retain lobbyists.39

49. Congressman Thompson spent four days at the conference at 

the expense of the third-party.40

50. There is substantial reason to believe that Congressman 

Thompson violated House Rule 25, clause 5(b)(1)(C) by accepting 

trip-related reimbursements from entities that employ or retain 

lobbyists for participating in an event for more than one day. 

E. THE GOVERNMENT OF ST. MAARTEN MADE IN-KIND DONATIONS TO

THE 2008 CONFERENCE AND PLAYED A SIGNIFICANT ROLE IN PLANNING, ORGANIZING AND CONDUCTING THE 2008 CONFERENCE

51. The Government of St. Maarten was the host of the 2008 conference. 

52. In that capacity, the Government of St. Maarten provided inkind donations to support the conference and also had a substantial role in planning the conference. As a result, it was effectively 

a sponsor of the 2008 conference.41

53. Rodney provided the Leader of Government of St. Maarten, 

Commissioner Sarah Wescott-Williams, with a list of ‘‘Basic Requirements to Host Caribbean Multi-National Business Conference.’’ 42 These included: 


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43Letter from Joel Cohen, Counsel for Karl Rodney (May 18, 2009) (Exhibit 6 at 09–2222— 

72–73). 

54. According to a statement from Mr. Rodney submitted to the 

OCE, the Government of St. Maarten, (1) developed local Host 

Committees to facilitate local planning; (2) helped negotiate the 

rate with the hotel, (3) assisted in developing the theme of the Conference, (4) assisted in identifying local speakers, including the 

Leader of Government, (5) assisted in local publicity, (6) provided 

local entertainment, including a school choir and cultural items, (7) 

arranged Host Country Evening on Friday, November 8 (the whole 

group was transported to another property for refreshments and 

entertainment), (8) helped with local transportation for some 

CARIB NEWS employees and helped arrange accommodations for 

some guests (not paying for such accommodations), (9) participated 

as event speakers, and (10) issued invitations to attend to specially 

invited guests.43 These contributions to the conference were all inVerDate Aug 31 2005 14:27 Mar 09, 2010 Jkt 054329 PO 00000 Frm 00019 Fmt 6601 Sfmt 6601 P:\54-329\REVIEW~1\54-329.TXT 54-329

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44 Id. 45 5 U.S.C. § 7342. 46Memorandum of Interview of Representative Bennie Thompson (May 6, 2009) (Exhibit 2 at 

09–2222—28). 47 Id. 48 House Ethics Manual (2008) at 92–93 (citing House Rule 25, clause 5(b)(1)(C)). 

kind, according to Mr. Rodney, and he did not provide an estimated 

value for them.44

55. In addition, because these donations to the conference are 

from a foreign government, Members are required to take certain 

actions under the Foreign Gifts and Decorations Act.45

56. Representative Thompson told the OCE that he was unaware 

of what role the Government of St. Maarten played in the conference.46

III. ROLE OF THE CHAIR’S COUNSEL IN THE APPROVAL OF THE 12TH

ANNUAL CARIBBEAN MULTI-NATIONAL BUSINESS CONFERENCE IN

2007 

57. As previously stated, Congressman Thompson told the OCE 

that he relied on the Standards Committee to determine who the 

true sponsor of the conference was based on information the Standards Committee received from the organization that invited him to 

the conference—the Carib News Foundation.47 In the course of the 

Board’s review, the OCE requested documents from Mr. Karl Rodney, the CEO of the Carib News Foundation. Mr. Rodney voluntarily submitted documents to the OCE that included, among other 

things, communication with certain members of the staff of the 

Committee on Standards of Official Conduct in 2007. The contents 

of these documents from 2007 are relevant because they indicate 

the role of the corporations was concealed from the Committee in 

2008. 

58. The Board requested that the Committee provide the information submitted to it for 2008 and the Committee declined to do 

so. 

59. The documents submitted by Mr. Rodney show that in 2007 

the CARIB NEWS initially identified, on several occasions, other 

corporations as sponsors of the Conference. The designation of 

these corporate entities as sponsors presented a problem for CARIB 

NEWS and the Members who wished to attend the conference insofar as their attendance would be limited to one day. In 2007, as a 

result of changes in the travel rules, a Member could not, in most 

instances, participate in an event (such as a conference) for more 

than one day if their travel to and participation in the event was 

paid for by an entity that employed or retained a lobbyist.48 Many 

of the corporate entities who sponsored the 2007, as well as the 

2008 conference, employed or retained lobbyists. Although CARIB 

NEWS initially identified these entities as sponsors, following 

interactions with the counsel to the then-chair of the Committee, 

apparently without the knowledge of the Standards Committee 

staff attorney assigned to review the trip, the documents identifying these organizations as sponsors were changed. 

60. Subsequently, in 2008, the Carib News Foundation submitted 

documents that omitted the role of these other corporations as 

sponsors of the conference. Further, the staff attorney assigned to 


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49 E-mail from Patricia Louis to Dawn Kelly Mobley (Sept. 17, 2007, 3:47 PM EST) (Exhibit 

17 at 09–2222—208) (The Board elected not the interview Ms. Mobley and Ms. Olson because 

the Standards Committee voted against disclosing information to the OCE. The Board determined that it would have been an act of bad faith on the part of the OCE to attempt to interview staff and former staff of the Standards Committee in light of the Committee’s refusal to 

grant OCE access to their records.). 50 E-mail from Dawn Kelly Mobley to Patricia Louis (Sept. 18, 2007, 12:57 PM EST) (Exhibit 

17 at 09–2222—208). 51 E-mail from Patricia Louis to Dawn Kelly Mobley (Sept. 18, 2007) (Exhibit 17 at 09–2222— 

208). (The Board notes that while the document that contains the e-mail does not have a header 

which indicates a date and time, both the e-mail before it and responding to it are dated September 18, 2007). 52 E-mail from Dawn Kelly Mobley to Patricia Louis (Sept. 18, 2007, 7:03 PM EST) (Exhibit 

17 at 09–2222—207). 53 E-mail from Dawn Kelly Mobley to Patricia Louis (Sept. 19, 2007, 2:16 PM EST) (Exhibit 

17 at 09–2222—207). 54 House Ethics Manual (2008) at 97–98. 

review the trip in 2008 was not the same staff attorney that reviewed the trip in 2007. 

61. The earliest communication between CARIB NEWS or the 

Carib News Foundation and anyone associated with the Ethics 

Committee in the documents submitted to the OCE from Mr. Rodney is an e-mail dated September 17, 2007 from Patricia Louis, an 

Executive Assistant at CARIB NEWS, to Dawn Kelly Mobley, 

Counsel to the then-Chair of the Ethics Committee.49

62. The next day, on September 18, 2007, Ms. Mobley responded 

and asked for ‘‘any information on your sponsor’s status.’’ 50

63. That same day Ms. Louis responded, indentifying multiple 

corporations as ‘‘sponsors’’ of the trip.51

64. In response that same day, Ms. Mobley asked, ‘‘[d]o any of 

these organizations have or retain a lobbyist’ ’’ 52

65. The next day, Ms. Mobley further responded asking Ms. 

Louis whether she, Ms. Mobley, should ‘‘assume’’ the sponsor was 

CARIB NEWS, despite the fact that Ms. Louis had not identified 

CARIB NEWS as a sponsor.53 The Board notes that in her e-mail, 

Ms. Louis did not identify CARIB NEWS as a sponsor. Further, 

Ms. Mobley acknowledged that she had been told corporations identified by Ms. Louis were ‘‘sponsoring food and other parts of the 

Antigua travel.’’ Under House rules in place at the time, and under 

current rules, sponsoring a meal makes these corporations sponsors 

of a Member’s travel.54 The Board also notes Ms. Mobley’s use of 

the phrase ‘‘safe review,’’ which the Board takes to mean a review 

which results in approval of the trip. 


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55 E-mail from Dawn Kelly Mobley to Patricia Louis (Sept. 19, 2007, 3:23 PM EST) (Exhibit 

17 at 09–2222—207). 56 E-mail from Patricia Louis to Dawn Kelly Mobley (Sept. 21, 2007, 1:56 PM EST) (Exhibit 

17 at 09–2222—205). 

66. Later in the afternoon on September 19, 2007, Ms. Mobley 

sent Ms. Louis another e-mail where she discussed the limitations 

posed by the new travel rules the House had adopted in 2007. Ms. 

Mobley told Ms. Louis, ‘‘the new rules might prohibit some things 

you were able to do with so many different sponsors in the past.’’ 

Thus, Ms. Mobley again acknowledged that these corporations were 

sponsors and that the new travel rules affected the nature of their 

participation in the trip.55

67. On September 21, 2007, Ms. Louis responded.56


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57Private Sponsor Travel Certification Form (Sept. 21, 2007) (Exhibit 17 at 09–2222—195). 58 Id. 

68. That same day, on September 21, 2007, Ms. Louis faxed Ms. 

Mobley a Private Sponsor Travel Certification Form. On the form 

Carib News Foundation is listed as the sponsor of the trip in question 1.57

69. However, the Carib News Foundation listed a number of corporations as private sponsors, each with responsibility for planning 

and conducting the trip, in question 12.58 This is at least the second instance where the Carib News Foundation identified these 

corporations as the trip’s sponsors. 


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59 E-mail from Dawn Kelly Mobley to Patricia Louis (Sept. 25, 2007, 12:42 PM EST) (Exhibit 

17 at 09–2222—192). 60 E-mail from Dawn Kelly Mobley to Patricia Louis (Sept. 25, 2007, 5:08 PM EST) (Exhibit 

17 at 09–2222—192). 61 E-mail from Dawn Kelly Mobley to Patricia Louis (Oct. 3, 2007, 12:39 PM EST) (Exhibit 

17 at 09–2222—185). 62Private Sponsor Travel Certification Form (Sept. 21, 2007) (Exhibit 17 at 09–2222—196). 63Private Sponsor Travel Certification Form (Oct. 5, 2007) (Exhibit 18 at 09–2222—211). 

70. This prompted the following e-mail from Ms. Mobley to Ms. 

Louis.59 The Board notes that Ms. Mobley stated she was ‘‘working 

through’’ the Carib News Foundation’s forms ‘‘before leaving them 

with our staff attorney.’’ 

71. Later that same day, Ms. Mobley queried further.60 At least 

as of this date, following at least two instances where Ms. Louis 

identified these corporations as sponsors, Ms. Mobley appeared to 

treat these entities as ‘‘co-sponsors.’’ 

72. On October 3, 2007, Ms. Mobley informed Ms. Louis that 

Susan Olson was the staff attorney assigned to review the trip.61

73. A copy of the Private Sponsor Travel Certification Form provided to a Member’s office on October 5, 2007, shows that by October 5, 2007, following its interaction with Ms. Mobley, Carib News 

Foundation changed its answer to question 12 regarding other private sponsors. As previously highlighted, as of September 21, 2007, 

Carib News Foundation provided the following answer to question 

12.62

74. However, as of October 5, 2007, it provided a different answer to question 12.63


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64 Id. at 09–2222—215 65 E-mail from Susan Olson to Patricia Louis (Oct. 10, 2007, 4:01 PM EST) (Exhibit 17 at 09– 

2222—177–178). 

And the attached sheet provided the following information.64

On October 10, 2007, Susan Olson, the staff attorney on the Standards Committee assigned to review the trip e-mailed Ms. Louis the 

following questions 65 (and copied Ms. Mobley and the Chief Counsel of the Standards Committee at that time, Bill O’Reilly). While 

the Private Sponsor Travel Certification Form for the trip had been 

changed by this date, the draft agenda for the conference apparently had not and still showed corporate sponsors for various 

events. What Ms. Olson does not appear to be aware of is the fact 

that Carib News Foundation had previously identified the same 

corporations she is raising questions about as private sponsors on 

its original Private Sponsor Travel Certification form. 


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66 Committee on Standards of Official Conduct, Advisory Opinion (Oct. 27, 2006) (Exhibit 17 

at 09–2222—201–203). 67Working Draft of the 13th Annual Caribbean Multi-National Business Conference Program 

(Oct. 3, 2007) (Exhibit 19 at 09–2222—217). 68 Id. at 09–2222—222–223. 

75. The Committee’s Advisory Opinion dated October 27, 2006 indicates, as Ms. Olson wrote, that Carib News Foundation told the 

Standards Committee in 2006 that there were several corporate entities that sponsored the conference.66 The ‘‘Advisory Opinion’’ did 

not conclude that these entities were, in fact, the trip’s sponsors, 

as the e-mail seems to indicate. 

76. A draft agenda for the conference dated October 3, 2007, 

identified a ‘‘sponsor’’ for each event listed.67 This appears to be the 

version of the agenda that Olson is referring to in her e-mail. For 

example, ‘‘Preferred Health Partners’’ is identified as the sponsor 

of this event on ‘‘Port & Airport Security—The Mandates.’’ 68


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69 Id. at 09–2222—229. 70 E-mail from Patricia Louis to Dawn Kelly Mobley, George Dalley, and Shelley Thomas (Oct. 

10, 2007, 5:56 PM EST) (Exhibit 17 at 09–2222—183). 

And Citi is identified as the sponsor of this event on ‘‘Community 

Outreach—Education—Access and Collaboration.’’ 69

77. Ms. Louis forwarded Ms. Olson’s e-mail to Ms. Mobley, Congressman Charles Rangel’s Chief of Staff George Dalley and Delegate Donna Christensen’s scheduler Shelley Thomas, and asked 

them to advise her on a response.70


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71Memorandum of Interview of Representative of IBM (May 8, 2009) (Exhibit 9); Memorandum of Interview of Representative 1 of the Verizon Foundation (Mar. 23, 2009) (Exhibit 11); 

Memorandum of Interview of Representative of Citi (Mar. 17, 2009) (Exhibit 4); Memorandum 

of Interview of Representative 1 of Macy’s (May 28, 2009) (Exhibit 20). 72 E-mail from Dawn Kelly Mobley to Patricia Louis (Oct. 10, 2007, 6:49 PM EST) (Exhibit 

17 at 09–2222—183). 

Ms. Louis appears to be pre-clearing her response to questions 

posed by the Standards Committee staff attorney. There is no indication that the staff attorney knew that the answer to her question 

had already been discussed with the counsel to the then-chair of 

the Standards Committee. Substantively, based on documents obtained by the OCE and interviews with sponsors, the statement 

‘‘the sponsors contribute to the overall expense of the trip’’ appears 

to be true. However, the statement ‘‘and the general work of the 

Foundation,’’ does not appear to be true. All of the sponsors OCE 

interviewed stated unequivocally that the contribution was intended for the conference.71

78. Less than an hour later Ms. Mobley responded.72 The Board 

notes Ms. Mobley’s concern with whether any of the corporate 

sponsors paid for an event and also retained a lobbyist’’ and her 

conclusion that if they did, Members of Congress could only attend 

for one day. 


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73Fax from Patricia Louis to Dawn Kelly Mobley (Oct. 11, 2007) (Exhibit 17 at 09–2222—180). 74Working Draft of the 13th Annual Caribbean Multi-National Business Conference Program 

(Oct. 22, 2007) (Exhibit 21 at 09–2222—238). 

79. Ms. Louis then faxed Ms. Mobley.73 The Board notes that Ms. 

Louis again appears to be pre-clearing her responses to the staff attorney, Ms. Olson, with Ms. Mobley (‘‘Kindly review and advise before I send to Ms. Olson.’’). 

80. The Board further notes that Ms. Louis represented that, 

‘‘the program has been amended to reflect the companies as Participants,’’ an action taken following Ms. Louis’ interactions with Ms. 

Mobley. A copy of the revised agenda was submitted by another 

Member of Congress who attended the conference.74 The Board 

notes that this ‘‘updated’’ schedule changed the label applied to 

‘‘sponsors’’ to ‘‘participants’’ and in some cases deleted any mention 


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75Working Draft of the 13th Annual Caribbean Multi-National Business Conference Program 

(Oct. 3, 2007) (Exhibit 19 at 09–2222—222–223). 76Working Draft of the 13th Annual Caribbean Multi-National Business Conference Program 

(Oct. 22, 2007) (Exhibit 21 at 09–2222—242). 77Working Draft of the 13th Annual Caribbean Multi-National Business Conference Program 

(Oct. 3, 2007) (Exhibit 19 at 09–2222—229). 78Working Draft of the 13th Annual Caribbean Multi-National Business Conference Program 

(Oct. 22, 2007) (Exhibit 21 at 09–2222—248). 79Memorandum of Interview of Representative of Citi (Mar. 17, 2009) (Exhibit 4). 

of the corporate entity that had previously been identified as a 

‘‘sponsor.’’ 

81. This event was previously identified in the earlier draft as 

being ‘‘sponsored’’ by Preferred Health Partners.75 Now it identifies 

them as merely a ‘‘participant.’’ 76

82. In another example, the Board notes that the following event 

was previously identified as being sponsored by CITI.77 Now CITI 

is not even mentioned.78 Michael Flanigan, the moderator, was an 

executive at CITI at the time and represented the company at the 

conference.79


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80 E-mail from Patricia Louis to Susan Olson (Oct. 10, 2007, 10:33 AM EST) (Exhibit 17 at 

09–2222—177). 81 E-mail from Susan Olson to Bill O’Reilly and Dawn Kelly Mobley (Oct. 12, 2007 9:29 AM) 

(Exhibit 17 at 09–2222—177). 

83. These changes were entirely cosmetic. There is no indication 

that the corporations’ substantive role in the conference changed in 

any way. 

84. That same day, October 11, 2007, Ms. Louis responded to Ms. 

Olson, stating that ‘‘[t]he sponsors contribute to the overall expense 

of the trip.’’ 80 The Board notes that this is precisely the answer she 

had pre-cleared with Mobley. 

85. Ms. Olson then forwarded her exchange with Ms. Louis to 

Bill O’Reilly, the Staff Director and Chief Counsel of the Ethics 

Committee at that time, and to Dawn Mobley.81 Based on this email, it appears that Ms. Olson was unaware that Mobley had been 


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82Memorandum of Interview of Representative of IBM (May 8, 2009) (Exhibit 9); Memorandum of Interview of Representative 1 of the Verizon Foundation (Mar. 23, 2009) (Exhibit 11); 

Memorandum of Interview of Representative of Citi (Mar. 17, 2009) (Exhibit 4); Memorandum 

of Interview of Representative 1 of Macy’s (May 28, 2009) (Exhibit 20). 83 E-mail from Dawn Kelly Mobley to Patricia Louis (Oct. 12, 2007 9:59 AM EST) (Exhibit 

17 at 09–2222—176). 84 E-mail from Dawn Kelly Mobley to Patricia Louis (Oct. 12, 2007 1:55 PM EST) (Exhibit 17 

at 09–2222—176). 

communicating directly with the Carib News Foundation. There is 

also no evidence that Ms. Mobley told her she had been involved 

in this manner. Witnesses for the various sponsors told the OCE 

that they did contribute funding directly to the trip (the conference) 

and in no case did they simply make donations to the ‘‘general 

funds’’ of the CARIB NEWS or the Carib News Foundation.82

86. Ms. Mobley then forwarded Ms. Olson’s internal e-mail to Ms. 

Louis.83 The Board notes that Ms. Mobley counseled that these 

‘‘other organizations’’ can ‘‘participate’’ in the program but ‘‘should 

not help pay for the trip.’’ 

87. Later that day, Ms. Mobley sent Ms. Louis an additional email.84 As previously stated, the sponsors whom the OCE interviewed all stated that they did not ‘‘support [the] foundation annually’’ and did specifically designate their donations for the 2007 

conference. Either Ms. Mobley was repeating inaccurate information Ms. Louis had given her, or she was giving inaccurate information to Ms. Olson without prompting. 


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85 E-mail from Susan Olson to Patricia Louis (Oct. 12, 2007 2:41 PM EST) (Exhibit 17 at 09– 

2222—171). 86 E-mail from Patricia Louis to Dawn Kelly Mobley (Oct. 18, 2007 11:00 AM EST) (Exhibit 

17 at 09–2222—170). 

88. Ms. Olson then sent Ms. Louis additional questions about the 

corporate entities previously identified as ‘‘sponsors.’’ 85

89. Three days later, Ms. Louis sent an e-mail to Ms. Mobley, but 

addressed to Ms. Olson.86 This may have been inadvertent or, 

based on their previous practice, Ms. Louis may have done this before she then sent it to Ms. Olson. This is the final communication 

regarding the 2007 conference provided to the OCE. 


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87Memorandum of Interview of Staff Member 1 of Congressman Rangel’s Office (May 27–28, 

2009) (Exhibit 22 at 09–2222—251–256). 881T3AId. at 09–2222—252. 89 Id. at 09–2222—253. 90 Id. 

90. In an interview with the OCE, a staff member of Representative Rangel’s office, Staff Member 1 of Congressman Rangel’s Office, described discussions with Ms. Louis and Ms. Mobley in 2007 

on the topic of how the new travel rules would affect the Members’ 

participation in the 2007 conference.87 The staff member said that 

Ms. Louis, and Mr. and Mrs. Rodney told him that the then Chair 

of the Standards Committee had assigned her counsel on the Committee, Ms. Mobley, to ‘‘find a way’’ to allow Members of Congress 

to participate in the conference under the new travel rules passed 

by the House in 2007.88 The staff member told the OCE that Congressman Rangel told him that the then-Chair had made similar 

statements to him.89

91. Staff Member 1 of Congressman Rangel’s Office said the 

‘‘framework’’ that was decided upon was that the Carib News Foundation would raise money from corporate donors who had previously sponsored the conference and that this money in turn 

would be deposited in a ‘‘common fund’’ that would then be used 

to pay for the conference. It was Staff Member 1 of Congressman 

Rangel’s Office’s understanding that if this was done, then Members of Congress could participate in the conference without any restrictions imposed by the new rules. Staff Member 1 of Congressman Rangel’s Office said that it was important to break the link 

between the corporations and the conference under the new rules 

and that using the Foundation in this way would enable that to 

happen. Staff Member 1 of Congressman Rangel’s Office said he 

learned of this new framework for the conference from Mr. and 

Mrs. Rodney and that they represented this approach had come 

from Ms. Mobley on the Standards Committee.90


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91Fax from Patricia Louis to Dawn Kelly Mobley (Aug. 20, 2008) (Exhibit 23 at 09–2222— 

258). 

92. This conduct in 2007 is relevant to the present reviews for 

a number of reasons. First, in and of itself, the intervention of the 

Chair’s counsel in this matter is troubling and more likely constituted an improper manipulation of the clearance process. Following Ms. Mobley’s intervention, Carib News Foundation changed 

the Private Sponsor Travel Certification Form to delete any mention of private sponsors before it was sent to the Standards Committee’s staff attorney assigned to review the matter. This occurred 

after Carib News Foundation had told Ms. Mobley that these corporations were sponsors of the conference on several occasions. Ms. 

Louis’s initial, and presumably truthful, submissions regarding the 

conference described the corporate entities as sponsors. However, if 

the corporations were sponsors of the conference, as opposed to 

Carib News Foundation, then the Members of Congress ability to 

attend would have been limited because, the corporations, unlike 

the Carib News Foundation, employed or retained lobbyists. It appears from the correspondence between Ms. Mobley and Ms. Louis, 

and Ms. Olson’s apparent ignorance of the correspondence, that Ms. 

Mobley assisted Ms. Louis in preparing inaccurate answers for Ms. 

Olson in order to ensure that Ms. Olson would approve the trip in 

a manner that would not limit the attendance of the Members of 

Congress. Ms. Mobley’s involvement in the process seems to have 

prevented the Standards Committee and its staff from correctly 

performing its responsibilities. Ms. Olson’s approval of the trip was 

predicated on an incomplete or inaccurate factual record, in which 

Ms. Mobley apparently was complicit, putting at risk those Members of Congress who relied on that approval. 

93. The 2007 conduct and attendant misrepresentations appear 

to have directly influenced what occurred in 2008. When the Carib 

News Foundation submitted materials to the Standards Committee 

for their approval of the 2008 conference, the Carib News Foundation took the same approach that they had been counseled to take 

in 2007 and did not disclose the role of the corporate sponsors on 

the Private Sponsor Travel Certification Form or the conference 

agenda. 

94. In fact, in 2008, Carib News Foundation again first submitted its document to Ms. Mobley.91 The Board notes that while 

Ms. Mobley remains an employee of the U.S. House of Representatives as of the date of this report, the above described conduct did 

not occur after the day the House passed the resolution creating 

the OCE, and therefore, under the terms of the that resolution, the 

OCE does not have jurisdiction to open a preliminary review into 

Ms. Mobley’s conduct. 


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92 House Rule 25(5)(h)(i)(1)(B) directs the Standards Committee to establish, ‘‘regulations describing the information it will require individuals subject to this clause to submit to the committee in order to obtain the prior approval of the committee for any travel covered by this 

clause . . .’’ On February 20, 2007, the Committee issued guidelines and regulations concerning 

the travel restrictions and requirements. 

IV. THE VALUE OF THE TRIP REPORTED ON THE MEMBER’S POSTTRAVEL DISCLOSURE FORM

95. Under House Rule 25 clause 5(d), Members are required to obtain prior approval of the Standards Committee for trips where the 

Member’s travel expenses will be reimbursed by a private source. 

The Standards Committee has adopted regulations, including a preand post-travel form Members must complete, pursuant to House 

Rule 25 clause 5(h)(i)(1)(B) 92 that requires Members to publicly disclose ‘‘trip expenses.’’ 

96. According to the House Ethics Manual, ‘‘[t]he rule and implementing regulations are concerned with the organization(s) or individual(s) that actually pay for travel.’’ House Ethics Manual (2008) 

at 97. 

97. There is substantial reason to believe that Congressman 

Thompson violated House Rule 25 clause 5(h)(i)(1)(B) by underreporting the value of the travel reimbursements he received to attend the 13th Annual Caribbean Multi-National Business Conference. 


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93Private Sponsor Travel Certification Form signed by Karl Rodney (Oct. 3, 2008) (Exhibit 

1 at 09–2222—10). 94Letter from Joel Cohen, Counsel for Karl Rodney (May 18, 2009) (Exhibit 6 at 09–2222— 

73). 

A. REPRESENTATIONS FROM CARIB NEWS FOUNDATION

98. Carib News Foundation submitted a Private Sponsor Travel 

Certification Form to each Member it sponsored for the 2008 trip— 

Representatives Christensen, Kilpatrick, Payne, Rangel and 

Thompson.93 This form was provided to each Member Office and 

then submitted by the Member Office to the Standards Committee 

as part of the pre-travel approval process. 

99. The Board notes that the Carib News Foundation provided 

the same exact dollar figure with very minor variations for each 

Member of Congress that attended the conference despite the fact 

that Carib News Foundation recognized on the same form that the 

Congressional travelers were travelling to and from different cities. 

In fact, the Congressional travelers came from St. Croix, U.S. Virgin Islands; Detroit, Michigan; Newark, New Jersey; New York, 

New York; and Jackson, Mississippi. 

100. In addition, according to Mr. Rodney, the cost charged to 

‘‘the public’’ to attend the conference for four days and three nights 

was $840 for double occupancy or $1085 for single occupancy. The 

cost of attendance included ‘‘room accommodations, meals, and admission to the Conference.’’ However, these figures were not disclosed pre-travel to the Members or the Standards Committee, nor 

were these figures disclosed to the Members after the conference.94


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95Member/Officer Post-Travel Disclosure Form signed by Representative Bennie G. Thompson 

(Dec. 5, 2008) (Exhibit 1 at 09–2222—3). 96 E-mail from Jennifer Jimerson to Patricia Louis (Oct. 27, 2008, 8:27 PM EST) (Exhibit 24 

at 09–2222—283). 97Memorandum of Interview of Representative Bennie Thompson (May 6, 2009) (Exhibit 2 at 

09–2222—26). 

B. INFORMATION REQUIRED FROM THE CONGRESSIONAL TRAVELER

101. On his Member/Officer Post-Travel Disclosure Form,95 Representative Thompson certified his travel cost as the following: 

102. However, documents from Congressman Thompson’s office 

show his airline ticket cost $750.15, not $410.96

103. In an interview with OCE, Congressman Thompson stated 

that he had been shown a list of flights and that he had chosen 

which flight he would take.97


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98Member/Officer Post-Travel Disclosure Form signed by Representative Bennie G. Thompson 

(Dec. 5, 2008) (Exhibit at 09–2222—2). 99Letter from IRS to OCE (Apr. 17, 2009) (Exhibit 8 at 09–2222—98–115). 100Online Version of Publication 78 (Accessed online on June 5, 2009 at http://www.irs.gov/ 

app/pub-78/) (Exhibit 8 at 09–2222—114–115). 101 26 U.S.C. §§ 501 and 509. 102 26 U.S.C. §§ 4941 and 4946. 103 26 U.S.C. § 4941(d)(1)(F). The Code imposes a tax (currently 10 percent of the amount involved) on the illegal payments, with later penalties (up to $20,000 per act of self-dealing) for 

failure to pay back the foundation. The tax is imposed on the disqualified person, including a 

government official if the official participates in the act of self-dealing knowingly. 

V. CARIB NEWS FOUNDATION, AS A PRIVATE FOUNDATION, WAS

PROHIBITED FROM PAYING FOR CONGRESSMAN THOMPSON’S TRAVEL

104. The Carib News Foundation is identified as the ‘‘sponsor’’ of 

this conference on at least three forms filed with the Committee on 

Standards of Official Conduct: (1) the ‘‘Private Sponsor Travel Certification Form’’; (2) the ‘‘Privately Sponsored Travel: Travel Form,’’ 

and (3) the ‘‘Member/Officer Post-Travel Disclosure Form.’’ 98

105. According to a query of the New York State’s Office of the 

Secretary of State, Mr. Rodney appears to operate two organizations—the ‘‘Carib News, Inc’’ which operates a newspaper and the 

‘‘Carib News Charities, Inc’’ which also may operate under the 

name ‘‘Carib News Foundation.’’ The OCE has not been able to 

identify any additional activity, other than the annual Caribbean 

Multi-National Business Conference, in which the latter organization is involved. Furthermore, while ‘‘Carib News Charities, Inc’’/ 

‘‘Carib News Foundation’’ is listed with New York’s Office of the 

Secretary of State as a domestic not-for-profit corporation, it is not 

listed, as required by law, with the New York State Charities Bureau. In addition, there is no evidence that the organization has 

filed a tax return with the IRS, under either name, since 2005.99

According to Publication 78 of the IRS, a list of all charities claiming 501(c) status, Carib Charities, Inc is a private foundation.100

106. Every organization that qualifies for tax exemption described in section 501(c)(3) of the Internal Revenue Code is defined 

as a private foundation unless the organization falls into one of the 

categories specifically excluded from the definition under section 

509(a).101 In effect, the definition divides 501(c)(3) organizations 

into two classes: private foundations and public charities. Private 

foundations are generally funded through a single donor, family or 

corporation and operate through investment income; whereas, public charities are typically funded and operated through diversified 

support from governmental sources and the general public. 

107. There are several restrictions that are placed on private 

foundations. At issue here is the restriction on ‘‘self-dealing’’ between a disqualified person (the definition of which includes Members of Congress) and a private foundation.102 The Code defines the 

act of ‘‘self-dealing’’ to include any direct or indirect agreement to 

make any payment of money (including reimbursement of expenses) or other property by a private foundation to a government 

official.103 Although framed as a tax provision, the statute essentially bars certain federal employees and federally elected officials 


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40 

104The payment or reimbursement of travel expenses for travel solely from one point in the 

United States to another point in the United States is excepted from the definition of self-dealing provided that the payment or reimbursement does not exceed the actual cost of the transportation involved and provided the amount for all other traveling expenses does not exceed 125 

percent of the maximum amount payable under section 5702 of title 5, United States Code, for 

like travel by employees of the United States. 26 U.S.C. § 4941(d)(2)(G)(vii). 105Memorandum from Ethics Counsel at the National Institutes of Health to Deputy Ethics 

Counsels at NIH (Jun. 2, 2000) (Exhibit 25 at 09–2222—278). 106Memorandum of Interview of Representative Bennie Thompson (May 6, 2009) (Exhibit 2 

at 09–2222—27). 

from receiving compensation, including reimbursements for international travel, from a private foundation.104

108. As such, it appears that the Carib News Foundation’s payment of travel expenses for Representative Kilpatrick and her acceptance of payment potentially violated the Internal Revenue 

Code. 

109. The Board infers from the fact that the Standards Committee approved the reimbursement that the Standards Committee 

is unaware of this restriction. The Board notes, however, that its 

own research revealed that numerous other ethics-related entities 

in the federal government are aware of this restriction, and have 

for some time been enforcing it.105

110. Congressman Thompson told the OCE that he was unaware 

of any limitations on the ability of private foundations to pay for 

overseas travel by government officials.106

111. The Board notes that these facts show failures at multiple 

points by multiple parties in complying with and enforcing the 

travel rules. Inaccurate information was provided by the Carib 

News Foundation to Members and the Standards Committee. Congressman Thompson certified inaccurate information to the Standards Committee. The counsel to the former Chair of the Standards 

Committee intervened in the review process in a way that both 

frustrated the process in 2007 and set a pattern of obfuscation that 

continued in 2008. Finally, the Standards Committee appears unaware of limitations on the ability of private foundations to pay for 

overseas travel by Members. 

112. For all these reasons, the Board concludes further review of 

this matter by the Standards Committee is appropriate. 


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EXHIBIT 1 

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EXHIBIT 2 

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CONFIDENTIAL 

Subject to the Nondisclosure Provisions of H. Res. 895 of the 110th Congress as Amended 

MOI – Page 1 of 4 OFFICE OF CONGRESSIONAL ETHICS 

OFFICE OF CONGRESSIONAL ETHICS 

UNITED STATES HOUSE OF REPRESENTATIVES 

Memorandum of Interview

In Re: Representative Thompson 

Review #: 09-2222; 09-2567; 09-4403; 09-3698; 09-6333 

Date: May 6, 2009 

Location: 2432 Rayburn HOB, Washington, D.C. 

Participants: Leo Wise 

Beth Horton

 

Summary: Representative Thompson attended the 13th Annual Caribbean Multinational 

Business Conference. We requested an interview with Representative Thompson and he 

consented. Representative Thompson was given an 18 U.S.C. § 1001 warning and he signed a 

written acknowledgement of the warning. Representative Thompson made the following 

statements in response to our questioning: 

1. He attended the 13th Annual Caribbean Multinational Business Conference in 2008. 

2. He stayed at the conference for 3 days. 

3. He recalled that he stayed in a standard room and that meals were provided at the 

conference. 

4. He was invited by the Rodneys. 

5. He stated that the Rodneys were newspaper people from NY. He knew of them through 

an affiliation with the Carib News community. The newspaper provides information 

about the Caribbean to people in NY. 

6. The Caribbean relates to his duties because there are significant issues regarding 

homeland security, human trafficking and drug issues. 

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7. Carib News paid for his travel (whoever is listed on the form). 

8. He made the decision to attend the conference. 

9. He has never been to any fundraiser for the Foundation. 

10. Jennifer, his scheduler, handled his travel. 

11. Once he decides that he is interested in a trip, Jennifer handles all the arrangements and 

works with the entity to work out the travel plans. 

12. He chooses flights based on what is going on in Congress. 

13. Jennifer generally provides him with a printout of available flights and he then chooses 

what will work with his schedule. 

14. He departed from Jackson, MS and arrived at the beginning of the conference on the 6th

of November. 

15. He does not recall the dinner but he would have attended the activities at the conference. 

16. He recalled that Rep. Payne attended the conference and he noted that if he was there, he 

would have spoken at the conference at some point, but he did not recall his speech. He 

stated that the time he spoke would be reflected on the program. 

17. He did not recall the first session of the conference but he would have attended. 

18. He recalled that Representative Kilpatrick spoke at the conference but he did not know 

when nor did he recall what she said. 

19. He did not recall the ribbon cutting and did not see himself in the picture of the ribbon 

cutting.

20. He attended a workshop regarding doing business in the U.S.

21. He also participated in a second session that dealt with homeland security issues. 

22. Generally, other government officials were at the session. 

23. He did not see a letter regarding the session. 

24. The signature on the post travel document is his. 

25. Members of his staff can also sign documents for him. 

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26. The travel form was put together between Marsha and Jennifer. 

27. The entity that sponsors the travel would provide the breakdown of expenses. He 

assumed that is what happened in this instance. 

28. He believed the information on the form to be accurate. He had no reason to disagree 

with the figures provided by the sponsor. Beyond meals, travel, and lodging there were 

no other expenses. 

29. He did not see any bill that would dispute the sponsor’s charges. 

30. He did not recall any sponsors, he remembered seeing people from companies but didn’t 

recognize them as sponsors. 

31. He did not recall Rep. Payne thanking any companies as sponsors. 

32. He did not recall Rep. Kilpatrick thanking sponsors. 

33. He had no personal knowledge of any of the representatives, the ’08 conference was one 

of the few conferences that he has attended where he didn’t know anyone prior to the 

conference. 

34. He stated that the Foundation paid for his travel. 

35. He was not aware if the government of St. Maarten paid for any expenses. 

36. He was not aware of any limitations on private foundation’s ability to pay for travel 

expenses.

37. His practice is to submit a travel request to the Standards Committee and if the request is 

approved then he would not assume there were any other issues. 

38. He has not had any contact with the Standards Committee regarding any travel issues. 

39. His understanding of Carib News is that it has a business interest in the Caribbean. 

40. He is not aware if the Carib News gave money to support the conference. 

41. He has not spoken with anyone about the conference. 

42. He is not aware of who the host of conference was, he did not see anything pertaining to 

the host. 

43. He was sure that someone from the government of St. Maarten was present but does not 

know any names. 

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44. He was not aware that the government played a role at the conference. 

45. There were various government officials from the islands at the conference. 

46. He is generally familiar with the House travel rules. 

47. He does not recall any specific briefing on travel. He relies on his request to the 

Standards Committee. If the Standards Committee raised any issue with regard to travel, 

he would not take the trip. He makes the decision to travel after receiving a letter from 

Standards.

48. He may have attended the ’07 conference, he could not recall for sure. 

49. He did not recall any ethics related issue regarding the ’07 conference. 

Beth Horton 

Investigative Counsel 

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EXHIBIT 4 

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CONFIDENTIAL 

Subject to the Nondisclosure Provisions of H. Res. 895 of the 110th Congress as Amended 

MOI – Page 1 of 4 OFFICE OF CONGRESSIONAL ETHICS 

OFFICE OF CONGRESSIONAL ETHICS 

UNITED STATES HOUSE OF REPRESENTATIVES 

Memorandum of Interview

In Re: Representative of Citi 

Review #: 09-2567; 09-4403; 09-3698; 09-6333; 09-2222 

Date: March 17, 2009 

Location: AkinGump NYC - 399 Park Ave, New York, NY 

Time: approximately 2:00 to 4:00 p.m. 

Participants: Leo Wise 

 Omar Ashmawy 

Summary: The Representative of Citi was the Citi employee who managed their donation to the 

Thirteenth Annual Multinational Business Conference. The OCE requested an interview with 

the Representative of Citi and he consented. The Representative of Citi was given an 18 U.S.C. § 

1001 warning and he signed a written acknowledgement of the warning. The Representative of 

Citi made the following statements in response to questioning: 

1. The Representative of Citi was given an 18 U.S.C. § 1001 warning and consented to an 

interview. The Representative of Citi signed a written acknowledgement of the warning 

[attached], 

2. The Representative of Citi was laid off from Citibank on December 15, 2008. At the 

time he was laid off he was Community Relations Officer for Brooklyn and Staten Island

3. The Representative of Citi joined Citi in December 2003. He had previously worked for 

Chase in a similar capacity. Chase sponsored previous Caribbean Multinational Business 

Conferences. The Representative of Citi attended the conference when he was at Chase. 

Chase was the first financial institution to act as a sponsor at the conference.

4. When he came to Citi, he was told to “lead the charge” in terms of Citi’s participation in 

the conference. His superiors made the decision that Citi should participate.

5. The Representative of Citi’s direct supervisor was Eileen Aulden, New York State 

Director; she reported to Kathy Ebanks, Regional Director. Eric Eve, Senior Vice 

President for Community Relations headed the Representative of Citi’s department. Mr. 

Eve made the decision to support the conference and decided on the dollar amount. The 

Representative of Citi was in charge of managing Citi’s participation. 

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6. Citi donated $75,000 to support the conference. Citi was the only “senior” sponsor. The 

money was specifically for the conference. Citi did not put any specific restrictions on 

how the money could be used to support the conference. The check came from Citi’s 

sponsorship budget and was either made out to the Carib News or the Carib News 

Foundation.

7. In previous years the amount Citi donated was less. In 2007 it was $50,000. 

8. Karl Rodney chose the location of the conference. Governments in the region made bids 

to host the conference. 

9. The only person from the conference that the Representative of Citi dealt with was 

Rodney. The Representative of Citi met with Rodney on 5 occasions between May and 

November 2008. These meetings concerned the program at the conference and Citi’s 

participation in it. These meetings were not about the amount of Citi’s sponsorship or to 

negotiate that in any way. The Representative of Citi described this interaction as a 

“dialogue” with Rodney. Rodney was receptive to suggestions about the program. 

10. At these meeting the Representative of Citi would tell Rodney how he would like to 

“position” Citi at the conference. Citi participated in the luncheon, with Eve as a keynote 

speaker, and in workshops that fit their business. The lunch topic was set by Rodney.

The Representative of Citi then tried to “position” Eve in a complimentary way. The 

Representative of Citi recalls suggesting to Rodney that Citi could do a workshop on 

financial education.

11. Rodney did not present a written agenda for the conference before any of their 5 

meetings. The first time the Representative of Citi saw a written agenda was a week or a 

week and a half before the conference began in early November. The Representative of 

Citi recalls seeing a draft agenda. He was shown the draft agenda submitted to the 

Committee on Standards of Official Conduct [attached as Exhibit B] and said he saw 

some version of the draft agenda but not this specific one. He did recall seeing the panel 

entitled, “Creative Financial Solutions” on page 9 of Exhibit B. He said when he saw 

that panel he thought he could participate in the panel and talk about foreclosures. He 

“vetted” that topic internally at Citi and then proposed it to Rodney and Rodney agreed.

12. The Representative of Citi attended the dinner on Thursday night. He does not recall 

Congressman Payne speaking. 

13. The Representative of Citi participated in the ribbon cutting with members of Congress, 

host government officials and major sponsors on the Friday morning of the conference.

The Representative of Citi got sick on Friday and missed the evening event. 

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14. Eve did not have a sit-down meeting with the members of Congress in attendance to the 

Representative of Citi’s knowledge.

15. The Representative of Citi did not have more than “cursory” conversations with the 

Members of Congress who attended. He saw all members that attended more than once. 

He saw most of them on Friday and had seen everyone by Saturday.

a. The Representative of Citi recalled Congressman Rangel was there. The 

Representative of Citi thought he first saw him on Friday and saw him on 

Saturday. The Representative of Citi thought he saw him at different events.

b. The Representative of Citi saw Congressman Payne on more than one occasion. 

c. The Representative of Citi saw Representative Kilpatrick early on Friday. He 

does not recall her speaking.

d. The Representative of Citi saw Representative Thomson on Thursday; he saw him 

on more than one occasion. 

16. 300 to 350 people typically attended the event. It was open to anyone.

17. The conference was billed as the Carib News conference. Rodney is the publisher and 

CEO of the Carib News. In May or June one would start seeing advertisements for the 

conference on the back page of the Carib News. The Representative of Citi thought 

Citi’s check went to the Carib News Foundation but did not know what the Foundation 

did other than the conference. The Representative of Citi thought the conference was 

“totally” financed by the sponsors. He did not know if Carib News put up any money for 

the conference. 

18. The Representative of Citi said Rodney saw the conference as an opportunity to position 

the Carib News as the “voice of the Caribbean” which is how the paper markets itself in 

New York.

19. Citi saw the conference as offering Citi three benefits: (1) it sent a message to their 

partners; (2) it was a business opportunity; and (3) it was good for Citi’s image. 

20. The members of Congress lent the meeting “clout.” 

21. Sponsors also bought ad space in the Carib News. This was not part of their sponsorship 

of the conference. Citi bought ad space in the Carib News.

22. The Representative of Citi also knows Rodney from the Board of the University of the 

West Indies. Both he and Rodney are members and participate in telephone meetings 

and, occasionally, in in-person meetings. 

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We certify that this memorandum contains all pertinent matter discussed with the Representative 

of Citi on March 17, 2009. 

Leo J. Wise Omar Ashmawy 

Staff Director & Chief Counsel Investigative Counsel 

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CONFIDENTIAL 

Subject to the Nondisclosure Provisions of H. Res. 895 of the 110th Congress as Amended 

MOI – Page 1 of 4 OFFICE OF CONGRESSIONAL ETHICS 

OFFICE OF CONGRESSIONAL ETHICS 

UNITED STATES HOUSE OF REPRESENTATIVES 

Memorandum of Interview

In Re: Representative of IBM, Vice President Market Development, IBM 

Review #: 09-2567; 09-4403; 09-3698; 09-6333; 09-2222 

Date: May 8, 2009 

Location: IBM Offices, Washington, D.C. 

Participants: Leo Wise 

Beth Horton

Lisa Palluconi, Counsel for Government Programs for IBM 

Adrienne G. Rhone, Director Governmental Programs 

Summary: The Representative of IBM is the Vice President of Market Development for IBM. 

She was interviewed pursuant to Reviews 09-2567; 09-4403; 09-3698; 09-6333; and 09-2222.

The Representative of IBM helped arrange IBM’s participation at the 13th Annual Caribbean 

Multinational Business Conference in 2008; she also participated at the event. The OCE 

requested an interview with the Representative of IBM and she consented to an interview. The 

Representative of IBM was given an 18 U.S.C. § 1001 warning and she signed a written 

acknowledgement of the warning. The Representative of IBM made the following statements in 

response to our questioning: 

1. She attended the 13th Annual Caribbean Multinational Business Conference in 2008. 

2. She attended the conference to extend IBM to areas that were not currently being served.

She focuses on the Caribbean because of her division at IBM which is women and 

minorities. The Caribbean is an underdeveloped business unit for IBM. 

3. She first attended the conference in 2004, as a participant, to see if the conference would 

be a good fit for IMB to participate at as a sponsor. 

4. IBM was an entry level sponsor in ’05. 

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5. She dealt with Faye Rodney on conference matters. 

6. After her attendance in ’05, she received a thank you letter signed by the Rodneys that 

asked IBM to be a sponsor at the ’06 conference. 

7. IBM participated at the ’05, ’06, ’07 and ’08 conference. 

8. The Rodneys continued their prior practice and sent a thank you letter with a request for 

sponsorship after the ’07 conference for IBM to participate at the ’08 conference. 

9. The letter was sent to the Operations Executive and the decision to participate was 

decided as a team. Colin Ward, with ENI Systems, is one of IBM’s business partners 

who also went to the conference. 

10. The letter is the first communication regarding the conference. 

11. After the letter is received, the team manager negotiates participation at the conference. 

Negotiations included timing of sessions (day/time). She requested Friday, right before 

or right after lunch, for the IBM session. It was important to have attendance by 

individuals interested in technology. 

12. She also agreed to moderate the women’s breakfast sponsored by Macy’s. 

13. The team manager would have worked with the Rodneys regarding the break-out sessions. 

14. IBM controlled its own content for the session(s). 

15. The first year IBM sponsored the conference, the sponsorship level was $10,000. IBM 

sponsored the conference the following year at $15,000, and in ’08 the sponsorship went 

up to $20,000 after IBM received a request from Faye Rodney for an increase. The 

Representative of IBM initially counter-offered $18,000 but agreed to the $20,000 at the 

urging of Ms. Rodney. 

16. IBM has a methodical way of approving conference sponsorships. The letter from the 

Rodneys was received in July. 

17. She approved the check for the purchase order and released the check. Carib would have 

received the check in August or September. 

18. After the check is released, she and the business partner collaborate on the content of session. 

19. She and the business partner attended the conference. 

20. She has only seen the Rodneys at the conference. She has been invited to other events 

but has not accepted the invitations. 

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21. She received a call from Mr. Rodney about the article on the conference. 

22. She had no knowledge of the Foundation until this matter. 

23. She understood Carib News to be the sponsor. 

24. The $20,000 level of sponsorship is low for IBM in general. However, it is worth the 

presence and branding for small the small business unit practice. 

25. She thought IBM’s sponsorship was of the conference, she did not know the Foundation 

existed until this issue arose. Her department does not give to non-profit organizations, 

only to businesses.

26. The only parameters placed on the money for the conference was with respect to time 

slots and length of the sessions. 

27. She tells her team her preferences and the team works out the specifics with Carib. 

28. She does not recall seeing a specific document that listed the various levels of 

sponsorship.

29. Carib News provides the framework for the conference. Then she typically tells Carib 

what she wants and what they will pay. She was aware from the signage that other 

companies were larger sponsors. 

30. She arrived at the conference on Thursday and attended the opening reception. She 

attended a reception on Friday that was hosted by Citi and a breakout session. 

31. She noticed names of entities on the agenda from the web that she knew were not at the 

conference. 

32. She noted that the agenda also listed her breakout session on Saturday which was 

inaccurate. Her session was on Friday, so she knew the agenda could not have been the 

final agenda.

33. She seemed to recall seeing the agenda that was submitted to Standards. She noted that 

the 12:00pm session was accurate, but that she did not believe that the breakout listed on 

Saturday was accurate.

34. She attended the Macy’s breakfast on Saturday morning because it is a popular event.

She noted who was on the breakfast panel and who was not (names were listed on 

agenda). Michelle Patterson did not speak, Burnice Johnson was not on the panel and she 

was not sure if she even attended the conference. 

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35. She saw several of the Members who attended the conference. She was on the same 

flight as Representative Payne. She spoke to Representative Rangel at the reception. 

Representative Kilpatrick was on a panel with her. And Representative Thompson road 

to an off-sight event with her. She was sure that she spoke to Delegate Christensen. And 

she spoke to Sheila Jackson Lee at the awards night. 

36. The off-sight event was held at a separate hotel, it included local talent and a comedienne. 

37. She stated that Members did not attend the breakout sessions. 

38. She had a conversation with Rep. Thompson regarding the election. 

39. She left the conference on Sunday morning by 7:00am. 

40. She spoke with her team after the article regarding the conference came out. 

41. She also called Mr. Rodney after she saw the article; she stated that he told her that there 

was an investigation and assured her that he had done all that he was supposed to do and 

that he wanted to keep her as a sponsor. 

42. She understood sponsor to be financial sponsor of the conference. She assumed all of the 

companies whose logos appeared on the banner were sponsors. She assumed Carib News 

organized the conference.

43. She was not aware of how funding for the conference was handled. She assumed the 

payment from IBM went to pay for her breakout session and collateral expenses for the 

session.

44. Her registration fee was part of the sponsorship. She paid for her room and all travel costs. 

45. There were less that 300 people at the conference. 

46. When she registered for the conference, she received a badge that allowed access to 

buffets during the meetings. 

47. The registration fee for the conference in ’05 was $750.00. 

48. She was not aware of the ’08 registration fee.

Beth Horton 

Investigative Counsel 

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OFFICE OF CONGRESSIONAL ETHICS 

UNITED STATES HOUSE OF REPRESENTATIVES 

Memorandum of Interview

In Re: Representative 1 of the Verizon Foundation 

Review #: 09-2567; 09-4403; 09-3698; 09-6333; 09-2222 

Date: March 23, 2009 

Location: Verizon Offices, Washington, DC 

Participants: Leo Wise 

Omar Ashmawy 

Beth Horton 

David Kass, Assistant General Counsel Compliance 

James C. Wilson, Vice President and Associate General Counsel Compliance 

Summary: Representative 1 of the Verizon Foundation is the President and the Strategic 

Director for Philanthropy of the Verizon Foundation. He was interviewed pursuant to Reviews 

09-2567; 09-4403; 09-3698; 09-6333; and 09-2222. Representative 1 of the Verizon Foundation 

participated at the 13th Annual Caribbean Multinational Business Conference in 2008. We 

requested an interview with Representative 1 of the Verizon Foundation and he consented to an 

interview. Representative 1 of the Verizon Foundation was given an 18 U.S.C. § 1001 warning, 

signed a written acknowledgement of the warning. Representative 1 of the Verizon Foundation 

made the following statements in response to our questioning: 

1. Representative 1 of the Verizon Foundation is currently the President of the Verizon 

Foundation (“the Foundation”) and Strategic Director for Philanthropy. His duties 

involve budget planning and implementation and governance for the foundation.

Representative 1 of the Verizon Foundation has significant decision-making authority 

over grants issued by the foundation. He approves all grants in excess of $25,000 and all 

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grants funded more than two years in a row. He has been with the foundation and acting 

as President for the past five years. 

2. The Foundation is funded through a corpus donated by Verizon and through public 

donations under Verizon Reads, a program that is offered as part of customer billing 

statements. The Foundation approves approximately 2,900 grants (totaling 67 million) 

through a competitive loan application process. The Foundation’s online loan application 

process has specific approval requirements, including a quarterly “impact report.” 

3. The Foundation funded the Carib News Foundation for the first time in 2008, the grant 

was issued to provide funding for the 13th Annual Caribbean Multinational Business 

Conference (“the Conference”). Representative 1 of the Verizon Foundation approved 

the Carib News Foundation grant. Representative 2 of the Verizon Foundation was the 

Foundation’s contact person for the Conference. Representative 1 of the Verizon 

Foundation did not interact with Karl Rodney or anyone at Carib News regarding the 

Foundation’s participation at the Conference. Both Representative 1 of the Verizon 

Foundation and Representative 2 of the Verizon Foundation attended the conference. Mr. 

Rodney invited Representative 1 of the Verizon Foundation to speak at the Conference 

and subsequently applied for a grant from the Foundation. 

4. Representative 1 of the Verizon Foundation and Mr. Rodney are both members of the 

board of the Foundation for the University of the West Indies. The two men interacted at 

board meetings four times per year. Representative 1 of the Verizon Foundation stated 

that he may also have spoken to Mr. Rodney 1-2 other times prior to the Conference 

regarding how the Foundation could showcase its Thinkfinity program. He also stated 

that he may have spoken to Mr. Rodney once after receiving his letter of invitation for the 

Conference. He does not recall Mr. Rodney “pitching” the conference to him. 

Representative 1 of the Verizon Foundation stated that the Foundation would not have 

participated at the Conference unless he could speak on educational issues.

Representative 1 of the Verizon Foundation believed the Conference would be a good 

opportunity to showcase the Foundation’s Thinkfinity program.

5. Mr. Rodney was aware of the Foundation’s educational work through his interaction with 

Representative 1 of the Verizon Foundation at board meetings for the Foundation of the 

University of West Indies. Representative 1 of the Verizon Foundation stated that while 

he had spoken with Mr. Rodney regarding the Thinkfinity program, he did not make any 

type of informal commitment to fund the Conference. 

6. Representative 1 of the Verizon Foundation believed that there were three levels of 

sponsorship for the Conference, the highest being $50,000 and the lowest being $25,000.

However, he does not recall seeing any specific document(s) setting out the different 

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levels of sponsorship. He stated that he was not interested in sponsorship at the $50,000 

level but later decided on a $35,000 grant donation. When asked what the Foundation 

received at the Conference for the $35,000, Representative 1 of the Verizon Foundation 

stated signage and visibility. Representative 1 of the Verizon Foundation stated that the 

Foundation often provides such support for conferences, including the NAACP 

conference and National Urban League Conference.

7. Representative 1 of the Verizon Foundation was provided 3 venues at the Conference to 

speak about the Thinkfinity program. The Foundation believed participation at the 

Conference would provide exposure to English speaking Caribbean individuals who have 

connections to universities in New York.

8. The Foundation is required to issue grants only to 501(c)(3) entities. The Foundation 

could not make a donation to a corporation. Representative 1 of the Verizon Foundation 

was somewhat familiar with the Carib News paper; he has been featured in the paper and 

Verizon has advertised in the paper. Representative 1 of the Verizon Foundation was not 

aware of Carib News Charities until the entity applied for a grant. He believed Carib 

News Charities was the same entity as Carib News Foundation. He is not aware of any 

other work the Carib News Charities/Foundation is involved in other than the conference.

Mr. Rodney did not talk about the Carib News Charities/Foundation at board meetings. 

9. Representative 1 of the Verizon Foundation arrived at the Conference on Thursday 

afternoon and departed on Saturday morning. Representative 1 of the Verizon 

Foundation stated that he went to make his speech and promptly left the event.

Representative 1 of the Verizon Foundation spoke 3 times on Friday; he was 

acknowledge at the welcome event on Friday morning and he participated in a 

demonstration on Thinkfinity in the afternoon. It is not clear from Representative 1 of 

the Verizon Foundation’s remarks what other time he spoke at the Conference. He was 

invited to speak on Saturday but he did not feel that an extra day was necessary. 

10. Representative 1 of the Verizon Foundation recalled seeing and speaking to Congressman 

Rangel. The Congressman mentioned Alltel and told him to remind his CEO to keep in 

mind the needs of the minority community. Representative 1 of the Verizon Foundation 

stated that he had no other contact with Members at the Conference. He did not know 

Delegate Christenson, Congressman Thompson, Congressman Payne and was not sure 

whether he saw Congresswoman Kilpatrick (he was not sure who she is). He does recall 

that one lady stated that she would love to see the Thinkfinity program in her state. 

Representative 1 of the Verizon Foundation was accompanied by Representative 2 of the 

Verizon Foundation 90% of the time he was at the Conference; he was not aware of any 

contact between Representative 2 of the Verizon Foundation and any Members.

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11. Representative 1 of the Verizon Foundation received an advance copy of the agenda for 

the conference. The copy indicated that the Foundation was scheduled for two days of 

activities. He requested that the Saturday meetings be canceled or moved to Friday. He 

had not seen the agenda that Mr. Rodney submitted to the Ethics Committee for travel 

approval. He stated that advance copies of the agenda were common, most organizations 

provided the same level of detail with other conferences. He believed that he had seen 

more than one copy of the agenda. The agendas that were sent to him focused on the 

Foundation’s participation and not the entire conference.

12. Representative 1 of the Verizon Foundation was asked if it was typical to have an agenda 

that listed speakers without identifying their employer/affiliations. He was not sure and 

didn’t remember if the drafts he had seen included his title; he was more concerned with 

having a sense of what he would be doing at the Conference.

13. Representative 1 of the Verizon Foundation spoke with Mr. Rodney prior to the 

Conference to cancel the programs he was slated to speak at on Saturday (this was his 3rd

call regarding the Conference – 1st call was regarding invitation, 2nd call was to discuss 

his participation, 3rd was to cancel Saturday programs). Mr. Rodney was receptive to 

Representative 1 of the Verizon Foundation’s request and the Saturday program was 

cancelled.

14. The Foundation paid all travel expenses for Representative 1 of the Verizon Foundation.

He did not see the check the Foundation issued for the Conference or the confirmation 

letter from Mr. Rodney. Representative 1 of the Verizon Foundation met with Mr. 

Rodney following the conference at a board meeting for the Foundation for the 

University of West Indies. He also had breakfast with Mr. Rodney at which time they 

briefly discussed the Conference. According to Representative 1 of the Verizon 

Foundation, Mr. Rodney was upset over the New York Post article regarding the 

Conference. Representative 1 of the Verizon Foundation stated that Mr. Rodney felt the 

article was misleading and that he had done everything that he was supposed to do 

regarding receiving approval from the Ethics Committee. Representative 1 of the 

Verizon Foundation stated that he and Mr. Rodney did not spend much time speaking 

about the matter. He felt that Mr. Rodney wanted him to know that he was diligent 

about following rules. When asked if he knew what rules Mr. Rodney was speaking 

about, Representative 1 of the Verizon Foundation stated that he did not know which 

rules he was referring to.

15. Prior to his work with the Foundation, Representative 1 of the Verizon Foundation was 

with Government Affairs with Verizon, his former position did not involve lobbying. His 

position involved Strategic Alliance, he was responsible for working with non-profits 

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across the country. He dealt with policy issues regarding universal service. He did not 

interact with regulators. 

16. Representative 1 of the Verizon Foundation met with Eric Eve with Citi 2-3 weeks prior 

to our interview, they were both attending a meeting with the head of the NAACP. He 

did not speak to Mr. Eve about the Conference although they did speak about scrutiny on 

Citi related to TARP funding. He has not had any contact with the Representative of Citi 

from Citi. 

Beth Horton 

Investigative Counsel 

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OFFICE OF CONGRESSIONAL ETHICS 

UNITED STATES HOUSE OF REPRESENTATIVES 

Memorandum of Interview

In Re: Representative 2 of the Verizon Foundation 

Review #: 09-2567; 09-4403; 09-3698; 09-6333; 09-2222 

Date: March 23, 2009 

Location: Verizon Offices, Washington, DC 

Participants: Leo Wise 

Omar Ashmawy 

Beth Horton 

David Kass, Assistant General Counsel Compliance 

James C. Wilson, Vice President and Associate General Counsel Compliance 

Summary: Representative 2 of the Verizon Foundation is the National Program Director for the 

Verizon Foundation and Vice President for Education & Technology for Verizon. He was 

interviewed pursuant to Reviews 09-2567; 09-4403; 09-3698; 09-6333; and 09-2222.

Representative 2 of the Verizon Foundation helped arrange the Verizon Foundation’s 

participation at the 13th Annual Caribbean Multinational Business Conference in 2008; he also 

accompanied Representative 1 of the Verizon Foundation to the event. The OCE requested an 

interview with Representative 2 of the Verizon Foundation and he consented to an interview.

Representative 2 of the Verizon Foundation was given an 18 U.S.C. § 1001 warning, signed a 

written acknowledgement of the warning. Representative 2 of the Verizon Foundation made the 

following statements in response to our questioning: 

1. Representative 2 of the Verizon Foundation is currently the National Program Director 

for the Verizon Foundation (“the Foundation”) and Vice President for Education & 

Training for Verizon. He works on educational literacy and technology innovations for 

the Foundation, 80% of his time is spent on Thinkfinity. He is the only person with an 

operational role in the program. 

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2. Representative 2 of the Verizon Foundation helped arrange the Verizon Foundation’s 

participation at 13th Annual Caribbean Multinational Business Conference (“the 

Conference”) in 2008; he also accompanied Representative 1 of the Verizon Foundation 

to the event. 

3. Representative 2 of the Verizon Foundation reviews repeat grant requests for the 

Foundation. When asked how the Carib News Foundation request came to his desk he 

stated that it was a result of conversations with Karl Rodney and Representative 1 of the 

Verizon Foundation. He was not sure which conversation occurred first. Representative 

1 of the Verizon Foundation was invited to speak at the Conference and either 

simultaneously or immediately after Representative 1 of the Verizon Foundation received 

the invitation, Representative 2 of the Verizon Foundation spoke with Mr. Rodney. 

4. Representative 2 of the Verizon Foundation believes that he spoke with Mr. Rodney in 

person at a meeting for the Foundation for the University of the West Indies. Mr. Rodney 

inquired about the application for the grant for the Conference. Representative 2 of the 

Verizon Foundation recalled Mr. Rodney stating that he had spoke with Representative 1 

of the Verizon Foundation and that he believed the Conference would be a good fit for 

the Foundation and would provide a good opportunity to communicate the Foundation’s 

program Thinkfinity. 

5. The Verizon Foundation also supports the Foundation for the University of the West 

Indies. Representative 2 of the Verizon Foundation has interacted with Mr. Rodney 

regarding the Foundation for the University of the West Indies. 

6. Representative 2 of the Verizon Foundation also had previous interactions with Mr. 

Rodney at dinner and business meetings related the American Fund and to the publication 

of articles on the Foundation’s Thinkfinity program. 

7. Representative 2 of the Verizon Foundation will have been with the Foundation 3 years 

in October. 

8. Representative 2 of the Verizon Foundation believes he began talking with Mr. Rodney 

about the Conference sometime in the summer. He spoke with Mr. Rodney about the 

grant application. He described to Mr. Rodney the cyber grant process and explained 

what needed to be provided in the grant application. The system requires applicants to be 

501 (c)(3) entities.

9. The head of Governance and Compliance for Verizon verifies whether applicant is a 

registered 501(c)(3). A grant request from a non 501 (c)(3) would be removed from the 

system; the request would not be forwarded to Representative 2 of the Verizon 

Foundation. The Foundation’s grant approval process is formal. Representative 2 of the 

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Verizon Foundation stated that he could show a specific interest in a proposal but could 

not give any type of commitment to an applicant. 

10. Mr. Rodney would be required to provide a deck of the “07 conference, a description of 

the purpose of the conference and a tentative agenda for the cyber application. 

11. Representative 2 of the Verizon Foundation spoke with Mr. Rodney approximately 8-10 

weeks prior to the conference at which time they discussed the level of sponsorship the 

Foundation was interested in funding. 

12. Mr. Rodney described 3 levels of sponsorship to Representative 2 of the Verizon 

Foundation. Representative 2 of the Verizon Foundation stated that this was typical of 

corporate sponsorships at other conferences. 

13. Mr. Rodney offered the Foundation a $50,000 sponsorship, which was the gold level. 

Representative 2 of the Verizon Foundation believes there was also a platinum level at 

$75,000. He believes that Mr. Rodney showed him a 2007 deck with 3 levels (platinum 

at $75,000, gold at $50,000, and silver at $25,000) prior to a scheduled interview of 

Representative 1 of the Verizon Foundation.

14. Representative 2 of the Verizon Foundation explained to Mr. Rodney that the Foundation 

wished to negotiate a level of funding other than what was being offered. The amount of 

$35,000 was decided upon by the Foundation. 

15. When asked what the Foundation would receive for its funding, Representative 2 of the 

Verizon Foundation stated that they would receive signage but that the Foundation was 

not specifically interested in a “quid pro quo” reciprocation, the Foundation merely 

wanted to disseminate information about its Thinkfinity program. Representative 2 of the 

Verizon Foundation stated that the Foundation does not do business in the Caribbean.

16. Representative 2 of the Verizon Foundation stated that Representative 1 of the Verizon 

Foundation made an introductory speech but that he was not sure whether the speech was 

included in the Foundation’s sponsorship level; the speech was not pre-set in the 2007 

sponsorship deck.

17. Representative 2 of the Verizon Foundation spoke with Mr. Rodney approximately once 

a week for 6-7 weeks prior to the conference to discuss Verizon’s participation/logistics/ 

capacity for web casts at the conference – contact included phone calls and emails. 

Contact increased as conference approached. 

18. When asked how Verizon decided on $35,000 sponsorship, Representative 2 of the 

Verizon Foundation stated that he received a call from the Carib staff regarding the 

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conference. The Foundation was asked to sponsor at the $50,000 level, a $35,000 

counter-offer was made to Mr. Rodney, which he accepted. 

19. Conversations regarding sponsorship levels began about 8-10 weeks prior to the 

conference with the final dollar figure being determined approximately 2 weeks prior to 

the conference. 

20. Representative 2 of the Verizon Foundation spoke with Patricia with Carib regarding 

sponsorship, she thought the Foundation was sponsoring at the $50,000, Representative 2 

of the Verizon Foundation explained that the amount was $35,000. When asked if Karl 

Rodney was upset with the sponsorship level, Representative 2 of the Verizon 

Foundation answered that he was not upset. 

21. Representative 2 of the Verizon Foundation worked on the conference before Carib 

submitted application for funding which he stated was not unusual. 

22. Representative 2 of the Verizon Foundation stated that he saw early drafts of the agenda 

prior to the conference, and then saw final draft at conference. 

23. An early draft was shared with him in order for him to staff and notify Representative 1 

of the Verizon Foundation of his speaking times. 

24. He did not recall seeing any affiliation information on the early draft, he believes 

affiliations might have appeared on final draft. He did ask that any information be 

included on final draft after reviewing the earlier version. 

25. Representative 2 of the Verizon Foundation prepared 2 versions of the Foundation’s role 

at the conference. 

26. The topics for the conference were decided through dialog between himself and Karl 

Rodney with some prior comments from Representative 1 of the Verizon Foundation.

Mr. Rodney was aware of the Thinkfinity program. Representative 2 of the Verizon 

Foundation suggested web casts. 

27. Representative 2 of the Verizon Foundation thought that Representative 1 of the Verizon 

Foundation and Mr. Rodney framed the Foundation’s participation at the conference. 

28. Town Hall event was Mr. Rodney’s idea. 

29. Representative 2 of the Verizon Foundation believes that Mr. Rodney was trying to bring 

together various corporate interests to create a dialogue about social and economic issues 

that would benefit both the Caribbean and the U.S. 

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30. Representative 2 of the Verizon Foundation stated that Carib News Foundation was the 

only charitable entity that he was aware of, it was the listed entity in the grant application. 

31. The question arose as to who sponsored conference, Representative 2 of the Verizon 

Foundation stated that he was aware that Carib News was a for-profit entity, so he asked 

who was the sponsor. If the sponsor was Carib News, the Foundation could not 

participate as a sponsor.

32. Representative 2 of the Verizon Foundation stated that he did not see the check that went 

to the Conference, it would have been generated and sent through the internal system. 

33. Representative 2 of the Verizon Foundation did not recall seeing the name Carib News 

Charities Inc. 

34. Representative 2 of the Verizon Foundation saw an early draft of the grant application but 

does not recall seeing the final version. He was not responsible for final approval. 

35. Kathy Browne, Senior VP for Corporate Responsibility would have approved the grant. 

36. Representative 2 of the Verizon Foundation spent 2.5 days at the conference, he arrived 

on Thursday evening, participated at the conference on Friday and departed on Sunday. 

37. Representative 2 of the Verizon Foundation and Representative 1 of the Verizon 

Foundation participated in the welcome remarks on Friday morning, the plenary session, 

and in a roundtable meeting with educational ministers. 

38. Mr. Rodney arranged these meetings, the webcast did not take place. 

39. Representative 2 of the Verizon Foundation did not attend the conference on Saturday or 

Sunday. He also left the hotel after the Foundation completed its presentations. 

40. When asked about the Town Hall meeting, Representative 2 of the Verizon Foundation 

stated that Karl Rodney suggested that the Foundation speak about the Thinkfinity 

program, the opening remarks framework was also suggested by Mr. Rodney, Mr. Eve 

was to give introductory remarks and then Representative 2 of the Verizon Foundation 

was to speak.

41. There was a back and forth discussion about the plenary session between Representative 

2 of the Verizon Foundation and Mr. Rodney to determine what role the Foundation 

would play in conjunction with the President of Medgar Evers College. The topic was 

technology supporting education.

42. There was no discussion regarding scheduling sessions to benefit US companies. 

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43. Representative 2 of the Verizon Foundation stated that he did not have any contact with 

Members of Congress other than a possible introductory handshake. 

44. Representative 2 of the Verizon Foundation saw Representatives Kilpatrick, Rangel and 

the former head of the NAACP at the conference, along with other governmental officials 

from other countries. He also recalled seeing Delegate Christensen and Representative 

Payne. Representative 2 of the Verizon Foundation did not know Representative 

Thompson. 

45. Representative 2 of the Verizon Foundation interacted with Mr. Rodney after the 

conference to discuss the American Fund and the University of the West Indies. He did 

not discuss the conference with Mr. Rodney. 

46. Representative 2 of the Verizon Foundation believes that he may have received a thank 

you letter from Mr. Rodney for participating at the conference. 

47. He did not see the contribution-sponsorship letter. 

48. Representative 2 of the Verizon Foundation was aware of Mr. Rodney’s Foundation, and 

the fact that it sponsored the conference. He also believed Mr. Rodney’s Foundation 

performed social work for boys and girls club events and that it worked with the 

American Fund for the University of the West Indies. He was not sure why he felt that 

Rodney’s Foundation was involved with these other events. 

49. Representative 2 of the Verizon Foundation stated that the Foundation did not place any 

restrictions on the funding it provided to the conference through its grant, the use would 

have been specified in the grant application/guidelines. 

Beth Horton 

Investigative Counsel 

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OFFICE OF CONGRESSIONAL ETHICS 

UNITED STATES HOUSE OF REPRESENTATIVES 

Memorandum of Interview

In Re: Representative 1 of Macy’s 

Review #: 09-6333; 09-2567; 09-4403; 09-3698; 09-2222 

Date: May 27, 2009 

Location: 11 Penn Plaza 

 New York, NY 10001 

Time: 11:10pm to 12:00 p.m. (approximately) 

Participants: Leo Wise 

 Omar Ashmawy 

Summary: Representative 1 from Macy’s is the Senior Vice President of Government and Consumer 

Affairs and Diversity Vendor Development at Macy’s, Inc. He was interviewed pursuant to Review 

09-2567; 09-4403; 09-3698; 09-6333; and 09-2222. The OCE requested an interview with 

Representative 1 from Macy’s and he consented to an interview. Representative 1 from Macy’s was 

given an 18 U.S.C. § 1001 warning and signed a written acknowledgement of the warning. 

Representative 1 from Macy’s made the following statements in response to our questioning: 

1. Representative 1 from Macy’s met Karl and Faye Rodney in 1996. As a result of the 

large Caribbean Community in New York City and Macy’s commercial interests in the 

Caribbean region, Representative 1 from Macy’s asked Macy’s advertizing division to 

consider the CaribNews newspaper. 

2. The first conference he attended was in 1998 in St. Lucia. He attended as a participant.

At the time, Macy’s was considering a store in Puerto Rico and so Representative 1 from 

Macy’s was especially interested in business in the region. He was impressed by how 

many government officials from the Caribbean region were present at the conference and 

by what they had to say about developing relationships with the United States.

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3. In the ensuing years, Macy’s became a sponsor. The conference was a place where the 

company looked for vendors and designers. It was also a place where they could hear 

from U.S. legislators about their thoughts on the region. It was also a place for 

Representative 1 from Macy’s to connect with U.S. companies who were attending. 

4. Macy’s first sponsored the conference in 2000. Over the years they have sponsored the 

event on an annual basis at varying levels, ranging from $10,000 to $35,000. As 

women’s issues are particularly important to Macy’s, given their clientele, their 

sponsorship focuses on the conference’s “Women’s Power Breakfast.” The event was 

described as very lavish. All attendee of the breakfast also get a Macy’s tote bag.

5. In 2008, Macy’s contribution to the conference was $35,000 is cash and an in-kind 

contribution of 400 tote bags. The total value of the in-kind contribution was $4,620.

The money was earmarked specifically for the conference. 

6. As a sponsor, Macy’s was given the opportunity to have a representative make opening 

remarks, to have representation at the Women’s Power Breakfast, have input into who the 

speaker at the breakfast will be, and attend the closed door session with Members of 

Congress and officials from the Caribbean governments. Representative 1 from Macy’s 

did in fact attend the closed door session in 2008. He recalled that other corporate 

sponsors also attended the meeting, but he could not recall which ones. 

7. Representative 1 from Macy’s recalled interacting with Representative Payne, 

Representative Kilpatrick, Representative Thompson, Representative Rangel, and 

Delegate Christensen. His interactions were all social in nature. 

8. Representative 1 from Macy’s was not aware of any other events sponsored by or 

planned by the CaribNews Foundation. With the exception of the conference, he was not 

aware of any other instances when Macy’s supported a CaribNews Foundation event.

Given Representative 1 from Macy’s position within the company, it is very likely he 

would know if Macy’s had done so. 

I prepared this Memorandum of Interview on May 28, 2009 after interviewing Representative 1 

from Macy’s on May 27, 2009. I certify that this memorandum contains all pertinent matter 

discussed with Representative 1 from Macy’s on May 27, 2009. 

 Omar Ashmawy 

 Investigative Counsel 

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Page 1 of 6 OFFICE OF CONGRESSIONAL ETHICS 

OFFICE OF CONGRESSIONAL ETHICS 

UNITED STATES HOUSE OF REPRESENTATIVES 

Memorandum of Interview

In Re: Staff Member 1 of Congressman Rangel’s Office 

Review #: 09-6333; 09-2567; 09-4403; 09-3698; 09-2222 

Date: May 27, 2009 and May 28, 2009 

Location: Washington, DC (via telephone on May 27, 2009) and at Rayburn HOB 354 (on

 May 28, 2009) 

Time: 4:10pm to 5:30 p.m. (approximately) and 3:30pm to 4:00pm (approximately) 

Participants: Leo Wise 

 Omar Ashmawy 

Summary: Staff Member 1 of Congressman Rangel’s Office is currently the chief of staff of 

Representative Charles Rangel, a Member of the United States House of Representatives 

representing the Fifteenth District of New York. He was interviewed pursuant to Review 09-

2567; 09-4403; 09-3698; 09-6333; and 09-2222. We requested an interview with Staff Member 

1 of Congressman Rangel’s Office and he consented to an interview. Staff Member 1 of 

Congressman Rangel’s Office’s counsel was present. Staff Member 1 of Congressman Rangel’s 

Office made the following statements in response to our questioning: 

1. Staff Member 1 of Congressman Rangel’s Office was given an 18 U.S.C. § 1001 warning 

and consented to an interview. Staff Member 1 of Congressman Rangel’s Office signed a 

written acknowledgement of the warning. 

2. Staff Member 1 of Congressman Rangel’s Office did not attend the 13th Annual Caribbean 

Multi-National Business Conference although he received an invitation. In response to a 

Request for Information by OCE, Staff Member 1 of Congressman Rangel’s Office looked 

for Representative Rangel’s invitation to the conference, but could not find it. He had 

thought Representative Rangel had received one, but because he could not find the 

invitation he now thinks that Representative Rangel did not receive one. 

3. Representative Rangel could have been invited orally as he has been attending the 

conference for years and was seen almost as a partner. He attends the conference because 

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he is dedicated to strengthening the relationships between the Caribbean community, the 

African-American community of New York City and in general, and the United States. 

4. The question of whether Representative Rangel would attend the conference in 2008 was 

a difficult one because of the negative press he had received throughout the preceding 

summer. Representative Rangel was cautious about attending because he didn’t want to 

be a target for additional negative publicity, but Staff Member 1 of Congressman 

Rangel’s Office and others on the Member’s staff argued that he should go to the 

conference. They argued that if Representative Rangel did not attend he would be 

rejecting the friends with whom he helped build the conference and that the Member had 

to stand up and do the right thing despite the possible negative publicity. 

5. Ultimately, Staff Member 1 of Congressman Rangel’s Office and his staff persuaded the 

Member to attend. Representative Rangel decided to keep a low profile and, unlike in 

past years, staff would not attend the conference with the Member. 

6. Staff Member 1 of Congressman Rangel’s Office stated that the CaribNews Foundation 

invited the Member. The CaribNews Foundation is the charitable arm of the newspaper. 

When the rules changed in 2007 and corporations could not be involved as before – i.e. 

direct contributions to the conference – there was “talk” about how to do the conference 

in light of the new rules. 

7. According to Staff Member 1 of Congressman Rangel’s Office, there was “talk” that the 

Rodneys needed an entity to create a common fund so that the corporate money could be 

used to pay for the conference and that the CaribNews Foundation could be used for that 

purpose.

8. Staff Member 1 of Congressman Rangel’s Office initially stated that he did not remember 

how he was aware of this “talk.” He stated that part of it was his reading of the rules and 

the supplemental material about how things get done. He then stated that “we” 

celebrated when Representative Susan Tubbs-Jones was made the chair of the Standards 

Committee in 2007 because she would try to create a way for Members of Congress to 

continue to attend the conference. Staff Member 1 of Congressman Rangel’s Office then 

stated that he was made aware of the “talk” through the Rodneys and that the Rodneys 

told Staff Member 1 of Congressman Rangel’s Office that Representative Tubbs-Jones 

was going to have her counsel, Dawn Kelly-Mobley, find a way to make the conference 

work. The Members would have a few more hoops to go through but “we” would find a 

way. Representative Tubbs-Jones would let Ms. Mobley know the conference was a 

priority and tell her to make it possible. Representative Tubbs-Jones made Ms. Mobley 

the point of contact on the issue of the conference. 

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9. Staff Member 1 of Congressman Rangel’s Office stated that Representative Rangel also 

mentioned that Representative Tubbs-Jones told him something similar. Staff Member 1 

of Congressman Rangel’s Office stated that there was talk about “keeping the conference 

going.” He also stated that “They gave us the framework to keep the conference going.” 

“They” referred to Ms. Mobley and Representative Tubbs-Jones. 

10. Staff Member 1 of Congressman Rangel’s Office did not remember any specific 

conversations with Ms. Mobley, but he would have had them because he would have 

wanted to make sure he followed her advice. He stated that the 2007 conversations about 

Standards Committee finding a way to keep the conference going may have also been 

with Patricia Louis, the Rodneys office manager. 

11. Regarding the structure of the CaribNews Foundation, Staff Member 1 of Congressman 

Rangel’s Office said that the role of the foundation was more formalized as a way to 

handle the new rules and that it would have come from the Standards Committee staff. 

The Rodneys were the first people to describe the new structure to Staff Member 1 of 

Congressman Rangel’s Office following their conversation with Ms. Mobley. The 

Rodneys told Staff Member 1 of Congressman Rangel’s Office that they could easily 

comply because they had always done the conference through the foundation. The 

Rodneys told him that it should have always been called the CaribNews Foundation’s 

conference. 

12. Before 2007, Staff Member 1 of Congressman Rangel’s Office new that the corporations 

had a role in the conference because the format was in part to bring businesses together. 

Members of Congress would talk policy, but the Members’ presence was the glamour 

part of the conference and a way to attract more people. However, policy was not the 

central focus of the conference. The central focus of the conference was business and 

increasing investment in the region. The Members of Congress drew government 

officials from the various Caribbean governments and these government officials drew 

the businesses. 

13. Staff Member 1 of Congressman Rangel’s Office was aware the involvement of other 

corporations like AT&T, Macy’s, Citi, etc because they were pretty consistent supports 

of the conference. It was clear they were supporters of the conference financially.

14. Staff Member 1 of Congressman Rangel’s Office did not talk to Representative Rangel 

about these matters because the Member does not require that level of detail and does not 

typically ask for specifics. 

15. Staff Member 1 of Congressman Rangel’s Office did not remember how he became 

aware of the 2007 rule changes and did not remember attending any briefings or training 

about the new rules. He thought he was aware of the limits on the number of days a 

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Member could attend an event paid for by an entity that employs a lobbyist, but he was 

not certain. Mr. Daley did not think he was aware of rules that made an entity that 

earmarked money for a trip a sponsor of that trip. 

16. In response to the question: At the time of the 2007/2008 conferences, how sponsor was 

defined? Staff Member 1 of Congressman Rangel’s Office stated that the New York 

CaribNews Foundation was the sponsor of the conference because they were putting on 

the conference with money from a general fund that would pay for the conference. At 

that time he became conscious of a need for a 501(c)(3) to be the sponsor. 

17. Over the course of several phone calls– most often with Patricia Louis and Faye Rodney, 

Karl Rodney’s wife – Staff Member 1 of Congressman Rangel’s Office learned that he 

CaribNews Foundation was going to raise money from their traditional donors and other 

entities. 

18. The government of St. Maarten was the lynchpin of the 2008 conference. They were the 

conference’s host and they had specific requirements, as host, that were financial in 

nature. For instance, when a host government owns a conference center and/or hotel then 

they give the rooms and conference space for free. If they do not own space, then they 

have to arrange with a hotel to give rooms and space to the conference at an affordable 

amount. Other host government support includes police escorts, airport greeting services, 

and security services. They also host an opening reception and key components of the 

conference. 

19. Although it was not typical, Staff Member 1 of Congressman Rangel’s Office became the 

scheduler for Representative Rangel’s travel to the conference in 2008 because he played 

a part in convincing him to go. Staff Member 1 of Congressman Rangel’s Office made 

the reservations for the Member, but did not remember how he did it or whether the 

Representative had an e-ticket or a ticket in some other form. He did not remember 

receiving any airline itinerary documents, but it would have been common practice for 

him to receive one. 

20. Staff Member 1 of Congressman Rangel’s Office was shown the pre-travel clearance form 

submitted to the Standards Committee and stated that he filled it out and the Member 

signed it. He was shown the post-travel disclosure forms that were submitted to the 

Standards Committee and stated that he filled them out and the Representative signed them.

21. Staff Member 1 of Congressman Rangel’s Office initially said he got the information to 

fill out the post-travel forms from the Rodneys and stated that he remembered getting a 

memo from the Rodneys with the cost of the various aspects of the trip on it and that the 

memo was where he got the dollar amounts for the post-travel forms. He was then asked 

to explain why the numbers on the post-travel form matched the pre-travel form and not 

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the memo from the Rodneys. Staff Member 1 of Congressman Rangel’s Office then said 

that he could not say for sure that he got the numbers from the memo. He did not 

remember if the numbers were from the memo or from the pre-travel forms. He was not 

sure if he checked the cost of the airfare against the airline tickets or if he got it from the 

pre-travel documents or from the memo. 

22. Generally speaking, however, Staff Member 1 of Congressman Rangel’s Office would 

not look behind the numbers given by the Rodneys. He would assume the Rodneys were 

accurate. Staff Member 1 of Congressman Rangel’s Office was not certain how it was 

done, but thought that the accounting for the conference was simple and the information 

for each Member would be the same. He did not ask the Rodneys for supporting 

documentation for the numbers on the memo. 

23. After the conference, he spoke to Representative Rangel generally about the event. 

When the article by Susan Crabtree was published there was a lot of talk about the 

subject of the article with several people. Staff Member 1 of Congressman Rangel’s 

Office did not remember with whom he spoke. He then said that he spoke with the 

Rodneys and the Member. Overall there was an opinion that there could not be anything 

substantive to the article because the travel was approved by the Standards Committee. It 

was true that the corporations were at the conference, but they did not have anything to 

do with their Washington, DC agenda because that’s not who attended the conference. 

His conversations with Representative Rangel were brief and were limited to reassuring 

him that the office followed the rules and got approval for the travel. 

24. After the OCE review was initiated Staff Member 1 of Congressman Rangel’s Office 

called other members of the Congressional Black Caucus. Representative Rangel asked 

him to make the calls and to tell them that he would stand by them and offered his help. 

25. Staff Member 1 of Congressman Rangel’s Office recalled a conversation with 

Representative Carolyn Kilpatrick’s chief of staff, Kim Rudolph. Ms. Rudolph addressed 

the comments that Representative Kilpatrick made in which she thanked the sponsors of the 

conference. Staff Member 1 of Congressman Rangel’s Office explained Representative 

Kilpatrick’s statements to OCE by saying that that regardless of who the real sponsor of the 

event was, when Members thank the corporations it helps the Rodneys put on the 

conference -- even if the sponsors are not sponsors under the rule. Staff Member 1 of 

Congressman Rangel’s Office also remembered speaking to Shelly Thomas, Delegate 

Donna Christensen’s scheduler, but did not recall the specifics of the conversation. 

26. Staff Member 1 of Congressman Rangel’s Office was not aware of any limits on a private 

foundation paying for overseas travel. He did not know whether the CaribNews 

Foundation was a private foundation or a public charity. 

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27. Staff Member 1 of Congressman Rangel’s Office was shown a copy of Congressman 

Rangel’s itinerary and a receipt for an electronic ticket. Staff Member 1 of Congressman 

Rangel’s Office stated that he did not remember seeing it before, but that the itinerary 

was the type of document that would typically be placed in the Congressman’s briefing 

book so that he could provide the information at the airport in order to get his ticket.

Staff Member 1 of Congressman Rangel’s Office also pointed out that the receipt for the 

electronic ticket was the sort of document that would only be provided after the 

Congressman checked in for his flight. 

I prepared this Memorandum of Interview on May 28, 2009 after interviewing Staff Member 1 of 

Congressman Rangel’s Office on May 27, 2009. I certify that this memorandum contains all 

pertinent matter discussed with Staff Member 1 of Congressman Rangel’s Office on May 27, 

2009.

 Omar Ashmawy 

 Investigative Counsel 

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