" ! HOUSE OF REPRESENTATIVES 

111TH CONGRESS

1st Session 

REVIEW NO. 

09–3698 

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. 09–3698 


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U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON : 

1 

54–331 

" ! HOUSE OF REPRESENTATIVES 

111TH CONGRESS

1st Session 

REVIEW NO. 

2009

09–3698 

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 

Omar Ashmawy, Investigative Counsel 

Elizabeth Horton, Investigative Counsel 


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REPORT 

Review No. 09–3698 

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: Delegate Donna Christensen 

NATURE OF THE ALLEGED VIOLATION: There is substantial 

reason to believe that Delegate Donna Christensen’s participation 

in the 13th Annual Caribbean Multi-National Business Conference 

in St. Maarten, N.A. from November 6–9, 2008, her acceptance of 

reimbursement of expenses to attend that conference and the Member Post Travel Disclosure Form she 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 

Delegate Christensen. 

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. INTRODUCTION .......................................................................................... 5 

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

B. A Note on Culpability ....................................................................... 6 

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 DELEGATE CHRISTENSEN’S 

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

A. Delegate Christensen’s Knowledge of The Involvement of These 

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

B. CARIB NEWS also Sponsored Delegate Christensen’s Travel ..... 14 

C. Corporate Donations Were Earmarked for the Conference ........... 14 

D. Because Entities that Employ or Retain Lobbyists Sponsored 

the Event, Delegate Christensen’s Involvement Should Have 

Been Limited to One Day .............................................................. 18 

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 .............. 19 

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

12TH ANNUAL CARIBBEAN MULTI-NATIONAL BUSINESS CONFERENCE IN 2007 .................................................................................... 22 

IV. THE VALUE OF THE TRIP REPORTED ON THE MEMBER’S POSTTRAVEL DISCLOSURE FORM ................................................................ 39 

A. Representations from Carib News Foundation .............................. 40 

B. Information Required from the Congressional Traveler ................ 41 

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

PROHIBITED FROM PAYING FOR DELEGATE CHRISTENSEN’S 

TRAVEL ...................................................................................................... 44 


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FINDINGS OF FACT AND CITATIONS TO LAW 

Review No. 09–3698 

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 that a violation actually occurred. 

I. INTRODUCTON 

1. Delegate Donna Christensen attended the 13th Annual Caribbean Multi-National Business Conference in St. Maarten, N.A., 

from November 6–9, 2008. Delegate Christensen received funds 

from a private source to participate in the conference. 

A. SUMMARY OF ALLEGATIONS

2. There is substantial reason to believe that Delegate 

Christensen violated the requirement that she identify the ‘‘true, 

correct and accurate’’ sponsor of her travel ‘‘to the best of her 

knowledge’’ on her Member Post Travel Disclosure Form. While 

forms submitted to her office and the Standards Committee before 

the conference identified one entity as the sponsor—the Carib 

News Foundation—once at the conference, Delegate Christensen 

was presented with indications that other corporations—including 

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

were also sponsors. For instance, Delegate Christensen attended a 

session where her colleagues, in remarks, thanked ‘‘the sponsors’’ 

after the corporations were identified as such. She also participated 

in a ribbon cutting ceremony with representatives of the corporate 

entities. Those indications proved to be true—these corporations 

were in fact sponsors of Delegate Christensen’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. The 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 thenVerDate Aug 31 2005 14:37 Mar 09, 2010 Jkt 054331 PO 00000 Frm 00005 Fmt 6601 Sfmt 6601 P:\54-331\REVIEW~1\54-331.TXT 54-331

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Chair of the Standards Committee, and apparently without the 

knowledge of the staff attorney reviewing the trip, the documents identifying the 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 they were instructed to take 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 Delegate 

Christensen 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 Delegate 

Christensen violated House Rule 25 clause 5(h)(i)(1)(B) by underreporting the value of the travel reimbursements she 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 Delegate Christensen 

and her 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 Delegate Christensen and (4) whether, because of its tax status, the Carib News Foundation could lawfully pay for Delegate Christensen’s conference-related expenses. 

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

do not all involve conduct by Delegate Christensen to the same degree. 

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

or sponsors implicates the conduct of both Delegate 

Christensen and the Standards Committee. Delegate 

Christensen told the OCE she 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 Delegate 

Christensen arrived at the conference, however, she was confronted with information that other corporations were co-sponsors. That information, at least in 2008, does not appear to 


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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. 

have been before the Standards Committee when they initially 

approved the 2008 travel. 

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 Delegate 

Christensen. 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 Delegate 

Christensen provided as to the value of the reimbursement of 

her conference-related expenses most directly implicates her 

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, not the Standards Committee and not 

sponsors, to certify that the information on the form is ‘‘true, 

accurate and complete’’ to the ‘‘best of the Member’s knowledge.’’ Delegate Christensen saw the documents that showed 

the true value of her travel. Nonetheless, she certified inaccurate information on the post-travel disclosure form. 

d. Topic 4, limitations on Carib News Foundation’s ability to 

pay for overseas travel of government officials, does not implicate Delegate Christensen. 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 Delegate Donna Christensen, a Member of the United States House of 

Representatives from the Virgin Islands. 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. 

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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 

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. 

phase review commenced on April 6, 2009.3 The second-phase review was scheduled to end on May 21, 2009. 

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 DELEGATE CHRISTENSEN’S 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 Delegate 

Christensen violated the requirement that she identify the ‘‘true, 

correct and accurate’’ sponsor of her travel ‘‘to the best of her 

knowledge’’ on her Member Post Travel Disclosure Form. While 

forms submitted to her and the Standards Committee before the 

conference identified one sponsor—the Carib News Foundation— 

once at the conference, Delegate Christensen was presented with 

indications that other corporations were also sponsors. As will be 

discussed below, those indications proved to be true—these corporaVerDate Aug 31 2005 14:37 Mar 09, 2010 Jkt 054331 PO 00000 Frm 00008 Fmt 6601 Sfmt 6601 P:\54-331\REVIEW~1\54-331.TXT 54-331

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5 The ‘‘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 of October 21, 2008 pre-approving Delegate 

Christensen’s trip. 6 Member/Officer Post-Travel Disclosure Form signed by Delegate Donna M. Christensen 

(Dec. 22, 2008) (Exhibit 1 at 09–3698 0002). 7 Id. at 09–3698 0003 

tions were in fact sponsors of Delegate Christensen’s travel according to House travel rules because these corporations had donated 

funds specifically for the conference (i.e. earmarked funds). 

A. DELEGATE CHRISTENSEN’S KNOWLEDGE OF THE INVOLVEMENT OF

THESE CORPORATIONS IN THE CONFERENCE

17. On her Member Post-Travel Disclosure Form, Delegate 

Christensen 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. Delegate Christensen certified that this information was 

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


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

1 at 09–3698 0005). 9 Id. at 09–3698 0006. 10 Exhibit 1 at 09–3698 0007 

19. 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.8

20. 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.’’ 9

21. Rodney also certified that the information was ‘‘true, complete, and correct.’’ 10


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11 Letter from the Committee on Standards of Official Conduct to Delegate Donna 

Christensen (Oct. 16, 2008) (Exhibit 1 at 09–3698 0004). 12 Photographs taken at the 13th Annual Caribbean Multi-National Business Conference (Exhibit 5 at Exhibit 1 at 09–3698 0070–0078) (The Board notes that the source of this information 

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

Multi-National Business Conference (Exhibit 3 at 09–3698 0037––3698 0039) (The Board notes 

that the source of this information may have a bias, interest, or motive in this matter.). 14 Id. at 09–3698 0037. 15 Id. at 09–3698 0039. 16 Id. at 09–3698 0054. 

22. Prior to the conference, the Standards Committee approved 

the reimbursement of Delegate Christensen’s expenses by the Carib 

News Foundation.11

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

IBM, AT&T, and others, were identified as ‘‘sponsors.’’ 12

24. 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.13

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).14

25. Michael Flanigan, an executive from Citibank, spoke immediately after Mr. Rodney and described Citibank as the ‘‘lead sponsor of the premier event.’’ 15

26. 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.’’ 16


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17 Memorandum of Interview of Delegate Donna Christensen (May 4, 2009) (Exhibit 2 at 09– 

3698 0034). 18 Photographs taken at the 13th Annual Caribbean Multi-National Business Conference (Exhibit 5 at 09–3698 0070). 19 Memorandum of Interview of Delegate Donna Christensen (May 4, 2009) (Exhibit 2 at 09– 

3698 0033). 20 Photographs taken at the 13th Annual Caribbean Multi-National Business Conference (Exhibit 5 at 09–3698 0071). 

27. In an interview with the OCE, Delegate Christensen confirmed she attended this session of the conference.17

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

speaker’s podium where the individuals spoke.18

29. In her interview, Delegate Christensen stated when she arrived at the conference on Thursday she recalled seeing the banner 

and that a similar banner hung in all the conference rooms.19

30. After attending the morning session, Delegate Christensen 

confirmed that she participated in a ‘‘ribbon cutting’’ ceremony in 

which she and representatives from these corporations and the 

Leader of Government of St. Maarten, Commissioner Sarah 

Wescott-Williams stood for photographs. She is the individual partially photographed on the far right of the picture below.20


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21 Memorandum of Interview of Delegate Donna Christensen (May 4, 2009) (Exhibit 2 at 09– 

3698 0034). 22 Id. at 09–3698 00035. 23 Id. at 09–3698 00033. 

31. In an interview with the OCE, Delegate Christensen stated 

that she relied on the entity that invited her to the conference, the 

Carib News Foundation, to identify the sponsor of her trip and, further, that she relied on the Standards Committee, who pre-approved her trip, to determine if that information was accurate.21 As 

a result, Delegate Christensen told the OCE that the involvement 

of these corporations in the conference did not raise questions in 

her mind about whether the Carib News Foundation was the sole 

sponsor of the conference.22 However, Delegate Christensen did acknowledge that she was aware that the corporate entities identified 

had some financial role in the conference.23 She did not know if 

they gave directly to the Foundation or to the conference. She also 

stated that the Government of St. Marten paid for a reception, 

which included food, that she attended. 

32. 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 


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

1 at 09–3698 0007). 25 Letter from Joel Cohen, Counsel for Karl Rodney (May 18, 2009) (Exhibit 6 at 09–3698 

0081). 26 Letter from Carib News Foundation to Mr. Eric Eve, Citigroup, Inc. (Apr. 4, 2008) (Exhibit 

7 at 09–3698 0085) (a nearly identical letter was sent to IBM, AT&T, Pfizer, Verizon Foundation 

and others). 

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 circumstances, have access to information about the trip not available 

to the Standards Committee. In this instance, the Member 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. 

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

sponsors of the conference. 

B. CARIB NEWS ALSO SPONSORED DELEGATE CHRISTENSEN’S TRAVEL

34. 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.24

35. 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.’’ 25

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

Delegate Christensen’s trip. 

C. CORPORATE DONATIONS WERE EARMARKED FOR THE CONFERENCE

37. 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. 

38. 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.26


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27 Id. at 09–3698 0088–0102 

39. Attached to this solicitation letter was a PowerPoint presentation.27 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 


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28 Id. at 09–3698 0095–0098 

of sponsorship—in terms of the conference.28 In each instance, the 

sponsorship covers travel related expenses such as gala events and 

meals. 

40. 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) earVerDate Aug 31 2005 14:37 Mar 09, 2010 Jkt 054331 PO 00000 Frm 00016 Fmt 6601 Sfmt 6601 P:\54-331\REVIEW~1\54-331.TXT 54-331

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29 Letter from IRS to OCE (April 17, 2009) (Exhibit 8 at 09–3698 0107). 30 Id. at 09–3698 0108–0119. 31 Memorandum of Interview of the Representative of IBM (May 8, 2009) (Exhibit 9 at 09– 

3698 0123). 32 Documents submitted to the OCE by Citigroup (Exhibit 7 at 09–3698 0084). 33 Mr. 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. 34 Documents Submitted to the OCE by Verizon Foundation (Exhibit 10 at 09–3698 0127). 35 Memorandum of Interview of Representative 1 of Verizon Foundation (Mar. 23, 2009) (Exhibit 11 at 09–3698 0133). 

marked 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 2005.29 On its 2005 Form 990, the Carib 

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

expenses.30 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.31

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

NEWS for the conference.32

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

payment to the Carib News Charities 33 for the conference.34

43. 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.35


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36 Documents submitted by IBM to the OCE (Exhibit 13 at 09–3698 0150). 37 Memorandum of Interview of Representative 1 of Macy’s (Exhibit 20 at 09–3698 0241) 38 Interview with Investigative Counsel on May 22, 2009. 39 Documents submitted by American Airlines to the OCE (Exhibit 14 at 09–3698 0153–0157) 

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). 40 Memorandum of Interview of Representative of IBM (Exhibit 9 at 09–3698 0123); Memorandum of Interview of Representative 2 of the Verizon Foundation (Exhibit 12 at 09–3698 

0145); Memorandum of Interview of Representative of Citi (Exhibit 4 at 09–3698 0065); Memorandum of Interview of Representative 1 of Macy’s (Exhibit 20 at 09–3698 0241). 

44. 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.36

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

for the conference.37

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

the conference.38

47. 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.39 No other sponsor with whom we spoke placed restrictions 

on how or on whom their contribution could be spent.40 The only 

expectation was that the contribution would be used for expenses 

associated with the conference. 

D. BECAUSE ENTITIES THAT EMPLOY OR RETAIN LOBBYISTS SPON- SORED THE EVENT, DELEGATE CHRISTENSEN’S INVOLVEMENT

SHOULD HAVE BEEN LIMITED TO ONE DAY

48. 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). 


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41 House Ethics Manual at 92–93 citing (House Rule 25, clause 5(b)(1)(C)) (emphasis in original). 42 Clerk of the House of Representatives Lobbying Disclosure Report 2008 (excerpt) (Exhibit 

15 at 09–3698 0159–0164). 43 Member/Officer Post-Travel Disclosure Form signed by Delegate Donna M. Christensen 

(Dec. 22, 2008) (Exhibit 1 at 09–3698 0002–0003). 44 Letter from Leader of Government of St. Maarten, Commissioner Sarah Wescot-Williams, 

to Delegate Donna Christensen (Aug. 28, 2008) (Exhibit 1 at 09–3698 0011). 

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 attend 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 caseby-case basis to be practically required to participate in the oneday 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 41

49. Citigroup, IBM and Verizon employ or retain lobbyists.42

50. Delegate Christensen spent three days at the conference.43

51. There is substantial reason to believe that Delegate 

Christensen 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

52. The Government of St. Maarten was the host of the 2008 conference and the Leader of Government of St. Maarten personally 

invited Delegate Christensen to attend.44


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45 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. 46 Letter from Karl Rodney to Commissioner Sarah Wescott-Williams (Aug. 13, 2008) (Exhibit 

16 at 09–3698 0166). 

53. In that capacity, it provided in-kind 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.45

54. 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.’’ 46 These included: 


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47 Letter from Joel Cohen, Counsel for Karl Rodney (May 18, 2009) (Exhibit 6 at 09–3698 

0080–0081). 48 Id. 

55. 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.’’ 47 These contributions to the conference were all inkind, according to Mr. Rodney, and he did not provide an estimated 

value for them.48


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49 5 U.S.C. § 7342. 50 Memorandum of Interview of Delegate Donna Christensen (May 4, 2009) (Exhibit 2 at 09– 

3698 0031). 51 Id. at 09–3698 0030–0035. 52 House Ethics Manual (2008) at 92–93 (citing House Rule 25, clause 5(b)(1)(C)). 

56. 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.49

57. Delegate Christensen told the OCE that the Government of 

St. Maarten plays a number of roles in the conference, including 

participating in holding the conference.50

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

ANNUAL CARIBBEAN MULTI-NATIONAL BUSINESS CONFERENCE IN

2007 

58. As previously stated, Delegate Christensen told the OCE that 

she 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 her to the 

conference—the Carib News Foundation.51 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. 

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

so. 

60. 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.52 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. 

61. 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 

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


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

17 at 09–3698 0213) (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.). 54 E-mail from Dawn Kelly Mobley to Patricia Louis (Sept. 18, 2007, 12:57 PM EST) (Exhibit 

17 at 09–3698 0213). 55 E–mail from Patricia Louis to Dawn Kelly Mobley (Sept. 18, 2007) (Exhibit 17 at 09–3698 

0213) (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). 56 E-mail from Dawn Kelly Mobley to Patricia Louis (Sept. 18, 2007, 7:03 PM EST) (Exhibit 

17 at 09–3698 0212). 57 E-mail from Dawn Kelly Mobley to Patricia Louis (Sept. 19, 2007, 2:16 PM EST) (Exhibit 

17 at 09–3698 0212). 58 House Ethics Manual (2008) at 97–98. 

62. 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.53

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

and asked for ‘‘any information on your sponsor’s status.’’ 54

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

corporations as ‘‘sponsors’’ of the trip.55

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

these organizations have or retain a lobbyist’’ 56

66. 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.57 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.58 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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59 E-mail from Dawn Kelly Mobley to Patricia Louis (Sept. 19, 2007, 3:23 PM EST) (Exhibit 

17 at 09–3698 0212). 60 E-mail from Patricia Louis to Dawn Kelly Mobley (Sept. 21, 2007, 1:56 PM EST) (Exhibit 

17 at 09–3698 0210) 

67. 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.59

68. On September 21, 2007, Ms. Louis responded.60


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61 Private Sponsor Travel Certification Form (Sept. 21, 2007) (Exhibit 17 at 09–3698 0200). 62 Id. at 09–3698 0201. 

69. 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 1.61

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

and conducting the trip, in question 12.62 This is at least the second instance where the Carib News Foundation identified these 

corporations as the trip’s sponsors. 


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

17 at 09–3698 0197). 64 E-mail from Dawn Kelly Mobley to Patricia Louis (Sept. 25, 2007, 5:08 PM EST) (Exhibit 

17 at 09–3698 0197). 65 E-mail from Dawn Kelly Mobley to Patricia Louis (Oct. 3, 2007, 12:39 PM EST) (Exhibit 

17 at 09–3698 0194). 66 Private Sponsor Travel Certification Form (Sept. 21, 2007) (Exhibit 17 at 09–3698 0201). 67 Private Sponsor Travel Certification Form (Oct. 5, 2007) (Exhibit 18 at 09–3698 0216). 

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

Louis.63 The Board notes that Ms. Mobley stated she was ‘‘working 

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

with our staff attorney.’’ 

72. Later that same day, Ms. Mobley queried further.64 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.’’ 

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

Susan Olson was the staff attorney assigned to review the trip.65

74. 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 

12.66

75. However, as of October 5, 2007, it provided a different answer to question 12.67


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68 Id. at 09–3698 0220. 69 E-mail from Susan Olson to Patricia Louis (Oct. 10, 2007, 4:01 PM EST) (Exhibit 17 at 

09–3698 0182–0183). 

And the attached sheet provided the following information.68

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 69 (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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70 Committee on Standards of Official Conduct, Advisory Opinion (Oct. 27, 2006) (Exhibit 17 

at 09–3698 0206–0208). 71 Working Draft of the 13th Annual Caribbean Multi-National Business Conference Program 

(Oct. 3, 2007) (Exhibit 19 at 09–3698 0222–0238). 72 Id. at 09–3698 0228. 73 Id. at 09–3698 0234 

76. 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.70 The ‘‘Advisory Opinion’’ did 

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

as the e-mail seems to indicate. 

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

identified a ‘‘sponsor’’ for each event listed.71 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.’’ 72

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

Outreach—Education—Access and Collaboration.’’ 73


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74 E-mail from Patricia Louis to Dawn Kelly Mobley, George Dalley, and Shelley Thomas 

(Oct. 10, 2007, 5:56 PM EST) (Exhibit 17 at 09–3698 0188). 

78. 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.74

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 


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75 Memorandum 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). 76 E-mail from Dawn Kelly Mobley to Patricia Louis (Oct. 10, 2007, 6:49 PM EST) (Exhibit 

17 at 09–3698 0188). 77 Fax from Patricia Louis to Dawn Kelly Mobley (Oct. 11, 2007) (Exhibit 17 at 09–3698 

0185). 

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.75

79. Less than an hour later Ms. Mobley responded.76 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. 

80. Ms. Louis then faxed Ms. Mobley.77 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.’’ ). 


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

(Oct. 22, 2007) (Exhibit 21 at 09–3698 0244). 

81. 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.78 The Board 

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

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

of the corporate entity that had previously been identified as a 

‘‘sponsor.’’ 


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

(Oct. 3, 2007) (Exhibit 19 at 09–3698 0228). 80 Working Draft of the 13th Annual Caribbean Multi-National Business Conference Program 

(Oct. 22, 2007) (Exhibit 21 at 09–3698 0248). 81 Working Draft of the 13th Annual Caribbean Multi-National Business Conference Program 

(Oct. 3, 2007) (Exhibit 19 at 09–3698 0234). 82 Working Draft of the 13th Annual Caribbean Multi-National Business Conference Program 

(Oct. 22, 2007) (Exhibit 21 at 09–3698 0254). 83 Memorandum of Interview of Representative of Citi (Mar. 17, 2009) (Exhibit 4). 

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

being ‘‘sponsored’’ by Preferred Health Partners.79 Now it identifies 

them as merely a ‘‘participant.’’ 80

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

was previously identified as being sponsored by CITI.81 Now CITI 

is not even mentioned.82 The Board notes that the moderator was 

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

the conference.83


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

09–3698 0182). 85 E-mail from Susan Olson to Bill O?Reilly and Dawn Kelly Mobley (Oct. 12, 2007 9:29 AM) 

(Exhibit 17 at 09–3698 0182). 

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

that the corporations? substantive role in the conference changed 

in any way. 

85. 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.’’ 84 The Board notes that this is precisely the answer she 

had pre-cleared with Mobley. 

86. 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.85 Based on this email, it appears that Ms. Olson was unaware that Mobley had been 

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 


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86 Memorandum 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). 87 E-mail from Dawn Kelly Mobley to Patricia Louis (Oct. 12, 2007 9:59 AM EST) (Exhibit 

17 at 09–3698 0181). 88 E-mail from Dawn Kelly Mobley to Patricia Louis (Oct. 12, 2007 1:55 PM EST) (Exhibit 

17 at 09–3698 0181). 

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.86

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

Louis.87 The Board notes that Ms. Mobley counseled that these 

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

not help pay for the trip.’’ 

88. Later that day, Ms. Mobley sent Ms. Louis an additional email.88 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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89 E-mail from Susan Olson to Patricia Louis (Oct. 12, 2007 2:41 PM EST) (Exhibit 17 at 

09–3698 0176–0177). 

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

corporate entities previously identified as ‘‘sponsors.’’ 89


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

17 at 09–3698 0176). 91 Memorandum of Interview of Staff Member 1 of Congressman Rangel’s Office (May 27– 

28, 2009) (Exhibit 22 at 09–3698 0258). 92 Id. at 09–3698 0259. 93 Id. at 09–3698 0259. 

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

addressed to Ms. Olson.90 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. 

91. 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.91 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 2007.92 The staff member told the OCE that Congressman Rangel told him that the then-Chair had made similar 

statements to him.93 ’’ 

92. 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 


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94 Id. 95 Fax from Patricia Louis to Dawn Kelly Mobley (Aug. 20, 2008) (Exhibit 23 at 09–3698 

0264). 

Mrs. Rodney and that they represented this approach had come 

from Ms. Mobley on the Standards Committee.94

93. 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. 

94. 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. 

95. In fact, in 2008, Carib News Foundation again first submitted its document to Ms. Mobley.95 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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96 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

96. 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) 96 that requires Members to publicly disclose ‘‘trip expenses.’’ 

97. 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. 

98. There is substantial reason to believe that Delegate 

Christensen violated House Rule 25 clause 5(h)(i)(1)(B) by underreporting the value of the travel reimbursements she received to 


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

1 at 09–3698 0007). 

attend the 13th Annual Caribbean Multi-National Business Conference. 

A. REPRESENTATIONS FROM CARIB NEWS FOUNDATION

99. 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.97 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. 

100. 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. 


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98 Memorandum from Carib News Foundation to Delegate Christensen (Nov. 18, 2008) (Exhibit 1 at 09–3698 0012). 99 Member/Officer Post-Travel Disclosure Form signed by Delegate Donna M. Christensen 

(Dec. 22, 2008) (Exhibit 1 at 09–3698 0003). 

101. After the conference, the Carib News Foundation provided 

a memorandum to Representatives Rangel, Thompson, Payne and 

Kilpatrick and Delegate Christensen that represented to contain 

the value of the trip-related reimbursements.98

102. The Board notes that the Carib News Foundation provided 

the same ‘‘total transportation’’ figure to the Congressional travelers despite the fact that Carib News Foundation had, in its own 

files, airline tickets and receipts for each Congressional traveler 

that showed, with the exception of Congressman Payne, that the 

actual cost of the ticket was significantly higher. 

103. 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. 

B. INFORMATION REQUIRED FROM THE CONGRESSIONAL TRAVELER

104. On her Member/Officer Post-Travel Disclosure Form,99 Delegate Christensen certified her travel cost as the following: 


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100 Memorandum of Interview of Delegate Donna Christensen (May 4, 2009) (Exhibit 2 at 09– 

3698 0032). 101 Memorandum from Carib News Foundation to Representatives Rangel, Thompson, Payne 

and Kilpatrick and Delegate Christensen (Nov. 18, 2008) (Exhibit 1 at 09–3698 0012). 102 Flight Reservation for Delegate Donna Christensen (Oct. 27, 2008) (Exhibit 24 at 09–3698 

0288). 

105. Delegate Christensen acknowledged her signature on her 

post-travel disclosure form.100 By signing the document, Delegate 

Christensen certified that her transportation expenses were $410. 

This is the figure in the memorandum from Karl Rodney cited 

above.101

106. However, according to records produced by Mr. Rodney, Delegate Christensen’s total transportation expenses were $578. Delegate Christensen received two-one way tickets in the amount of 

$381 and $197, respectively.102


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107. In her interview with the OCE, Delegate Christensen stated 

that she saw her airline ticket. Although she did not recall seeing 

a hotel bill, she remembered checking into the hotel. She also stated that she probably received a bill when she checked out because 


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103 Memorandum of Interview of Delegate Donna Christensen (May 4, 2009) (Exhibit 2 at 09– 

3698 0031). 104 Id. at 09–3698 0032 105 Member/Officer Post-Travel Disclosure Form signed by Delegate Donna M. Christensen 

(Dec. 22, 2008) (Exhibit 1). 106 Letter from IRS to OCE (Apr. 17, 2009) (Exhibit 8). 107 Online Version of Publication 78 (Accessed online on June 5, 2009 at http://www.irs.gov/ 

app/pub-78/) (Exhibit 8 at 09–3698 0119.1–0119.2). 108 26 U.S.C. §§ 501 and 509. 109 26 U.S.C. §§ 4941 and 4946. 

she was responsible for any incidental expenses.103 Delegate 

Christensen’s scheduler filled out the post-travel forms. Delegate 

Christensen did not know where her scheduler got the information 

that appeared on the form but assumed she knew how much the 

hotel cost.104

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

PROHIBITED FROM PAYING FOR DELEGATE CHRISTENSEN’S TRAVEL

108. 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.’’ 105

109. 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 2005.106

According to Publication 78 of the IRS, a list of all charities claiming 501(c) status, Carib Charities, Inc is a private foundation.107

110. 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).108 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. 

111. 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.109 The Code defines the 

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

make any payment of money (including reimbursement of exVerDate Aug 31 2005 14:37 Mar 09, 2010 Jkt 054331 PO 00000 Frm 00044 Fmt 6601 Sfmt 6601 P:\54-331\REVIEW~1\54-331.TXT 54-331

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110 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. 111 The 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). 112 Memorandum from Ethics Counsel at the National Institutes of Health to Deputy Ethics 

Counsels at NIH (Jun. 2, 2000) (Exhibit 25 at 09–3698 0291). 

penses) or other property by a private foundation to a government 

official.110 Although framed as a tax provision, the statute essentially bars certain federal employees and federally elected officials 

from receiving compensation, including reimbursements for international travel, from a private foundation.111

112. 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. 

113. 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.112

114. 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. Delegate Christensen certified inaccurate information to the Standards 

Committee and failed to disclose the number of family members accompanying her. 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. 

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

this matter by the Standards Committee is appropriate. 


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CONFIDENTIAL 

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

MOI – Page 1 of 2 OFFICE OF CONGRESSIONAL ETHICS 

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.

09-3698 0240

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CONFIDENTIAL 

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

MOI – Page 2 of 2 OFFICE OF CONGRESSIONAL ETHICS 

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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