" ! HOUSE OF REPRESENTATIVES 

112TH CONGRESS

2d Session 

REPORT

112–642 

House Calendar No. 156 

IN THE MATTER OF ALLEGATIONS 

RELATING TO 

REPRESENTATIVE LAURA RICHARDSON 

R E P O R T 

OF THE

COMMITTEE ON ETHICS 

AUGUST 1, 2012.—Referred to the House Calendar and ordered to be 

printed 


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IN THE MATTER OF ALLEGATIONS RELATING TO 

REPRESENTATIVE LAURA RICHARDSON 


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U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON : 

1 

75–373 

" ! HOUSE OF REPRESENTATIVES 

112TH CONGRESS

2d Session 

REPORT

2012

112–642 

House Calendar No. 156 

IN THE MATTER OF ALLEGATIONS 

RELATING TO 

REPRESENTATIVE LAURA RICHARDSON 

R E P O R T 

OF THE

COMMITTEE ON ETHICS 

AUGUST 1, 2012.—Referred to the House Calendar and ordered to be 

printed 


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(II) 

COMMITTEE ON ETHICS 

JO BONNER, Alabama, 

Chairman 

MICHAEL T. MCCAUL, Texas 

K. MICHAEL CONAWAY, Texas 

CHARLES W. DENT, Pennsylvania 

GREGG HARPER, Mississippi 

LINDA T. SA ́ NCHEZ, California, 

Ranking Member 

JOHN A. YARMUTH, Kentucky 

DONNA F. EDWARDS, Maryland 

PEDRO R. PIERLUISI, Puerto Rico 

JOE COURTNEY, Connecticut 

REPORT STAFF 

DANIEL A. SCHWAGER, Chief Counsel/Staff Director 

DEBORAH SUE MAYER, Director of Investigations 

KELLE A. STRICKLAND, Counsel to the Chairman 

DANIEL J. TAYLOR, Counsel to the Ranking Member 

CLIFFORD C. STODDARD, JR., Senior Counsel 

SHERIA A. CLARKE, Counsel 

CHRISTOPHER R. TATE, Counsel 

BRITTANY M. BOHREN, Investigative Clerk 


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(III)

LETTER OF SUBMITTAL 

HOUSE OF REPRESENTATIVES, 

COMMITTEE ON ETHICS, 

Washington, DC, August 1, 2012. 

Hon. KAREN L. HAAS, 

Clerk, House of Representatives, 

Washington, DC. 

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

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

the attached Report, ‘‘In the Matter of Allegations Relating to Representative Laura Richardson.’’ 

Sincerely, 

JO BONNER, 

Chairman. 

LINDA T. SA ́ NCHEZ, 

Ranking Member. 


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(V) 

C O N T E N T S 

Page 

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

II. PROCEDURAL HISTORY ............................................................................... 2 

III. COMMITTEE ON ETHICS’ RESPONSE TO REPRESENTATIVE RICHARDSON’S VIEWS ....................................................................................... 3 

IV. FINDINGS OF THE COMMITTEE ON ETHICS AND REASONS FOR 

RECOMMENDED SANCTION ................................................................... 15 

V. STATEMENT UNDER RULE XIII, CLAUSE 3(c) OF THE RULES OF 

THE HOUSE OF REPRESENTATIVES .................................................... 15 

APPENDIX A: STATEMENT OF ALLEGED VIOLATION, ADOPTED JULY 

18, 2012 ................................................................................................................. 16 

APPENDIX B: THE INVESTIGATIVE SUBCOMMITTEE’S REPORT ............. 36 

APPENDIX C: REPRESENTATIVE RICHARDSON’S VIEWS ........................... 394 

APPENDIX D: LETTERS OF REPROVAL ISSUED TO SHIRLEY COOKS 

AND DAYSHA AUSTIN ...................................................................................... 417 


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1 Before any decisions were made in the 112th Congress regarding the Rule 18(a) review regarding Representative Richardson that was initiated in the 111th Congress, Ranking Member 

Sa ́nchez voluntarily recused herself from consideration of the matter, to avoid even the appearance of a conflict of interest, and designated Representative John Yarmuth to act as Acting 

Ranking Member for the purposes of this matter. See Public Statement of the Chairman and 

Ranking Member, dated November 4, 2011. At that time, in light of uncertainties in California’s 

redistricting process, there was a possibility that Representatives Sa ́nchez and Richardson could 

have been primary opponents. Representatives Sa ́nchez and Richardson were not, in fact, opponents in the primary election on June 5, 2012. Moreover, with the primary elections over, they 

cannot be opponents in the 2012 general election under California’s unique election system. Accordingly, after consultation with the Committee’s Staff Director and Chief Counsel, Representative Sa ́nchez determined on June 7, 2012, that it was appropriate to end her voluntary recusal 

regarding the matter of Representative Richardson. 

House Calendar No. 156 

112TH CONGRESS REPORT " ! HOUSE OF REPRESENTATIVES 2d Session 112–642 

IN THE MATTER OF ALLEGATIONS RELATING TO 

REPRESENTATIVE LAURA RICHARDSON 

AUGUST 1, 2012.—Referred to the House Calendar and ordered to be printed 

Mr. BONNER, from the Committee on Ethics, 

submitted the following 

R E P O R T1

I. INTRODUCTION 

The Committee on Ethics (Committee) submits this privileged 

Report pursuant to House Rule XI, clause 3(a)(2) and House Rule 

XIII, clause 5(a)(5), which authorize the Committee to investigate 

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

House of Representatives, of the Code of Official Conduct or any 

law, rule, regulation, or other standard of conduct applicable to the 

conduct of such Member, officer, or employee and to submit to the 

House a privileged report recommending action by the House as a 

result of such investigation. 

This Report: (1) summarizes the Committee’s investigation of 

Representative Laura Richardson relating to Representative Richardson’s violations of House Rules, the Code of Ethics for Government Service, federal law and other applicable standards related to 

her compelling members of her official staff to work on her re-election campaign, her use of official resources for campaign purposes, 

her use of official resources for personal purposes, and her obstrucVerDate Mar 15 2010 07:04 Aug 02, 2012 Jkt 075373 PO 00000 Frm 00009 Fmt 6659 Sfmt 6602 E:\HR\OC\HR642.XXX HR642

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2The Committee notes that throughout the ISC’s Report and contained in the exhibits are references to a variety of campaign or political events. There is no allegation that there was anything improper with any of these events other than Representative Richardson’s compulsion of 

her staff’s attendance or her use of official resources in connection with such events. Furthermore, mere attendance at these events by other Members is not rendered improper in any way 

by Representative Richardson’s misconduct. 

tion of this Committee’s investigation; (2) addresses the concerns 

and arguments raised by Representative Richardson in her July 25, 

2012, views submitted and attached hereto; (3) adopts the attached 

report of the Investigative Subcommittee in the Matter of Representative Richardson, which (a) includes evidence supporting the 

Committee’s findings, (b) explains the Committee’s reasons for its 

recommendation to the House that, pursuant to Article I, Section 

5, Clause 2 of the United States Constitution, House Rule XI, 

clause 3(a)(2), and Committee Rule 24(e), Representative Richardson be reprimanded, (c) summarizes the Committee’s inquiry into 

the role of Representative Richardson’s Chief of Staff Shirley Cooks 

in this matter, and (d) summarizes the Committee’s inquiry into 

the role of Representative Richardson’s Deputy District Director 

Daysha Austin in this matter; and (4) recommends that the House 

of Representatives adopt this Report and, by doing so, reprimand 

Representative Laura Richardson. 

II. PROCEDURAL HISTORY 

During the first week of October 2010, the Committee received 

complaints from several members of Representative Laura Richardson’s staff in both the Washington, DC, and Long Beach, CA, offices indicating Representative Richardson required her staff to 

perform campaign work. Based on these complaints, the Chair and 

Ranking Republican Member of the Committee for the 111th Congress authorized Committee staff to conduct an inquiry into these 

allegations pursuant to Committee Rule 18(a). On October 15, 

2010, Committee counsel notified Representative Richardson in 

writing of the inquiry and requested she make her staff and documents and records available to the Committee. Committee staff 

interviewed 17 witnesses, including members of Representative 

Richardson’s staff from her offices in Washington, DC (also known 

as the ‘‘Capitol Hill office’’), and Long Beach, CA (also known as 

the ‘‘district office’’), as well as a shared employee, during that 

phase of the inquiry. 

Based on the results of the 18(a) investigation, staff recommended in the 112th Congress that the Committee empanel an 

ISC to further investigate the allegations. On November 3, 2011, 

following an initial inquiry under Committee Rule 18(a), the Committee empanelled an Investigative Subcommittee to investigate allegations that Representative Richardson, as well as two members 

of her official staff, had (1) engaged in improper use of House resources for campaign, personal, and nonofficial purposes; and (2) 

improperly required or compelled official staff to perform campaign 

work.2

At the completion of its investigation, the Investigative Subcommittee unanimously concluded that there was substantial reason to believe that Representative Laura Richardson violated the 

Purpose Law, 31 U.S.C. § 1301; House Rule XXIII clauses 1, 2, and 

8; and clause 2 of the Code of Ethics for Government Service, and 


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other standards of conduct, by improperly using House resources 

for campaign, personal, and nonofficial purposes; by requiring or 

compelling her official staff to perform campaign work; and by obstructing the investigation of the Committee and the Investigative 

Subcommittee through the alteration or destruction of evidence, 

the deliberate failure to produce documents responsive to requests 

for information and a subpoena, and attempting to influence the 

testimony of witnesses. 

On July 18, 2012, after negotiating a resolution to this matter 

with Representative Richardson, the Investigative Subcommittee 

unanimously voted to adopt a Statement of Alleged Violation (SAV) 

against Representative Richardson. As part of the negotiated resolution, Representative Richardson agreed to admit to all seven 

counts in the SAV and waive all further procedural rights in this 

matter provided to her by House or Committee Rule. 

On July 26, 2012, the Investigative Subcommittee submitted a 

Report to the full Committee unanimously recommending that the 

full Committee submit a public report to the House, and that the 

adoption of that report by the House serve as a reprimand of Representative Richardson for her misconduct. Additionally, the Investigative Subcommittee recommended that the Committee issue a 

fine to Representative Richardson in the amount of $10,000, to be 

paid no later than December 1, 2012. The Investigative Subcommittee further strongly discouraged Representative Richardson 

from permitting any of her official staff to perform work on her 

campaign (either on a paid or volunteer basis), but recommended 

to the Committee that, to the extent any of her official staff do perform work on her campaign, that said staff be required to sign a 

waiver asserting that such work will be provided voluntarily and 

is not being compelled by Representative Richardson. As part of the 

resolution Representative Richardson negotiated with the Investigative Subcommittee, Representative Richardson agreed to admit 

to all seven counts in the SAV, pay a $10,000 fine by December 1, 

2012, and accept all other terms of the Investigative Subcommittee’s recommendation. 

In addition, as a part of its investigation, the Investigative Subcommittee inquired as to the role of Representative Richardson’s 

Chief of Staff Shirley Cooks and Deputy District Director Daysha 

Austin in this matter. Following its investigation, Ms. Cooks and 

Ms. Austin agreed to waive all further procedural rights in this 

matter provided to them by House or Committee Rule. The Investigative Subcommittee recommended that the Committee issue 

public letters of reproval to Ms. Cooks and Ms. Austin for their conduct. On August 1, 2012, the Committee issued public letters of 

reproval to Ms. Cooks and Ms. Austin. 

III. COMMITTEE ON ETHICS’ RESPONSE TO 

REPRESENTATIVE RICHARDSON’S VIEWS 

The Investigative Subcommittee, as a part of its negotiated resolution of this matter, provided to all respondents (Representative 

Richardson, Ms. Cooks, and Ms. Austin) the opportunity to review 

a draft of the Investigative Subcommittee’s Report and to submit 

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3 Respondents agreed to a five-day period in which to review and respond to the Investigative 

Subcommittee’s Report (ISC Report). As discussed more fully below, this timeline was not only 

a part of the negotiated resolution (from which Representative Richardson herself benefited significantly), but also an objectively reasonable amount of time to appropriately and fully respond. 4See Views of Representative Richardson (July 25, 2012). 5See Views of Representative Richardson at 1–8 (July 25, 2012). 6See Views of Representative Richardson at 1–2 (July 25, 2012). 

cation.3 Representative Richardson chose to submit 22 pages of her 

views on the Investigative Subcommittee’s Report and the Committee’s investigation,4 while Ms. Cooks and Ms. Austin declined to respond to the Investigative Subcommittee’s Report. In this section 

the Committee will address some of Representative Richardson’s 

concerns. 

As a threshold matter, Representative Richardson’s submission 

attempts to object to a variety of factual, procedural, and legal conclusions underpinning the result we reach today. Even if her objections had merit—and they do not—the time for lodging those objections has passed, because the conclusion of this matter is one 

reached through negotiation with Representative Richardson herself. Representative Richardson admitted to wrongdoing. Representative Richardson waived her procedural rights. Representative Richardson agreed to accept a reprimand and fine for her misconduct. If Representative Richardson did not wish to agree to this 

process and these conclusions, she could have availed herself of the 

adjudicatory process provided by House and Committee rules. Instead, she affirmatively sought out a resolution with the Investigative Subcommittee, and gained specific and significant personal 

benefit from the resolution. 

In the end, Representative Richardson’s views seem to leave 

enough of the SAV un-challenged, and seem to use enough language of acceptance, however qualified it is, so that her views do 

not amount to a withdrawal from the negotiated resolution. Still, 

the concerns raised do warrant a response so that the House of 

Representatives and the public are not left with the misimpression 

that Representative Richardson’s views amount to an accurate recitation of the facts, rules, or law in this matter. The Committee 

gave serious consideration to Representative Richardson’s concerns, 

and ultimately found that they are without merit. 

Even if she had not rendered her own arguments moot by entering into a negotiated resolution, the Committee would not find 

them persuasive. Representative Richardson constructs three straw 

men in her submission, towards which she deflects responsibility in 

different, and ultimately baseless, respects. First, Representative 

Richardson impugns the hard work of the Committee, Committee 

staff, and the Investigative Subcommittee, by accusing them of a 

variety of procedural errors and purported violations.5 Her arguments in this regard significantly exaggerate some of her rights, 

and fabricate other rights, which simply do not exist. Indeed, rather than the Committee preventing Representative Richardson from 

providing a true and full account of the facts in context, as she has 

suggested,6 it has been Representative Richardson who failed to 

take advantage of the fulsome opportunities provided through the 

Investigative Subcommittee. 

These multiple missed opportunities began, at the latest, in November, 2011, when the Investigative Subcommittee sent RepVerDate Mar 15 2010 07:04 Aug 02, 2012 Jkt 075373 PO 00000 Frm 00012 Fmt 6659 Sfmt 6602 E:\HR\OC\HR642.XXX HR642

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7See Letter from Representative Charles Dent and Representative John Yarmuth to Representative Laura Richardson on November 17, 2011. 8See Subpoena duces tecum issued by the Committee on Ethics to Representative Richardson 

on June 7, 2012. 9See ISC Report at 46. 10See ISC Interview of Representative Laura Richardson. 11See ISC Interview of Representative Laura Richardson. 12See Views of Representative Richardson at 1–3 (July 25, 2012). 

resentative Richardson a request for documents.7 For months that 

request went unanswered, until the Investigative Subcommittee 

threatened to serve Representative Richardson with a subpoena. 

From that point, documents began to trickle in at a pace so slow 

that the Investigative Subcommittee was ultimately forced to follow 

through on its threat and compel the production of documents by 

subpoena.8 As noted in the Investigative Subcommittee’s Report, 

even the subpoena did not cause Representative Richardson to 

make a complete production of responsive documents.9 Then, after 

the Investigative Subcommittee delayed its interview of Representative Richardson for over a month to accommodate her request for 

more time because of her primary election schedule, the Investigative Subcommittee finally held its interview with Representative 

Richardson on June 20, 2012. Moreover, during her interview, Representative Richardson repeatedly made complaints about its 

length and ultimately demanded that it end so she could participate in an annual Congressional softball game.10 When the Investigative Subcommittee Chairman expressed the Subcommittee’s 

willingness to continue into the evening or reconvene at a later 

date, Representative Richardson declined the offers, stating her 

preference to finish her interview in the short time available that 

day.11

Even if Representative Richardson had not acted with utter disdain for the Committee’s process, her arguments demanding greater or different process are both misleading and baseless. For example, Representative Richardson argues that at the end of the 111th 

Congress, in the phase of the investigation conducted pursuant to 

Committee Rule 18(a) (18(a) investigation), Committee staff made 

inappropriate remarks to witnesses in her matter that showed prejudice.12 In reality, Committee staff provided information to witnesses about the next steps in the investigation and repeatedly informed witnesses that it was up to the Committee to decide what, 

if anything, would happen in this matter. In what became an obvious pattern in her submission, Representative Richardson omitted 

significant qualifying statements of staff that made clear that they 

were not making any definitive predictions as to what the Committee would do. The statements that were made are typical statements made to witnesses in the course of an investigation in order 

to inform the witness of their likely role in the investigation. These 

statements violate no rights even in a criminal process. This process, of course, is by no means a criminal process. As such, these 

rights have never been applied to this context in any form. Even 

more importantly, any staff recommendation to the Committee is 

purely advisory: it was the Committee that, after an independent 

review of evidence, unanimously chose to empanel an Investigative 


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13See Statement of the Chairman and Ranking Member of the Committee on Ethics regarding 

Representative Laura Richardson (November 4, 2011) (‘‘The Committee-initiated action follows 

a discretionary review of the allegations, pursuant to Committee Rule 18(a) . . . ’’). 14See ISC Report at Exhibit 1. 15See Views of Representative Richardson at 4 (July 25, 2012). 16See ISC Report at 9–10, 21, 47–48. 17 Views of Representative Richardson at 7 (July 25, 2012). 18See ISC Report at 8–9, 15–20; ISC Exhibit 3, 6, 10, 11, 33. 

Subcommittee,13 and it was the Investigative Subcommittee that, 

after a further investigation and independent review of all evidence, unanimously chose to adopt a Statement of Alleged Violation.14 Representative Richardson has provided no evidence tending 

to show that the outcome of this matter would have differed in any 

respect if staff had stayed silent. 

Representative Richardson also restates a complaint she initially 

raised in a letter to the Committee on November 30, 2010, that, in 

interviews conducted during the 18(a) investigation at the end of 

the 111th Congress, Committee staff improperly requested that 

witnesses not speak to Representative Richardson’s counsel.15

However, as the committee has repeatedly informed her through 

counsel, Representative Richardson’s complaint omits stark clarifications made in many of those interviews. In fact Committee 

counsel informed witnesses repeatedly that the general confidentiality requests were limited to the content of the interview itself, 

and not to the general facts of the case, and that the final decision 

of whether to speak to Representative Richardson’s counsel or not 

was up to the witnesses, who would suffer no consequences if they 

did so. Also omitted are exceptions to the bar rules cited, as well 

as relevant distinctions in the case law cited. In the end, with the 

disclaimers that were employed by Committee staff at the time, 

and with the significant legal differences between these proceedings and criminal proceedings, there is no constitutional impediment to the resolution of this matter before the Committee and 

the House. 

Further, the Committee notes the disturbing irony in Representative Richardson’s submission when she alleges that this conduct 

by Committee staff intimidated and frightened her employees, 

given the horrendous picture so many of her own current and 

former staff described of their time in her employment, and her 

own attempts to intimidate them on a regular basis.16 Given that 

Representative Richardson is accepting responsibility for obstructing the Committee’s investigation and compelling her staff to engage in other improper conduct, the Committee’s concerns for the 

integrity of the investigation and the interests of the witnesses 

were well born out. 

Representative Richardson also argues that by providing her 

with a draft of the Investigative Subcommittee’s Report on a Friday, the five-day review period fell on a weekend, ‘‘significantly reducing the ability to use the five agreed days.’’ 17 Representative 

Richardson’s complaint is contradicted by the facts uncovered during the Investigative Subcommittee’s investigation which demonstrate overwhelmingly that Representative Richardson forced her 

staff to perform campaign work on weekends, demanding that her 

needs be placed over those of her staff, their families, their health, 

their faith, and their education.18 Beyond the contradictory nature 

of the complaint, however, the Investigative Subcommittee and 


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19 Views of Representative Richardson at 7 (July 25, 2012). 

Committee staff made clear on the record of an Investigative Subcommittee meeting (for which Representative Richardson and her 

counsel were present by telephone) that their proposed timeline 

contemplated her receiving the draft on Friday and submitting the 

views the following Wednesday. Representative Richardson appears 

in her submission to insinuate that the Investigative Subcommittee 

is lying about the disclosure of the timeline, where she states that 

‘‘the ISC then refused to make the transcript of the recital of the 

terms of the settlement agreement available to Rep. Richardson.’’ 19

In fact, after receiving the written transcript of the meeting, the 

Investigative Subcommittee, through staff, confirmed to Representative Richardson’s attorney that the transcript included the explicit 

recital of this information as Representative Richardson herself 

well knew since she was present on the call. 

ISC STAFF: Okay. So, Joe, we’re on the record. Can you 

just state for the court reporter your name and who is 

there with you? 

MR. SANDLER: Yes. This is Joseph Sandler. I’m counsel 

for Congresswoman Richardson, and the Congresswoman 

is here with me in her office. 

ISC STAFF: And the purpose of this—of conferencing 

you in is to review the terms that we’ve already reviewed 

with you on the telephone this morning but to do it on the 

record, okay? 

MR. SANDLER: Yes, that’s fine. 

ISC STAFF: So, as we discussed earlier, Representative 

Richardson, as part of her resolution of this matter, has 

agreed to admit to the allegations in the SAV that was 

transmitted to you this morning, with the one change 

. . . . That’s the first term. 

The second is that Ms. Richardson agrees to accept a 

reprimand and a public report. 

Number three, that Ms. Richardson agrees to waive all 

of her procedural rights under committee and House rules. 

Number four, that although Ms. Richardson has waived 

all of her procedural rights under committee and House 

rules the subcommittee will give Ms. Richardson 5 days— 

5 calendar days to review their report and submit any 

views. Her views cannot be contrary to the SAV. The calendar days will start when the ISC report is transmitted. 

We expect that that will be on Friday, and so her response 

would be due the following Wednesday. Number five, that Ms. Richardson will pay a $10,000 

fine by no later than December 1, 2012. 

Number six, that the ISC strongly discourages Representative Richardson from allowing any of her official 

staff to volunteer on her 2012 campaign. However, to the 

degree that any of her staff wish to volunteer, they must 

sign a written statement acknowledging that their work is 

voluntary and not compelled by Representative Richardson. 

And, seven, that the ISC will recommend to the full committee that the report shall serve as the reprimand or will 


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20Transcript of ISC Meeting of July 18, 2012 (emphasis added). 21See Views of Representative Richardson at 7–8 (July 25, 2012). 

include the reprimand language and that there will be no 

standalone resolution regarding the reprimand. 

Those are the terms that we discussed on the telephone 

this morning and that you told us that you agreed to, and 

we just want to get your agreement on the record. 

MR. SANDLER: On point four you said, contrary to the 

SAV, but what we discussed on the phone was she would 

be able to address allegations—specific factual assertions 

in that—as distinct from the counts? 

ISC STAFF: That’s correct. She will be able—it’s not 

contrary to the allegations in the SAV, so she will be able 

to include in her views any factual recitation of her view 

of some of the background evidence. But, as we also discussed, if she has a recitation that’s contrary to every single paragraph of the SAV, that’s essentially eviscerating 

her admission to the SAV under number one of the terms. 

MR. SANDLER: Okay. 

ISC STAFF: Are those the terms as you understand 

them, Mr. Sandler? 

MR. SANDLER: Just one second. Okay. This will confirm that we accept the terms as you described them with 

the one caveat we discussed at the end. 

ISC STAFF: And when you say ‘‘we,’’ Mr. Sandler, just 

for the record, you mean yourself and Ms. Richardson. 

MR. SANDLER: My client, Congresswoman Richardson, 

accepts them.20

Representative Richardson also contends that the Investigative 

Subcommittee should not have relied on attorney proffers from the 

other two respondents, Ms. Cooks and Ms. Austin, and complains 

that these proffers were not provided to her.21 On the first point, 

the Committee notes that all respondents, including Representative 

Richardson herself, proffered information to the Investigative Subcommittee after they received a draft SAV and a copy of all of the 

evidence. These proffers were plainly intended to persuade the Investigative Subcommittee. Ms. Cooks and Ms. Austin, through 

their proffers, did indeed convince the Investigative Subcommittee 

of some additional facts, or corroborated other facts already in evidence. Both Ms. Cooks and Ms. Austin, by the terms of their negotiated resolutions with the Investigative Subcommittee, agreed to 

testify in any further proceedings. If Representative Richardson 

wanted to attack their credibility, she would have had her chance 

to do so at an adjudicatory hearing. Instead, she waived that right 

and agreed to accept the Report of the Investigative Subcommittee. 

Further, there is absolutely no basis in the rules, law, or Constitution upon which Representative Richardson would still have a 

right, at this stage, to those proffer statements in full. 

Having finished her complaints about the Committee, the Committee staff, and the Investigative Subcommittee, Representative 

Richardson pivots to her second line of attack: the credibility of her 

own staff. Representative Richardson takes umbrage at the idea 

that members of her staff spoke to each other about the fact that 


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22See Views of Representative Richardson at 8–9 (July 25, 2012). 23See Views of Representative Richardson at 8–9 (July 25, 2012). 24 Views of Representative Richardson at 8 (July 25, 2012). 25 18(a) Interview of Jeremy Marcus (emphasis added). 26 18(a) Interview of Jeremy Marcus. 27 Views of Representative Richardson at 9–21 (July 25, 2012). 

she was under investigation.22 She appears to make the leap from 

this observation to a contention that these conversations influenced 

the testimony of staff to such an extent as to impede her rights and 

make the overwhelming evidence in this case unreliable.23 Witnesses to an event speak to each other about the event all the time. 

They are human. Neither House Rules nor legal principles mandate a cessation of this unremarkable activity. 

That being said, this type of conversation is exactly what the 

Committee staff was attempting to avoid when they requested that 

witnesses not speak to anyone else about the matter. Amazingly, 

Representative Richardson criticizes the Committee staff for trying 

to prevent exactly what she later complains about. In the end, just 

as Committee staff properly made clear to numerous witnesses that 

we cannot require them to refrain from discussing the case, so too, 

such discussions on their own do not amount to an automatic deprivation of Representative Richardson’s rights. 

Furthermore, as is common throughout her complaints, Representative Richardson omits starkly contradictory evidence in the 

same record she selectively quotes from. For example, in support 

of her claim, Representative Richardson notes that Jeremy Marcus 

testified that ‘‘amongst the staff . . . there has been, you know, 

some interested chatter about, you know, what’s going on.’’ 24 What 

Mr. Marcus actually said in his testimony is as follows: 

Q: Did anybody else talk to you about what you were 

going to say? 

A: I mean, of course amongst the staff, there’s been— 

but, actually, people have been very resolute about not discussing any details. But of course—— 

Q: That’s really good. 

A: ——but of course there has been, you know, some interested chatter about, you know, what’s going on.25

The removal of Mr. Marcus’ clear statement that the staff was 

‘‘resolute about not discussing any details,’’ is a crucial part of his 

statement and directly contradicts Representative Richardson’s 

claim of improper collusion.26 Representative Richardson continues 

to attack the credibility of other current and former staff of hers 

with a similar pattern of omission and deception. The Committee 

finds these attempts to be as objectionable as they are meritless. 

Representative Richardson spends the rest of her submission 

taking aim at her third and final target: the facts, as proven by the 

overwhelming weight of the evidence collected. Representative 

Richardson’s views weave an elaborate fabrication out of threads of 

decontextualized evidence and outright prevarication, in an absurd 

attempt to rebut the majority of the tremendous evidence against 

her.27 For example, Representative Richardson, when discussing a 

meeting where Ms. Cooks stated that if staff failed to volunteer 

they risked losing their jobs, stated that ‘‘[n]o staff testified, however, that Ms. Cooks indicated at the meeting that she was speakVerDate Mar 15 2010 07:04 Aug 02, 2012 Jkt 075373 PO 00000 Frm 00017 Fmt 6659 Sfmt 6602 E:\HR\OC\HR642.XXX HR642

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28 Views of Representative Richardson at 9 (July 25, 2012). 29 ISC Report at 4. 30 ISC Report at 4–5 31 ISC Report at 5. 32 Views of Representative Richardson at 12 (July 25, 2012). 33 18(a) Interview of Lucinda Woodward. 

ing for or at the direction of the Congresswoman.’’ 28 This carefully 

worded point is highly misleading. 

Kenneth Miller testified that Ms. Cooks invoked Representative 

Richardson directly: ‘‘If you know anything about [Representative 

Richardson], you probably will not have a job, you know, if you 

don’t volunteer.’’ 29 Eric Boyd testified that he took Ms. Cooks’ 

statements ‘‘to be coming not from Shirley.’’ 30 And Candace 

Yamagawa testified that ‘‘even prior to Shirley Cooks coming to the 

district office, I knew it was the highway or the byway, either adhere to what [Representative Richardson] wants or you are out.’’ 31

And yet, perhaps hoping that the public would read her submission 

and not the Investigative Subcommittee’s Report, Representative 

Richardson ignores the overwhelming evidence that it was her own 

actions, judgments and management, that created the undeniable 

message among her staff that if they considered campaign work to 

be voluntary, it was at their peril, and risked her wrath. 

These sorts of misrepresentations continue throughout Representative Richardson’s submission. On certain occasions, Representative Richardson repeats the strategy she employed with Mr. 

Marcus’ testimony regarding conversations between witnesses: she 

simply cuts off a passage or section where it is most helpful for her. 

For example, Representative Richardson quotes Lucinda Woodward 

in a way that characterizes her testimony as exculpatory of Representative Richardson: 

Q: Were you ever threatened if you chose not to participate? 

A: No.32

But immediately after the quoted passage, Ms. Woodward continued: 

Q: You have volunteered? 

A: I never have . . . I feel like my hours in her office 

are so long that I barely have the time to spend with my 

family. I would not volunteer my time . . . She gets really 

angry. I would describe her as a vindictive person . . . It 

is not like you get fired for [standing up to her] necessarily, but it is a very uncomfortable environment for the 

person who does.’’ 33

Representative Richardson uses this technique again when attempting to discredit the testimony of her current Communications 

Director, Makeda Scott, by saying that Ms. Scott erroneously assumed that an event to which she was assigned was a campaign 

event, and that Ms. Scott based this assumption solely on the location of the event, outside Representative Richardson’s district. This 

is incorrect. As Ms. Scott herself explains, she did not base her conclusion solely on the location of the event: 

And I said, are you Tim from the division [sic] office? 

And he said, no, the Congresswoman called me to come 

meet her here, and she had me take pictures on her camVerDate Mar 15 2010 07:04 Aug 02, 2012 Jkt 075373 PO 00000 Frm 00018 Fmt 6659 Sfmt 6602 E:\HR\OC\HR642.XXX HR642

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34 ISC staff interview of Makeda Scott (emphasis added). 35 ISC staff interview of Makeda Scott (emphasis added). 

era. And he said, you know, she wanted to get some more 

inroads in, you know, the new district. And I said, in the 

where? And I said, where am I? And he said Wilmington. 

And I said, is this the 37th District? And he said, no, and 

he said, you know, I help out on the campaign.34

Moreover, Representative Richardson suggests that Ms. Scott’s 

testimony regarding compulsory campaign work was limited to this 

one event. Contrary to this suggestion, Ms. Scott’s testimony identifies interactions she had directly with Representative Richardson 

wherein Representative Richardson pressured her to perform campaign work after Representative Richardson was fully aware of this 

Committee’s investigation: 

. . . And she [Representative Richardson] brought me in 

her office and she said, did you bring in your personal 

camera? I said no. I said, we have a camera here in the 

office. And then she said, I know that. I wanted you to 

bring your personal camera in because I wanted you to 

take pictures of me and a Member for the campaign. And 

I said, here in the building? And she said, yes. And I said, 

well, I don’t—she said, well, you can do that, and I said 

I don’t feel—I don’t know. I said, that doesn’t—you know, 

I said I didn’t want to do anything on the campaign. And 

then that is when she, you know, just went off and said, 

you can do these things. You should do these things. You 

haven’t offered to volunteer on the campaign. And she 

said, I am not saying that you have to, she said, but you 

haven’t offered, and that makes me feel uncomfortable 

working with you. And so I said, okay, well, you know, so 

that is what I mean. She was trying to, I feel, force me 

into working on her campaign. 

Q: So I want to go back to one thing that you said, which 

is that you said—you said that she objected to the fact that 

you haven’t offered to volunteer? 

A: Volunteer. 

Q: And she said that that made her, Representative 

Richardson, uncomfortable with working with you. 

A: Yes. 

Q: What did you take that to mean? 

A: As a threat. If you don’t volunteer on my campaign 

you are not going to continue working here. That is how I 

took it.35

Even in those cases where Representative Richardson does not 

do violence to the complete record, she relies on a selective judgment of credibility which the Investigative Subcommittee did not 

share. For example, Representative Richardson attempts to rebut 

the testimony of no fewer than five witnesses with the testimony 

of a single district staffer, Henry Rogers, whose testimony was 

largely exculpatory for Representative Richardson. The Investigative Subcommittee reviewed Mr. Rogers’ transcript. It also either 

reviewed the transcripts or actually heard the testimony of Kenneth Miller, Eric Boyd, Maria Angel Macias, Moises Romero, and 


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36See ISC Report at 4–24. 37 Views of Representative Richardson at 16–17 (July 25, 2012). 38 ISC Report at 28–29. 39 ISC Report at 28–30. 40 Views of Representative Richardson at 1 (July 25, 2012). 41 ISC Report at 28–30. 42 ISC Report at Exhibit 51. 

Candace Yamagawa, which was largely inculpatory of Representative Richardson.36 In the Investigative Subcommittee’s judgment, 

Mr. Rogers’ account simply did not outweigh the credibility of the 

accounts of the five other witnesses. If Representative Richardson 

wanted to attack five witnesses with her own single witness, she 

was free to do so at an adjudicatory hearing, but there is no reason 

to conclude from her submission that the Committee’s judgment of 

credibility would have differed in any meaningful respect from that 

of the Investigative Subcommittee. 

Likewise, Representative Richardson quotes three Washington, 

DC staffers—Jakki Dennis, Gregory Berry, and Jeremy Marcus— 

who stated that their attendance at her campaign fundraiser 

‘‘Democratic Idol’’ was voluntary.37 But even if the Investigative 

Subcommittee credited their testimony, it does not answer the ultimate question of whether anyone else was compelled to attend. Ms. 

Dennis, Mr. Berry, and Mr. Marcus could not volunteer on behalf 

of Ms. Woodward or Mr. Billington, both of whom stridently testified that their attendance was not voluntary.38 In fact, the staff 

who had already decided to attend the event paid very little attention to Ms. Cooks’ email, and for good reason—compulsion only affects those who would otherwise refuse. 

Finally, Representative Richardson ignores some of the most 

damning facts in the Investigative Subcommittee’s Report. For example, in her testimony before the Investigative Subcommittee, 

Representative Richardson insisted that she never intended to require her staff to attend Democratic Idol and attempted to place 

blame on Ms. Cooks’ email telling staff they were required to attend.39 She attempts to insulate and exculpate herself by saying 

that because she was not included on the email, she was unaware 

until after the fact that staff had been told they were required to 

attend.40 As discussed in the Investigative Subcommittee’s Report, 

Ms. Cooks informed the Investigative Subcommittee that after 

speaking directly with Representative Richardson and at Representative Richardson’s direction, she sent the email to the Washington, DC staff.41 In addition to Ms. Cooks’ information, Representative Richardson’s own calendar, has the following entry: 42


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43 Email from Representative Richardson to Eric Boyd and Shirley Cooks (July 8, 2010, 4:05 

PM) 44 Email from Representative Richardson to Jakki Dennis and Shirley Cooks (July 29, 2010, 

8:18 AM); see also ISC Report at Exhibit 6 (email entitled ‘‘Schedule today,’’ wherein Representative Richardson points out an event listed on her calendar that does not have a staffer assigned 

to it, ‘‘I notice no staff is assigned @ lcdp dinner tonight.’’) 45See Views of Representative Richardson (July 25, 2012). 

The Investigative Subcommittee’s investigation gathered overwhelming evidence that Representative Richardson checked her 

calendar often and it was not uncommon for her to chastise her 

staff for an improper entry. For example, in July 2010, Representative Richardson sent her Chief of Staff and District Director and 

email entitled ‘‘Schedules on the calendar,’’ wherein she ‘‘stress[ed] 

how important it is everyday to review the schedule together and 

ensure there is proper coverage and info for staff contact.’’ Representative Richardson went on in the email to (1) direct her staff 

to add certain events to the calendar, (2) point out that a certain 

event did not have a staffer assigned to cover it, (3) ask which day 

a particular staffer was going to be out for their birthday since that 

entry was listed on two days, and (4) noted that a staff appointment had been left off the calendar.43 And on July 29, 2010, Representative Richardson emailed her scheduler and Chief of Staff 

saying ‘‘Before you leave EVERY evening you must completely update the calendar. For ie: my calendar is showing preside 4–6 not 

2–4. Thx.’’44 Therefore, the Investigative Subcommittee properly 

concluded that Representative Richardson did indeed intend to require her official staff to attend her campaign fundraiser and 

whether or not she received Ms. Cooks’ email is of no consequence. 

Representative Richardson’s submission launches an attack on 

many members of her staff.45 Based on the overwhelming evidence 

against Representative Richardson, the Committee wishes to make 

abundantly clear that, in the credibility dispute Representative 

Richardson presents between herself and those of her own current 


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46 Views of Representative Richardson at 17–19 (July 25, 2012). 47See ISC Report at 37–46. 48 Views of Representative Richardson at 19 (July 25, 2012). 49 ISC Report at 45. 50 ISC Report at 45. 

and former staff whom she continues to attack, the Committee 

sides with her staff. 

In the same vein, Representative Richardson disputes that her 

actions with respect to changing Ms. Austin’s status were intended 

to obstruct the Committee’s investigation, and relies on Ms. Austin’s testimony early in the investigation that she had discussions 

with Representative Richardson in September about moving to 

part-time status in October.46 However, Ms. Austin has now corrected her testimony and made clear to the Investigative Subcommittee that these September conversations never occurred. In 

addition, Representative Richardson’s own emails and her own 

plainly inconsistent accounts over time support the Investigative 

Subcommittee’s rejection of her claims, and their finding that Representative Richardson’s change to Ms. Austin’s status was in fact 

intended to obstruct the Committee’s investigation.47

Representative Richardson also stated that her meeting with 

staff, in which she suggested answers to the Committee, was not 

intended to obstruct, and that ‘‘[w]hen she referenced staff volunteering, she was referring to attendance at a local meeting of a political club.’’ 48 She therefore admits that she did tell her staff that 

they were volunteering, but limits it to a single event. This is not 

credible. Because numerous staffers testified that Representative 

Richardson had a mock dialogue with herself, stating some of the 

questions she expected the Committee to ask, such as ‘‘did you feel 

that your campaign work was mandatory or you were compelled in 

some way?’’ and then an answer—‘‘no.’’ 49 Three staffers testified 

that they felt that Representative Richardson was asking them to 

answer a certain way that would minimize her culpability whether 

or not those answers were true.50 Even if Representative Richardson’s explanation was on all fours with the facts—and it is not— 

if she told staff how to testify regarding the voluntary nature of 

their campaign work, this would be obstruction, even if she limited 

such a statement to a single event. 

In sum, Representative Richardson’s submission continues the 

approach she has taken in this matter from the outset: an utter absence of true remorse for her misuse of official resources and, 

equally as significant, for what she has put her staff through, as 

well as a near total deflection of responsibility for this matter. It 

is not this Committee, it is not other Members, it is not either political party, and most certainly, it is not her staff that is responsible for the situation Representative Richardson finds herself in. 

It is Representative Richardson’s own management, Representative 

Richardson’s own decisions, and Representative Richardson’s own 

actions that are responsible for the existence of this matter, the resources they have required, and the damage to the integrity of her 

office and this institution that they have caused. That Representative Richardson still does not seem willing to accept this simple 

fact is all the more reason why this Committee must refer the matter to the whole of the House of Representatives for their consideration and judgment. 


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IV. FINDINGS OF THE COMMITTEE ON ETHICS AND 

REASONS FOR RECOMMENDED SANCTION 

The Committee on Ethics adopts as its findings in this matter 

the Report of the Investigative Subcommittee, as attached. 

Prior Committee precedent supports a recommendation of reprimand for conduct involving compelling official staff members to 

perform campaign work, using official resources for campaign purposes, using official resources for personal purposes, and obstruction of this Committee’s investigation. This is particularly true in 

the case of a negotiated settlement where a public hearing is 

waived, saving significant resources and allowing the Committee to 

continue working through the many other matters it must address 

in the interest of the institution and all Members. 

In addition to public reprimand, the Committee recommends that 

the House, by adoption of this Report, impose a $10,000 fine on 

Representative Richardson for her misconduct and that the fine be 

payable to the U.S. Treasury no later than December 1, 2012. Towards that end, the Committee recommends that the House of Representatives adopt a resolution in the following form and that the 

adoption of this Report will serve as a reprimand of Representative 

Richardson and the imposition of a $10,000 fine under the conditions outlined herein: 

HOUSE RESOLUTION—— 

Resolved, (1) That the House adopt the report of the 

Committee on Ethics dated August 1, 2012, In the Matter 

of Representative Laura Richardson. 

V. STATEMENT UNDER RULE XIII, CLAUSE 3(c) OF THE 

RULES OF THE HOUSE OF REPRESENTATIVES 

The Committee made no special oversight findings in this Report. 

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

measure in this Report. No oversight findings are considered pertinent. 


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tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 159 here 75373.138
153 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 160 here 75373.139
154 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 161 here 75373.140
155 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 162 here 75373.141
156 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 163 here 75373.142
157 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 164 here 75373.143
158 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 165 here 75373.144
159 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 166 here 75373.145
160 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 167 here 75373.146
161 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 168 here 75373.147
162 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 169 here 75373.148
163 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 170 here 75373.149
164 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 171 here 75373.150
165 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 172 here 75373.151
166 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 173 here 75373.152
167 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 174 here 75373.153
168 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 175 here 75373.154
169 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 176 here 75373.155
170 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 177 here 75373.156
171 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 178 here 75373.157
172 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 179 here 75373.158
173 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 180 here 75373.159
174 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 181 here 75373.160
175 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 182 here 75373.161
176 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 183 here 75373.162
177 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 184 here 75373.163
178 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 185 here 75373.164
179 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 186 here 75373.165
180 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 187 here 75373.166
181 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 188 here 75373.167
182 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 189 here 75373.168
183 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 190 here 75373.169
184 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 191 here 75373.170
185 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 192 here 75373.171
186 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 193 here 75373.172
187 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 194 here 75373.173
188 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 195 here 75373.174
189 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 196 here 75373.175
190 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 197 here 75373.176
191 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 198 here 75373.177
192 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 199 here 75373.178
193 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 200 here 75373.179
194 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 201 here 75373.180
195 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 202 here 75373.181
196 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 203 here 75373.182
197 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 204 here 75373.183
198 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 205 here 75373.184
199 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 206 here 75373.185
200 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 207 here 75373.186
201 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 208 here 75373.187
202 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 209 here 75373.188
203 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 210 here 75373.189
204 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 211 here 75373.190
205 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 212 here 75373.191
206 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 213 here 75373.192
207 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 214 here 75373.193
208 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 215 here 75373.194
209 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 216 here 75373.195
210 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 217 here 75373.196
211 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 218 here 75373.197
212 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 219 here 75373.198
213 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 220 here 75373.199
214 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 221 here 75373.200
215 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 222 here 75373.201
216 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 223 here 75373.202
217 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 224 here 75373.203
218 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 225 here 75373.204
219 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 226 here 75373.205
220 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 227 here 75373.206
221 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 228 here 75373.207
222 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 229 here 75373.208
223 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 230 here 75373.209
224 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 231 here 75373.210
225 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 232 here 75373.211
226 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 233 here 75373.212
227 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 234 here 75373.213
228 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 235 here 75373.214
229 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 236 here 75373.215
230 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 237 here 75373.216
231 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 238 here 75373.217
232 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 239 here 75373.218
233 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 240 here 75373.219
234 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 241 here 75373.220
235 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 242 here 75373.221
236 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 243 here 75373.222
237 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 244 here 75373.223
238 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 245 here 75373.224
239 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 246 here 75373.225
240 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 247 here 75373.226
241 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 248 here 75373.227
242 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 249 here 75373.228
243 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 250 here 75373.229
244 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 251 here 75373.230
245 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 252 here 75373.231
246 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 253 here 75373.232
247 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 254 here 75373.233
248 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 255 here 75373.234
249 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 256 here 75373.235
250 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 257 here 75373.236
251 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 258 here 75373.237
252 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 259 here 75373.238
253 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 260 here 75373.239
254 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 261 here 75373.240
255 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 262 here 75373.241
256 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 263 here 75373.242
257 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 264 here 75373.243
258 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 265 here 75373.244
259 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 266 here 75373.245
260 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 267 here 75373.246
261 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 268 here 75373.247
262 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 269 here 75373.248
263 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 270 here 75373.249
264 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 271 here 75373.250
265 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 272 here 75373.251
266 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 273 here 75373.252
267 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 274 here 75373.253
268 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 275 here 75373.254
269 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 276 here 75373.255
270 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 277 here 75373.256
271 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 278 here 75373.257
272 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 279 here 75373.258
273 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 280 here 75373.259
274 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 281 here 75373.260
275 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 282 here 75373.261
276 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 283 here 75373.262
277 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 284 here 75373.263
278 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 285 here 75373.264
279 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 286 here 75373.265
280 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 287 here 75373.266
281 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 288 here 75373.267
282 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 289 here 75373.268
283 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 290 here 75373.269
284 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 291 here 75373.270
285 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 292 here 75373.271
286 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 293 here 75373.272
287 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 294 here 75373.273
288 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 295 here 75373.274
289 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 296 here 75373.275
290 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 297 here 75373.276
291 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 298 here 75373.277
292 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 299 here 75373.278
293 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 300 here 75373.279
294 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 301 here 75373.280
295 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 302 here 75373.281
296 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 303 here 75373.282
297 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 304 here 75373.283
298 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 305 here 75373.284
299 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 306 here 75373.285
300 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 307 here 75373.286
301 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 308 here 75373.287
302 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 309 here 75373.288
303 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 310 here 75373.289
304 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 311 here 75373.290
305 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 312 here 75373.291
306 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 313 here 75373.292
307 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 314 here 75373.293
308 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 315 here 75373.294
309 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 316 here 75373.295
310 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 317 here 75373.296
311 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 318 here 75373.297
312 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 319 here 75373.298
313 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 320 here 75373.299
314 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 321 here 75373.300
315 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 322 here 75373.301
316 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 323 here 75373.302
317 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 324 here 75373.303
318 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 325 here 75373.304
319 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 326 here 75373.305
320 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 327 here 75373.306
321 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 328 here 75373.307
322 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 329 here 75373.308
323 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 330 here 75373.309
324 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 331 here 75373.310
325 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 332 here 75373.311
326 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 333 here 75373.312
327 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 334 here 75373.313
328 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 335 here 75373.314
329 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 336 here 75373.315
330 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 337 here 75373.316
331 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 338 here 75373.317
332 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 339 here 75373.318
333 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 340 here 75373.319
334 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 341 here 75373.320
335 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 342 here 75373.321
336 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 343 here 75373.322
337 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 344 here 75373.323
338 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 345 here 75373.324
339 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 346 here 75373.325
340 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 347 here 75373.326
341 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 348 here 75373.327
342 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 349 here 75373.328
343 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 350 here 75373.329
344 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 351 here 75373.330
345 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 352 here 75373.331
346 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 353 here 75373.332
347 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 354 here 75373.333
348 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 355 here 75373.334
349 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 356 here 75373.335
350 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 357 here 75373.336
351 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 358 here 75373.337
352 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 359 here 75373.338
353 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 360 here 75373.339
354 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 361 here 75373.340
355 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 362 here 75373.341
356 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 363 here 75373.342
357 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 364 here 75373.343
358 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 365 here 75373.344
359 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 366 here 75373.345
360 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 367 here 75373.346
361 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 368 here 75373.347
362 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 369 here 75373.348
363 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 370 here 75373.349
364 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 371 here 75373.350
365 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 372 here 75373.351
366 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 373 here 75373.352
367 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 374 here 75373.353
368 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 375 here 75373.354
369 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 376 here 75373.355
370 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 377 here 75373.356
371 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 378 here 75373.357
372 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 379 here 75373.358
373 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 380 here 75373.359
374 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 381 here 75373.360
375 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 382 here 75373.361
376 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 383 here 75373.362
377 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 384 here 75373.363
378 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 385 here 75373.364
379 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 386 here 75373.365
380 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 387 here 75373.366
381 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 388 here 75373.367
382 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 389 here 75373.368
383 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 390 here 75373.369
384 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 391 here 75373.370
385 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 392 here 75373.371
386 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 393 here 75373.372
387 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 394 here 75373.373
388 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 395 here 75373.374
389 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 396 here 75373.375
390 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 397 here 75373.376
391 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 398 here 75373.377
392 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 399 here 75373.378
393 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 400 here 75373.379
394 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 401 here 75373.380
395 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 402 here 75373.381
396 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 403 here 75373.382
397 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 404 here 75373.383
398 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 405 here 75373.384
399 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 406 here 75373.385
400 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 407 here 75373.386
401 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 408 here 75373.387
402 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 409 here 75373.388
403 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 410 here 75373.389
404 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 411 here 75373.390
405 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 412 here 75373.391
406 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 413 here 75373.392
407 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 414 here 75373.393
408 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 415 here 75373.394
409 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 416 here 75373.395
410 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 417 here 75373.396
411 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 418 here 75373.397
412 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 419 here 75373.398
413 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 420 here 75373.399
414 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 421 here 75373.400
415 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 422 here 75373.401
416 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 423 here 75373.402
417 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 424 here 75373.403
418 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 425 here 75373.404
419 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 426 here 75373.405
420 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 427 here 75373.406
421 


tjames on DSK6SPTVN1PROD with REPORTSInsert graphic folio 428 here 75373.407