CAMPAIGN

FINANCE TASK

FORCE

Problems and

Disagreements

Initially Hampered

Justice’s Investigation

United States General Accounting Office

GAO Briefing Report to the Chairman

Committee on the Judiciary

House of Representatives

May 2000

GAO/GGD-00-101BR

United States General Accounting Office General Government Division

Washington, D.C. 20548

Page 1 GAO/GGD-00-101BR Campaign Finance Task Force

B-284908

May 31, 2000

The Honorable Henry J. Hyde

Chairman, Committee on the Judiciary

House of Representatives

Dear Mr. Chairman:

As you requested, this report discusses the management and oversight,

operations, and results of the Department of Justice’s (DOJ) Campaign

Finance Task Force (CFTF). Created by Attorney General Reno in

December 1996 within the Criminal Division’s Public Integrity Section (PI),

CFTF was established to investigate allegations of illegal fundraising

during the 1996 presidential election. Subsequently, investigating illegal

fundraising allegations concerning the 1994 congressional election was

added to CFTF’s mission. The Task Force comprised primarily DOJ

attorneys; Federal Bureau of Investigation (FBI) investigators; and support

staff, such as financial analysts and intelligence research specialists. Since

its creation, CFTF has undergone several management changes and has

been the target of accusations of mismanagement.

On February 17, 2000, we provided your office a preliminary briefing on

the results of our review. This report summarizes and updates the

information presented at that briefing. More specifically it addresses (1)

strained working relationships and trust concerns; (2) disagreement over

investigative approach; (3) management and analysis of evidence

problems; (4) management changes, staffing fluctuations, and oversight;

(5) CFTF prosecutive results and costs; and (6) limitations in the Federal

Election Campaign Act that may inhibit prosecutions. The briefing slides,

which have been updated to include additional information obtained

subsequent to our briefing, are contained in appendix I.

Following its creation, CFTF faced several management challenges and

operational problems. Notably, the working relationships between DOJ

and the FBI were strained and hampered by mutual concerns of trust, with

DOJ attorneys and FBI investigators disagreeing over which investigative

approach to take. Furthermore, efforts to manage and analyze

documentation and evidence were hampered by the lack of (1) an

electronic data management system that could effectively process and

manage the overwhelming amount of documents and other evidence

collected and (2) sufficient staff to input and analyze them.

Results in Brief
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To get the investigation on track, in the fall of 1997, DOJ and the FBI

changed the Task Force’s leadership, streamlined CFTF’s oversight

structure, and committed additional staff and information management

resources. The Task Force was removed from PI’s leadership and placed

directly under a Deputy Assistant Attorney General in DOJ’s Criminal

Division. PI, however, maintained its oversight of CFTF-related matters

that had Independent Counsel statute implications. Up until its expiration

in 1999, the statute and its applicability to CFTF’s investigation had been a

source of tension and disagreement between DOJ and the FBI and within

DOJ.

As of December 31, 1999, CFTF had launched 121 investigations. As of

March 31, 2000, it had initiated 24 prosecutions and 15 individuals and 1

corporation had been convicted. From its inception through fiscal year

1999, DOJ and the FBI estimated that they had spent $31.2 million on Task

Force activities.

DOJ and FBI officials reviewed a draft of this report and generally

concurred with its substance.

As it relates to campaign financing, the Federal Election Campaign Act

(FECA) of 1971, as amended, (2 U.S.C. 431-455) generally applies only to

financial transactions that are intended to influence federal elections, i.e.,

campaigns for the office of U.S. Representative, U.S. Senator, President, or

Vice President. FECA contains its own criminal provision, which generally

provides that knowing and willful violations involving at least $2,000 may

be prosecuted as misdemeanors.

According to DOJ, those FECA violations most likely to warrant criminal

prosecution involve schemes to influence a federal candidate’s election by

making contributions that are patently illegal, through means calculated to

conceal the scheme. Furthermore, to warrant criminal prosecution, in

general, a FECA fraud must have subverted one of FECA’s “core”

provisions. These provisions place limits on the amount that can be

contributed and disallow contributions from foreign nationals, disguised

contributions, and attempts to circumvent FECA’s disclosure

requirements.

The Independent Counsel statute, 28 U.S.C. 591-599, which expired June

30, 1999, required the Attorney General to decide whether a criminal

allegation involving a top official of the executive branch of the federal

government, such as the President, Vice President, Cabinet officers, or the

chairman or treasurer of the national campaign committee seeking the

Background
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reelection of the President, was to be investigated by someone outside of

DOJ. The purpose of this legislation was to ensure both the appearance

and the reality of impartial prosecutive decisions concerning the President

and certain high-level government and campaign officials.

At your request, we examined the management and oversight, operations,

and results of CFTF from its inception through December 31, 1999. To

accomplish this objective, we interviewed current and former DOJ and FBI

officials responsible for managing and overseeing CFTF. We obtained

information on CFTF’s management structure, oversight, cost, and staffing

from DOJ and the FBI. We reviewed CFTF indictments and obtained

information concerning the results of its prosecutions. We have updated

CFTF’s prosecutive results through March 31, 2000.

In addition, we reviewed selected prosecution and declination documents1

from five closed cases and five closed matters2 to gain a sense of whether

those documents showed evidence of supervisory review and management

oversight. Of the five cases we selected, three cases were selected because

they had been high-profile cases; one case was selected because the

defendant was found not guilty; and one case was randomly selected.

Because information on the number and chronology of matters that had

been declined was not readily available, we selected, with CFTF’s

assistance, five matters to review. We recognize that this small sample is

insufficient to be representative of all matters declined; however, we

sought to obtain some limited insight into the supervisory oversight and

approval process for declinations. Thus, we selected two matters closed

during fiscal year 1998 and three matters closed during fiscal year 1999. No

matters were declined during fiscal year 1997.

We did not assess the appropriateness of CFTF’s prosecutive decisions or

its rationale for those decisions. Because CFTF’s work is ongoing, active

investigation and prosecution files were not available to us. We did our

work from July 1999 to March 2000 in accordance with generally accepted

government auditing standards.

1

Declination memoranda are internal documents, which set forth the facts of a matter and explain the

government’s reasons for not prosecuting individuals or organizations accused of violations.

2

For purposes of this report, we define a matter as an allegation of a violation that has been considered

for possible further investigation and prosecution. If Justice decides to prosecute a matter and files it

with the court, either by indictment or information, it then becomes a case.

Scope and

Methodology
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Describing their working relationship following CFTF’s creation, the PI

attorney in charge and the FBI’s lead investigator, respectively,

characterized their relationship as not very effective and strained.

According to PI’s chief, tensions between investigators and attorneys

existed over the extent of attorney involvement in investigations.

According to two FBI officials, investigators believed that the Task Force

attorneys’ involvement in traditional investigative functions, especially

interviews, was excessive. For example, the lead investigator said that

some agents believed that during investigative interviews they were being

used mainly as note takers.

In addition, disagreements developed over the need for an Independent

Counsel. Both DOJ and FBI officials frequently cited their disagreement

over the need for an Independent Counsel as a major source of tension and

conflict. One FBI official characterized DOJ’s criteria for triggering the

seeking of an Independent Counsel as too stringent. According to PI’s

Chief, the disagreement over the need for an Independent Counsel also

created mutual trust concerns. Eventually, both the FBI Director and a

Supervising Attorney leading the Task Force recommended that the

Attorney General appoint an Independent Counsel. (See appendix I, slides

17 - 18.)

Initially, attorneys and investigators differed over the Task Force’s

investigative approach. The attorneys’ approach was to build cases from

the ground up and investigate wherever the evidence led. One of DOJ’s

concerns was to avoid prematurely tipping off potential witnesses or

targeting individuals before sufficient predication was established. The

lead investigator, on the other hand, wanted to pursue several investigative

tracks simultaneously. For example, a senior FBI official said that on the

basis of news reports of White House coffees for campaign contributors,

one of the tracks the FBI wanted to investigate was whether the White

House had violated campaign finance laws. However, according to the

Chief of PI, there was no specific predication to justify all the investigative

tracks that the FBI wanted to pursue.

Moreover, the FBI official said that the investigative effort was always

under a microscope and subject to enormous scrutiny and secondguessing. The Chief of PI agreed that the investigation was under

considerable scrutiny, but he also said that this scrutiny was occasioned

by PI’s belief that the press created expectations for a major scandal. DOJ

officials said it was important to have sufficient predication to justify an

investigative direction, and it was particularly important for the

Strained Working

Relationships and

Trust Concerns

Disagreement Over

Investigative Approach
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investigation to be thorough and not perceived as being political. (See app.

I, slides 19 - 21.)

Exacerbating the strained situation were document management

problems, which impeded the investigation’s progress. According to the

lead investigator, CFTF was overwhelmed with documents and other

evidence and lacked sufficient staff and electronic system resources to

input and organize the information being gathered. The lead investigator

noted that after several months, the large volume of documents obtained

overwhelmed CFTF’s electronic data management system and a new

system had to be purchased. He added that due, in part, to delays in hiring

support staff, it took months to input backlogged documents into the new

system. According to the lead investigator and CFTF’s attorney-in-charge,

the document management problems hindered efforts to assess the

documents' importance to the investigation and their relationship to other

evidence. The problems continued into late 1997. (See app. I, slides 22 –

24.)

In the fall of 1997, displeased with the investigation’s slow pace,

disclosures in the press about critical leads not being pursued, and internal

frictions, the Attorney General and the FBI Director changed the Task

Force’s leadership. Subsequently, the Task Force’s oversight structure was

streamlined by the removal of PI from its leadership role and the

commitment of additional staff and information management resources to

get the investigation on track.

Since its inception, CFTF’s staffing levels have fluctuated as investigations

were initiated, documents and evidence were obtained and analyzed, and

cases were completed. CFTF staffing peaked in late 1997 at 126 (24

attorneys, 67 agents, and 35 support staff). However, it has declined since

then; and as of December 31, 1999, it totaled 48 (13 attorneys, 12 agents,

and 23 support staff).

Since the fall of 1997, a number of personnel changes have taken place

within CFTF and among the DOJ officials responsible for its oversight.

However, the level and type of CFTF’s management and oversight have

remained fairly consistent. According to officials, (1) briefings for the

Attorney General and top DOJ management officials have taken place

weekly; (2) the FBI Director has had periodic discussions about CFTF with

his executive staff; and (3) within CFTF, weekly meetings have been held

among managers, case attorneys, and investigators to discuss case

strategy, progress, and problems.

Management and

Analysis of Evidence

Problems

Management Changes,

Staffing Fluctuations,

and Oversight
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Regarding case management, all prosecution proposals were to be

reviewed by senior Task Force managers and attorneys and forwarded

through DOJ management to the Attorney General. Procedurally, both DOJ

and the FBI were to concur on whether to decline prosecution of an

investigation. Our review of documents in five selected prosecution case

files showed evidence of high-level DOJ reviews in three of the five cases.

However, the absence of documentary evidence in the two cases does not

necessarily mean that supervisory reviews did not occur. Our review of

documents in five selected declination matters showed evidence of DOJ

and FBI concurrence in all instances. (See app. I, slides 27 - 41.)

As of December 31, 1999, CFTF had completed 70 of the 121 investigations

it had initiated and was focusing on completing its work on the 51

investigations ongoing. As of March 31, 2000, CFTF had initiated

prosecution of 24 cases. It had convicted 15 individuals and 1 corporation,

and 6 trials were pending. A jury acquitted one individual, and one

prosecution resulted in a hung jury. Through fiscal year 1999, DOJ

estimated that it had spent $5.2 million, and the FBI estimated that it had

spent about $26 million funding CFTF. (See app. I, slides 42 - 43.)

According to a DOJ official, limitations in FECA penalties and its statute of

limitations have inhibited more effective investigation of campaign finance

violations. Specifically, he said that the criminal misdemeanor penalties

provided in FECA are not severe enough to encourage violators to

cooperate with the government to reveal the other participants and the

extent of campaign financing schemes in exchange for lesser charges or

for favorable consideration at sentencing. (See app. I, slides 44 - 46.)

We provided the Attorney General with a draft of this report for comment.

Representatives of the Criminal Division and the FBI reviewed the draft.

On May 8, 2000, the Director of the Department of Justice’s Audit Liaison

Office responded that the Department generally concurred with the

report’s substance. The Department provided some technical comments,

which have been incorporated where appropriate.

As agreed with your office, unless you publicly announce its contents

earlier, we plan no further distribution of this report until 30 days from the

date of this letter. At that time, we will send copies of this report to

Representative John Conyers, Ranking Minority Member of your

Committee; Senator Orrin G. Hatch, Chairman of the Senate Judiciary

Committee; Senator Patrick J. Leahy, Ranking Minority Member of the

Senate Judiciary Committee; Senator Fred Thompson, Chairman of the

Senate Governmental Affairs Committee; Senator Joseph Lieberman,

CFTF Prosecutive

Results and Costs

Federal Election

Campaign Act

Limitations May Inhibit

Prosecutions

Agency Comments
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Ranking Minority Member of the Senate Governmental Affairs Committee;

Representative Dan Burton, Chairman of the House Government Reform

Committee; Representative Henry Waxman, Ranking Minority Member of

the House Government Reform Committee; the Honorable Janet Reno,

Attorney General; the Honorable Louis J. Freeh, Director of the Federal

Bureau of Investigation; the Honorable Jacob J. Lew, Director of OMB; and

other interested parties. Copies will also be made available to others upon

request.

If you have any questions, please contact me or Daniel C. Harris, Assistant

Director, at (202) 512-8777 or by e-mail at ekstrandl.ggd@gao.gov or

harrisd.ggd@gao.gov. Major contributors to this work were Robert P. Glick

and Charles Michael Johnson.

Sincerely yours,

Laurie Ekstrand

Director, Administration

of Justice Issues
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1

General Government Division

Briefing to the Staff of the House Judiciary

Committee on the Department of Justice’s

Campaign Finance Task Force

February 17, 2000

Note: Information on Task Force prosecutions and staffing was updated subsequent to the briefing.
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2

CONTENTS

• Objectives, Scope, and Methodology

• Background

• Results

• Summary of Prosecutions
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3

Objectives, Scope, and Methodology

• The Chairman asked us to review the management and oversight,

operations, and results of the Department of Justice’s (DOJ)

Campaign Finance Task Force (CFTF).

• To accomplish these objectives, we:

• interviewed current and former DOJ and Federal Bureau of

Investigation (FBI) officials responsible for managing and

overseeing the Task Force;

• obtained information on the management structure, oversight,

cost, and staffing of CFTF from its creation in December 1996

to December 31, 1999;

• reviewed CFTF indictments and obtained information

concerning their prosecutive results through March 31, 2000.
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4

Objective, Scope, and Methodology (cont)

• Obtained access to CFTF documents related to five closed

prosecutions and five declinations to gain a sense for whether

these documents evidenced supervisory review and management

oversight. We recognize that this small sample is insufficient to be

representative of the universe of closed cases and matters. The

reviewed documents included prosecution and declination

memoranda, plea bargain agreements, and correspondence

related to those documents. Moreover, we did not assess the

appropriateness of CFTF’s decisions or its rationale for those

decisions in the cases and matters we reviewed.

• Obtained staffing and cost data estimates from DOJ and the FBI.

• Because CFTF’s work is ongoing, active investigation and

prosecution files were not available to us.
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5

Background

• In November 1996, DOJ’s Public Integrity Section (PI) initiated

an effort to collect, collate, and evaluate various press

allegations concerning violations of campaign finance laws in

the 1996 presidential election.

• This effort led to Attorney General Reno creating CFTF in

December 1996 to investigate alleged violations of campaign

finance laws (discussed below) and to prosecute those cases

where violations were believed to have occurred. Allegations

concerning the 1994 congressional election were subsequently

included in the Task Force’s scope.
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6

Background

• The Federal Election Campaign Act

• As it relates to campaign financing, the Federal Election

Campaign Act of 1971, as amended, 2 U.S.C. 431-455 (FECA),

generally applies only to financial transactions that are intended

to influence federal elections, i.e., campaigns for election to the

office of U.S. Representative, U.S. Senator, President, or Vice

President.

• FECA contains its own criminal provision, which generally

provides that FECA violations that are knowing and willful and

involve at least $2,000 may be prosecuted as misdemeanors.

According to DOJ, those FECA violations most likely to warrant

criminal prosecution involve schemes to influence a federal

candidate’s election by making contributions that are patently

illegal, through means calculated to conceal the scheme.
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7

Background

• According to DOJ, in general, to warrant criminal prosecution, a

FECA fraud must have subverted one of FECA’s “core”

provisions, which include, for example, the following:

• Limits on contributions from persons. Contributions from

“persons” may not exceed $1,000 to a federal candidate per

election; $20,000 to a national party committee per year; or

$5,000 to any other political committee per year. 2 U.S.C.

441a(a).

• No contribution from foreign nationals. Section 441e

prohibits any foreign national from making, directly or

through any other person, any contribution in connection

with any federal, state, or local election. It also prohibits any

person from knowingly soliciting or accepting such a

contribution.
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8

Background

• No disguised contributions. Section 441f makes it unlawful

for any person to make a contribution in the name of

another, or for any person to permit his or her name to be

used to make a contribution. A violation occurs if a person

gives funds to a straw donor, or conduit, for the purpose of

having the conduit pass the funds on to a federal candidate.

• No avoidance of FECA’ s disclosure requirements. Section

434 requires timely and accurate reporting of, among other

things, all contributions over $200 to federal candidates and

committees seeking to elect federal candidates and all

expenditures over $200 on behalf of federal candidates.
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9

Background

• According to DOJ, reporting violations are normally involved in

any aggravated scheme to subvert one of the other “core”

campaign financing provisions.

• For example, the use of conduits to disguise illegal

contributions to federal candidates is evidence of an intent to

interfere with the accurate reporting of campaign

contributions and to deliberately cause false information to

be conveyed to the Federal Election Commission, the

federal agency charged with overseeing FECA.
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10

Background

• Independent Counsel Statute

• The Independent Counsel Statute, 28 U.S.C. 591-599, which

expired June 30, 1999, required the Attorney General to decide

whether a criminal allegation involving a top official of the

executive branch of the federal government, such as the

President, Vice President, Cabinet officers, or the chairman or

treasurer of the national campaign committee seeking the

reelection of the President, was to be investigated by someone

outside of DOJ.

• The purpose of this legislation was to ensure both the

appearance and the reality of impartial prosecutive decisions

concerning the President and certain high-level government

and campaign officials.
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11

Background

• In general, under the Independent Counsel Statute, the

Attorney General had 30 days from the date of receipt of an

allegation that a covered official had committed a crime to

determine if there existed grounds to commence a

preliminary 90-day investigation. During this initial 30-day

inquiry, the Attorney General was to consider only the

specificity of the information received and the credibility of its

source.

• Under the statute, once a preliminary investigation

commenced, the Attorney General generally had 90 days to

determine if there were reasonable grounds to believe

further investigation was warranted. If the Attorney General

found that it was warranted, she made an application to a

special panel of federal judges for the appointment of an

Independent Counsel.
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12

Background

• In order to avoid potential conflicts, the act limited the

Attorney General’s authority and power during the initial

inquiry and the preliminary investigation phases to prevent

her from extensively participating in substantive

decisionmaking.

• As a result, during these phases, some of the Attorney

General’s normal investigative tools were prohibited. The

Attorney General was not allowed to convene a grand

jury, plea bargain, issue subpoenas, and grant immunity.
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13

Results - Initial Organization and Staffing

• In December 1996:

• Laura Ingersoll, a PI trial attorney, was placed in charge of

CFTF, which was a subunit of PI. She reported to PI’s chief.

• Jeff Lampinski, a Section Chief in the FBI’s Information

Resources Division, was named lead investigator on the Task

Force, reporting to a Deputy Assistant Director in the FBI’s

Criminal Investigative Division.

• Lee Radek, PI’s Chief, said that no formal mission statement was

prepared for the Task Force because he expected its investigation

to be handled in the same way as other high-priority cases within

the section. He anticipated that as additional targets or cases were

developed, they would be spun off to other PI trial attorneys. PI

was to apply its normal case review and oversight procedures to

CFTF.
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14

Results - Initial Organization and Staffing

(cont’d)

• When CFTF was first created, John Keeney, then Acting

Assistant Attorney General, Criminal Division, recused himself

of all CFTF matters because his son, a private attorney,

represented John Huang, one of the investigation’s targets.

• Mark Richard, a Criminal Division Deputy Assistant Attorney

General, was designated to oversee CFTF.

• Due to Mr. Keeney’s recusal, Mr. Richard reported directly

to the Deputy Attorney General and the Attorney General

and, thus, for Task Force purposes, fulfilled the role of

Assistant Attorney General.

• Neil Gallagher, then an FBI Deputy Assistant Director, was

designated to oversee Mr. Lampinski and the FBI’s

investigative efforts.
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15

Department of Justice Management and Oversight Structure

for the Campaign Finance Task Force - January 1997

Laura Ingersoll

Attorney-in-Charge

Campaign Finance Task Force

Lee Radek

Chief

Public Integrity Section

Mark Richard

Deputy Assistant Attorney General

Criminal Division

Department of Justice

Jeff Lampinski

FBI Lead Investigator

Campaign Finance Task Force

Neil Gallagher

FBI Deputy Assistant Director

Criminal Investigative Division

Louis Freeh

Director

Federal Bureau of Investigation

Attorney General

Deputy Attorney General

Department of Justice

Results - Initial Organization and Staffing

(cont’d)
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16

Results - Initial Organization and Staffing

(cont’d)

• Initially, 20 FBI agents, 2 Department of Commerce Office of Inspector

General agents, 3 FBI financial analysts, 2 FBI intelligence research

specialists, 1 FBI secretary, 4 PI attorneys, and a PI paralegal

constituted the Task Force.

• In January 1997, CFTF’s investigative and prosecutive resources

were co-located in the same offices.

• Subsequently, according to DOJ and FBI officials, between February

and September 1997, 24 FBI agents, 9 intelligence research

specialists, 3 attorneys, and 5 administrative support personnel were

added to CFTF headquarters. One other attorney worked part-time

coordinating intelligence issues. In August 1997, two Internal Revenue

Service agents were brought in to review all cases for tax issues.
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17

Results - Initial Problems and Obstacles

• Strained Working Relationships Ms. Ingersoll and Mr. Lampinski,

respectively, characterized their working relationship as not very effective

and strained. In addition, according to two FBI Task Force officials, agents

complained about PI attorneys’ excessive participation in traditional

investigative functions, especially interviews of witnesses where agents

felt they were being used mainly as note takers.

• Mr. Radek confirmed that tensions existed between attorneys and

agents over the extent of attorney involvement in investigations. He

added that disagreements over the threshold of information required to

trigger a recommendation for an Independent Counsel also adversely

affected their relationship. Mr. Radek said that as a result, issues of

trust arose and the FBI resisted the team concept.

• Moreover, Mr. Radek believed the press created expectations for a

major scandal, rather than allowing the investigative process to make

that determination. As a result, he said it was particularly important for

the investigation to be thorough and not perceived as political.
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18

Results - Initial Problems and Obstacles

(cont’d)

• According to Mr. Gallagher, contentious divisions arose

between the FBI and DOJ over several issues, including the

applicability of the Independent Counsel statute. Mr. Gallagher

believed that Mr. Radek’s criteria for what information was

needed to trigger the seeking of an Independent Counsel were

too stringent. Moreover, concerns over leaks to the media about

Task Force progress and problems added to mutual trust

concerns.

• Although both the attorneys and investigators held strong views on

these issues, they believed the process for arguing their positions

was fair. Mr. Lampinski said that disagreements between Ms.

Ingersoll and him were elevated to their supervisors and in some

cases to Mr. Richard. He described Mr. Richard as a fair mediator

and said that no one ever told the investigators to back away from

an investigation. He said the Attorney General and Director Freeh

got involved only when Independent Counsel statute issues arose.
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19

Results - Initial Problems and Obstacles

(cont’d)

• Disagreement over Investigative Approach: The attorneys’

investigative approach was to build cases from the ground up

and investigate wherever the evidence led. The lead

investigator, on the other hand, wanted to pursue several

investigative tracks simultaneously.

• DOJ officials believed protecting the investigative process

was important, and this meant having sufficient predication

to justify an investigative direction.

• One of DOJ’s concerns was to avoid prematurely tipping off

potential witnesses and/or investigative targets or targeting

individuals before sufficient predication was established. Mr.

Radek did not believe specific predication existed at that

time to justify all the investigative tracks proposed by the

investigators.
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20

Results - Initial problems and obstacles

(cont’d)

• Mr. Gallagher said he and Mr. Radek disagreed on the investigative

strategy. Mr. Gallagher said that on the basis of news reports

concerning White House coffees for campaign contributors, one of

the tracks the FBI wanted to investigate was whether the White

House had violated campaign finance laws. Mr. Gallagher said that

the FBI believed that its investigative efforts were always under a

microscope and subject to enormous scrutiny and second-guessing.

• Because of PI’s oversight of matters relating to the Independent

Counsel statute, the overall approach taken by the Task Force

was very conservative; that is, building cases from the ground up.

• Mr. Radek said that he believed that the FBI was too anxious to

recommend the need for an Independent Counsel and that in his

opinion the information gathered did not justify seeking the

appointment of an Independent Counsel. He added that their

disagreement over this issue had a devastating impact on the

relationship between the FBI and PI.
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21

Results - Initial Problems and Obstacles

(cont’d)

• The need to appoint an Independent Counsel continued to

be an area of disagreement.

• In November 1997, FBI Director Freeh recommended to

the Attorney General that she appoint an Independent

Counsel.

• Then, in July 1998, the then Supervising Attorney of the

Task Force also recommended that the Attorney General

appoint an Independent Counsel.

• In both instances, the Attorney General decided not to

appoint an Independent Counsel.
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22

Results - Initial Problems and Obstacles

(cont’d)

• Management and Analysis of Evidence: CFTF was overwhelmed with

documents and other evidence and lacked sufficient resources to

address this problem. Mr. Lampinski said that CFTF was receiving

about 60 boxes of documents a day and had acquired over 2 million

pages of documents. The FBI had to copy, index, and enter all

documents into an electronic data management system that would

support search and full retrieval capabilities. After several months, the

system became overwhelmed and a new system had to be purchased.

• According to Ms. Ingersoll and Mr. Lampinski, it took months to

input backlogged documents into the new system, which

significantly hindered efforts to assess the documents’ importance

to the investigation and their relationship to other evidence.

• Mr. Lampinski said that by mid-February 1997, he had recognized

the problem and subsequently sought to get resources to input the

documents but had difficulty obtaining the FBI staffing he needed.
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23

Results - Initial Problems and Obstacles

(cont’d)

• Mr. Lampinski said that efforts to obtain additional staff

resources were delayed due to the process used to fill positions.

At that time, the Criminal Justice Information Systems Division

was moving its operations to West Virginia. The FBI was trying

to help employees who did not want to move to West Virginia

find other jobs at headquarters and decided that these

employees should have the first opportunity at CFTF positions.

However, according to Mr. Lampinski, the process of selecting

individuals for these positions took 5 or 6 months to complete as

positions had to be advertised, applications reviewed, career

boards established, and applicants interviewed and selected.

• Mr. Gallagher said that in late spring 1997, the document

management problems became evident.
B-284908

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24

Results - Initial Problems and Obstacles

(cont’d)

• In June 1997, on the basis of the FBI’s proposed multiple-track

investigative strategy, Director Freeh directed CFTF investigators

to interview over 100 individuals. Many of those interviewed were

not as yet the focus of CFTF efforts, including a number of White

House and Democratic National Committee employees.

• According to Mr. Radek, using CFTF investigators to interview

additional individuals at this point diverted them from assessing

the significance of documents already obtained. Moreover, Mr.

Radek said he did not believe there was sufficient predication at

the time to justify conducting all the interviews.

• Ms. Ingersoll said that as a result of the interviews, about 90

percent of the Task Force’s investigative resources were

unavailable for about 2 to 3 weeks.

• The document management problems continued into late 1997.
B-284908

Page 32 GAO/GGD-00-101BR Campaign Finance Task Force

25

Results - Initial Problems and Obstacles

(cont’d)

• Congressional/media impacts: According to CFTF officials, parallel

congressional investigations and media reports during this period led

to internal DOJ pressures and decisions that required CFTF to divert

its efforts to address these external events.

• For example, CFTF officials had to work with the congressional

committees to coordinate CFTF and congressional documentation

requests. CFTF also had to divert investigators to interview

individuals identified as possible witnesses at congressional

hearings although they had not as yet been earmarked for

interview. The normal approach would be to first analyze

information collected and use those analyses as a basis for the

interviews.

• Mr. Lampinski said that the need to divert resources to interview

possible congressional witnesses had a negative impact on the

Task Force’s progress.
B-284908

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26

Results - Initial Problems and Obstacles

(cont’d)

• Mr. Radek said that CFTF efforts became unfocused as it

attempted to ensure that if the Attorney General inquired

about a news report, CFTF would already have information

on it and not be caught by surprise disclosures.

• Lack of Foreign Country Cooperation: CFTF had difficulty

obtaining evidence and interviewing subjects in certain foreign

countries. According to DOJ, in many of these countries, legal

assistance treaties do not exist. Although they may cooperate

on crimes viewed as serious, some countries considered

campaign finance violations to be internal U.S. political

problems and were not as willing to cooperate. As a result,

investigations of certain individuals were hampered and

allegations of a foreign conspiracy to influence the presidential

election could not be fully investigated, according to DOJ.
B-284908

Page 34 GAO/GGD-00-101BR Campaign Finance Task Force

27

Results - Management and Organizational

Changes (Sept. 1997)

• In the fall of 1997, displeased with the investigation’s slow pace,

disclosures in the press that critical leads were not being pursued,

and internal frictions plaguing CFTF, the Attorney General and FBI

Director Freeh decided to replace CFTF’s leadership.

• Charles LaBella, 1st Assistant U.S. Attorney in San Diego and

James DeSarno, a former Special Agent-in-Charge of the FBI’s

New Orleans Field Office, were selected to lead the Task Force.

• Mr. LaBella was told that the Task Force needed more focus,

direction, and aggressive leadership.

• Mr. DeSarno was told that the investigation was moving too

slowly and that there were evidential and staffing issues that

needed to be addressed.
B-284908

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28

Results - Management and Organizational

Changes (Sept. 1997)(cont’d)

• Mr. DeSarno said that one of the reasons he was selected

was because he was high enough in the FBI organization to

coordinate across FBI divisional lines and obtain

cooperation and support in addressing issues and problems

he identified.

• Ms. Ingersoll stayed with the Task Force for a short period after

Mr. LaBella took over.

• Mr. Lampinski remained with the Task Force and maintained

much the same role he had before: managing agents and cases

and overseeing case assignments and investigative strategies.
B-284908

Page 36 GAO/GGD-00-101BR Campaign Finance Task Force

29

Department of Justice Management and Oversight Structure

for the Campaign Finance Task Force Subsequent to September 1997

Lee Radek

Chief - Public Integrity Section

Advisory Role

Los Angeles Suboffice

Campaign Finance Task Force

Charles LaBella

Supervising Attorney

Campaign Finance Task Force

Mark Richard

Deputy Assistant Attorney General

Criminal Division

Department of Justice

Neil Gallagher

Deputy Assistant Director

Criminal Investigative Division

Jeff Lampinski

FBI Lead Investigator

James DeSarno

FBI Supervising Investigator

Campaign Finance Task Force

Louis Freeh

Director, FBI

Robert Bryant

Deputy Director

Attorney General

Deputy Attorney General

Department of Justice

Results - Management and Organizational

Changes (Sept. 1997)(cont’d)
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Results - Management and Organizational

Changes (Sept. 1997)(cont’d)

• Both Messrs. LaBella and DeSarno recognized the need to

streamline CFTF’s oversight structure.

• Mr. LaBella insisted on a more direct chain of command.

Subsequently, he reported directly to Mr. Richard, and Mr.

Radek assumed an advisory role. However, Mr. Radek

continued a direct role whenever Independent Counsel

statute issues arose, as PI maintained primary responsibility

for initial inquiries and preliminary investigations related to

the statute.

• Mr. DeSarno said that he reported directly to FBI Deputy

Director Robert Bryant and Director Freeh. Upon Mr.

DeSarno’s arrival, Mr. Gallagher no longer had to take on as

formal a role in the Task Force. However, he still attended

weekly meetings and was involved in briefing the Director.
B-284908

Page 38 GAO/GGD-00-101BR Campaign Finance Task Force

31

Results - Management and Organizational

Changes (Sept. 1997)(cont’d)

Organization Chart Showing Public Integrity

Section Responsibility for Independent Counsel

Matters

Investigators

Federal Bureau of Investigation

Chief

Public Integrity Section

Deputy Assistant Attorney General

Criminal Division

Assistant Attorney General

Criminal Division

Attorney General

Deputy Attorney General
B-284908

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Results - Management and Organizational

Changes (Sept. 1997)(cont’d)

• Mr. DeSarno believed CFTF should be structured more like a field

office, with investigators separated from attorneys. With Mr.

LaBella’s concurrence, investigators were moved to another floor in

the building, which allowed the FBI to maintain greater investigative

control of the cases.

• Mr. LaBella said that he quickly realized that CFTF’s biggest problem

was understaffing -- too few agents and attorneys for the number of

cases that it had. As a result, documents went unreviewed and

investigative leads were not followed. Mr. LaBella also noted that the

experience level of the Task Force attorneys was not sufficient to

address pending investigations. As a result, he brought three

experienced Assistant U.S. Attorneys with him from San Diego.

• Since then, according to several CFTF managers, the Task Force has

not had a problem getting resources. Both the Attorney General and

Director Freeh have been very helpful in getting needed resources.
B-284908

Page 40 GAO/GGD-00-101BR Campaign Finance Task Force

33

Results - Management and Organizational

Changes (Sept. 1997)(cont’d)

• Ms. Ingersoll said that she had been requesting more

resources for some time and had formally submitted a

written request for additional resources just prior to Mr.

LaBella’s appointment to replace her.

• About the time of Messrs. LaBella’s and DeSarno’s arrival,

CFTF received a significant increase in investigative and

prosecutive resources.

• Mr. DeSarno said that soon after taking over the Task Force,

he was able to get 90 FBI support personnel detailed shortterm to address the backlog of documents to be indexed and

entered into the new electronic database.
B-284908

Page 41 GAO/GGD-00-101BR Campaign Finance Task Force

34

Results - Management and Organizational

Changes (1998 - 1999)

• In June 1998, James Robinson was confirmed as Assistant

Attorney General for the Criminal Division and acquired

responsibility for CFTF. Mr. Richard then reported through

Mr. Robinson.

• July - August 1998:

• David Vicinanzo, former Chief of the Criminal Division in

the New Hampshire U.S. Attorneys Office, replaced Mr.

LaBella as Supervising Task Force Attorney. Mr. LaBella

returned to San Diego to become Acting U.S. Attorney for

the Southern District of California.

• Mr. Lampinski replaced Mr. DeSarno, who was designated

to head the FBI’s Criminal Justice Information Systems

Division.
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• In March 1999, Michael Horowitz, a Deputy Assistant

Attorney General in the Criminal Division, replaced Mr.

Richard in overseeing the Task Force.

• In June 1999, FBI Supervisory Special Agent David Reign,

who was already a member of the Task Force, replaced Mr

Lampinski, who was designated Special Agent-in-Charge of

the FBI’s Louisville, KY, Field Office.

• In September 1999, Mr. Vicinanzo returned to the New

Hampshire U.S. Attorneys Office but continued to consult

with CFTF. He was subsequently replaced in December

1999 by Assistant U.S. Attorney Robert Conrad, Chief of the

Criminal Section in the Western District of North Carolina.

Results - Management and Organizational

Changes (1998 - 1999)(cont’d)

Note: Additional management changes have taken place since December 31, 1999
B-284908

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Results - CFTF Organization Chart, as of

December 31, 1999

Department of Justice Management and Oversight Structure

for the Campaign Finance Task Force - December 31, 1999

Lee Radek

Chief

Public Integrity Section

Advisory Role

Los Angeles Suboffice

Campaign Finance Task Force

Robert Conrad

Supervising Attorney

Campaign Finance Task Force

Michael Horowitz

Deputy Assistant Attorney General

Criminal Division

James Robinson

Assistant Attorney General

Criminal Division

Department of Justice

David Reign

FBI Lead Investigator

Campaign Finance Task Force

Louis Freeh

FBI Director

Thomas Pickard

Deputy Director

Attorney General

Deputy Attorney General

Department of Justice
B-284908

Page 44 GAO/GGD-00-101BR Campaign Finance Task Force

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Results - Management and Oversight

• According to CFTF managers interviewed, Task Force oversight has been

accomplished in several ways:

• Since Mr. LaBella arrived, weekly Attorney General briefings have been

held to keep her informed of CFTF progress, problems, and needs.

Participants have included, among others, the Deputy Attorney

General; the Attorney General’s Counsel; Mr. Robinson; Mr. Radek;

Mr. Horowitz; Mr. Richard; the FBI’s General Counsel; and CFTF’s

Lead Investigator and Supervising Attorney.

• Director Freeh had periodic CFTF discussions with his executive staff.

• Task Force managers met weekly with staff attorneys and investigators

to discuss case strategy, progress, and problems on each ongoing

investigation and prosecution.

• Managers have been apprised daily, as needed, of important

developments that may affect cases.
B-284908

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Results - Management and Oversight

(cont’d)

• Case management - prosecutions:

• CFTF prosecutors said that when prosecutions were believed to be

justified, senior Task Force managers and attorneys met with case

attorneys and investigators to review and comment on prosecution

memoranda. Prosecution memos were to be forwarded up the

chain-of-command for information purposes, and the Attorney

General and the Director were to be briefed.

• We found evidence of high-level DOJ reviews, including the

Attorney General and/or the Deputy Attorney General, in three of

the five cases we reviewed (Johnny Chung, John Huang, and

Yah Lin “Charlie” Trie). In two cases (Franklin Haney and Howard

Glicken), we did not see evidence of high-level reviews of the

prosecution memo nor, in Glicken’s case, the plea agreement.

(We should note, however, that the absence of documentary

evidence on these case documents does not necessarily mean

that supervisory reviews did not occur.)
B-284908

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39

Results - Management and Oversight

(cont’d)

• Case management - declinations:

• Procedurally, both DOJ and FBI concurrence was required to

decline prosecution on an investigation. The FBI indicated that

CFTF’s lead investigator was authorized to sign off on

declinations although in one instance Director Freeh signed off.

• Our review of five matters declined for prosecution showed

FBI and DOJ concurrence. In those five matters, we were

told that evidence was not sufficient to prove that a crime

had been committed.

• Since Mr. LaBella’s tenure, PI has served in an exclusively

advisory capacity, except for matters or issues that related to

the Independent Counsel Statute.
B-284908

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Results - Staffing Trends

• CFTF staffing has fluctuated depending on its operational phase.

• When CFTF was established, the investigation was only

beginning and its scope was still unknown. As more

information was developed, staffing grew.

• In the summer and fall of 1997, CFTF staffing began to

increase rapidly, reaching its peak in late 1997.

• As of December 31, 1999, CFTF had completed 70 of the 121

investigations it had initiated and was focusing on completing

its work on the 51 ongoing. As a result, staffing has

decreased significantly.
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41

• In January 1997, there were 4 attorneys, 22

agents, and 7 support staff.

• In April 1997, CFTF had grown to 7 attorneys,

32 agents, and 16 support staff.

• By the end of August 1997, CFTF staff

numbered 77, which included 8 attorneys; 48

agents; and 21 support staff

• At its peak, in November 1997, staff

numbered 126, including 24 attorneys, 67

agents, and 35 support staff.

• As of December 31, 1999, staff numbered 48,

including 13 attorneys, 12 agents, and 23

support staff. Jan. 1997

Apr. 1997

Aug. 1997

Nov. 1997

Dec. 1999

Attorneys

Agents

Support

Results - Staffing Trends (cont’d)

Note: Support staff included computer support, paralegal, intelligence research staff, financial

analysts, and clerical.
B-284908

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Results - Estimated CFTF Costs

• Justice Department Costs:

• Fiscal Year 1997 - $1.0 million

• Fiscal Year 1998 - $2.1 million

• Fiscal Year 1999 - $2.1 million

• FBI Costs:

• Fiscal Year 1996 - $10,000 (equipment purchased

in FY 1996 but transferred to CFTF in FY 1997)

• Fiscal Year 1997 - $5.2 million

• Fiscal Year 1998 - $16.1 million

• Fiscal Year 1999 - $4.7 million
B-284908

Page 50 GAO/GGD-00-101BR Campaign Finance Task Force

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Results - Prosecution Efforts, as of

March 31, 2000

• Prosecutions - 24

• Convictions - 16

(15 plea bargains)

• Acquittals/hung juries- 2

• Trials pending - 6

Note: See summary of prosecutions, slides 47 – 52.
B-284908

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44

Results - FECA Limitations May Inhibit

Prosecution Efforts

• Limitations in FECA penalties and statute of limitations:

• According to DOJ and FBI officials, the penalties for violating

FECA campaign finance provisions need strengthening.

• Mr. Horowitz stated that FECA’s prescribed penalties have

adversely affected CFTF’s investigative efforts in that they are

not severe enough to encourage cooperation by those being

investigated to reveal the participants and the extent of the

campaign finance scheme. Noting FECA’s weak penalties, Mr.

DeSarno stated that he was unaware of any area where Justice

and the FBI put in so much effort for such a small return.

• According to Mr. Horowitz, FECA violations are penalized as

misdemeanors no matter the extent or amount of the

violation. Moreover, the criminal penalties do not

differentiate between donors or conduits.
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Results - FECA Limitations May Inhibit

Prosecution Efforts (cont’d)

• Commenting on how FECA violations were being treated by the

courts, Mr. Horowitz stated that there is no current sentencing

guideline for FECA violations. Therefore, judges usually use

the closest, most analogous guidelines, which deal with fraud.

• Using analogous fraud guidelines and considering the (a)

first-time offense of those convicted and (b) lack of material

loss involved, judges have sentenced most campaign

finance violators to supervised probation and community

service.

• Generally, jail time or witness cooperation was obtained only

in those cases where offenders were found to have

committed other more serious violations, such as mail or

wire fraud or income tax violations.
B-284908

Page 53 GAO/GGD-00-101BR Campaign Finance Task Force

46

Results - FECA Limitations May Inhibit

Prosecution Efforts (cont’d)

• According to Mr. Horowitz, another problem with FECA is its

3-year statute of limitations. The statute of limitations for

most crimes is 5 years and for some crimes even longer.

• This shortened statute of limitations is even more

problematic in that the clock for the limitation generally

starts when the check is written, not when the contribution

report is filed. Thus, several months can pass before

enforcement officials learn of a possible violation, further

shortening the time prosecutors and investigators have to

establish and file a case.

• As of December 31, 1999, legislation was pending in both

the House and Senate to strengthen the criminal penalties

for FECA violations.
B-284908

Page 54 GAO/GGD-00-101BR Campaign Finance Task Force

47

Summary of Prosecutions

(As of March 31, 2000)

Defendant and court

district Summary of charges Disposition of case Sentencing

U.S. v. David Chang

District of New Jersey,

January 7, 2000 and

March 31, 2000

4 counts of violating Title 18

(Conspiracy, Obstruction of

Justice, Witness Tampering)

Trial scheduled for

June 6, 2000

Trial pending

U.S. v. Audrey Yu,

District of New Jersey,

January 7, 2000 and

March 31, 2000

11 counts of violating Title 18

(Perjury Before the Grand Jury,

Conspiracy, Obstruction of

Justice, and Witness Tampering)

Trial scheduled for

June 6, 2000

Trial pending

U.S. v. Pornpimol “Pauline”

Kanchanalak & Duangnet

“Georgie” Kronenberg

District of Columbia,

November 13, 1998

15 counts of violating Title 18

(Conspiracy, Causing False

Statements) and 1 count of

violating Title 2 (Causing

Contribution by Foreign National)

Trial scheduled for

November 13, 2000

Trial pending

U.S. v. Mark B. Jimenez,

Southern District of Florida,

April 15, 1999

43 counts of violating Title 18

(Conspiracy, False Statements,

and Aiding and Abetting), violating

Title 2 (Causing Conduit

Contributions, Aiding and

Abetting), and 4 counts of

violating Title 26 (Tax Evasion

and Fraud)

DOJ pursuing Jimenez’

extradition from the

Philippines

Trial pending
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48

Defendant and court

district Summary of charges Disposition of case Sentencing

U.S. v. Mark B. Jimenez,

District of Columbia,

September 30, 1998

17 counts of violating Title 18

(Conspiracy, False Statements,

and Aiding and Abetting) and

Title 2 (Causing, Aiding and

Abetting)

DOJ pursuing extradition

from the Philippines

Trial pending

U.S. v. Yuan “Antonio” Pan,

District of Columbia,

January 29, 1998

4 counts of violating Title 18

(Conspiracy to Defraud, Impair

and Impede the FEC, Wire

Fraud, Aiding and Abetting)

Yuan Pan is currently a

fugitive

Trial pending

U.S. v. Carmine Alampi,

District of New Jersey,

December 1, 1999

1 count violation of Title 18

(Funneling Illegal Contributions

to a 1996 Senate Campaign)

and Title 2 (Illegal Conduit

Contribution)

Pled guilty to 1 Count

Illegal Campaign

Contributions

December 1, 1999

Sentencing date pending

U.S. v. Lawrence Penna

Southern District, New York,

September 15, 1999

1 count violation of Title 18

(Conspiracy to Impede the

Reporting Functions of the FEC)

Pled guilty to 1 count

Conspiracy to Impede

Reporting Functions of

the FEC

September 15, 1999

Delayed pending

Penna’s cooperation

U.S. v. Berek Don

District of New Jersey,

March 5, 1999

1 count violation of Title 18

(Conspiracy to Funnel Illegal

Contributions to a 1996 Senate

Campaign)

Pled guilty to Making

Illegal Contributions to

1996 Senate campaign

May 27, 1999

Sentencing date pending

Summary of Prosecutions

(As of March 31, 2000)
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49

Defendant and court

district Summary of charges Disposition of case Sentencing

U.S. v. Maria Hsia (Hsia

Ling) District of Columbia,

February 18, 1999

6 counts of violating Title 18

(Conspiracy, False Statements,

and Willfully Causing the

Commission of an Offense)

Found guilty on 5 counts

of Causing False

Statements to be made to

the FEC

March 2, 2000

Sentencing date

August 18, 2000

U.S. v. Yogesh Gandhi

Northern District of

California,

August 5, 1998 and

March 9, 1999

1 count of violating Title 18 (Mail

Fraud) and violation of Title 26

(Tax Evasion, and Violating

Federal Election Laws)

Pled guilty to Mail Fraud,

Tax Evasion, and

Violating Federal Election

Laws

June 25, 1999

December 5, 1999

1 year imprisonment, 2

years supervised

release, and $237,299

restitution

U.S. v. Yah Lin "Charlie"

Trie, District of Columbia,

January 29, 1998 and

Eastern District of

Arkansas,

November 9, 1998

Violations of Title 18 (Conspiracy

to Defraud, Impair and Impede

the FEC, Mail and Wire Fraud,

Aiding and Abetting, False

Statements, Witness Tampering,

Conspiracy to Obstruct Justice

and Congressional Investigation)

and 1 count violation of Title 18

(Causing False Statements to

FEC) and 1 count violation of

Title 2 (Making Political

Contributions in the Name of

Another)

Pled guilty to 2 counts of

campaign financing

violations (Causing a

False Statement to be

Made to FEC and

Causing Conduit

Contributions to be made

to the DNC)

May 21, 1999

November 1, 1999

3 years probation

(including 4 months of

home detention), 200

hours of community

service, and $5,000 fine

Summary of Prosecutions

(As of March 31, 2000)
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Summary of Prosecutions

(As of March 31, 2000)

Defendant and court

district Summary of charges Disposition of case Sentencing

U.S. v. Jian-Nan “John”

Huang

Central District of Columbia,

May 25, 1999

1 felony count violation of

Campaign Finance Laws

Pled guilty to a felony

conspiracy charge

August 2, 1999

August 12, 1999

1 year probation, 500 hours

community service, and

$10,000 fine

U.S. v. Robert Lee

Central District of California,

April 6, 1999

Violations of Title 18 (Aiding

and Abetting Illegal Foreign

Campaign Contributions)

Pled guilty to Aiding and

Abetting Illegal Foreign

Campaign Contributions

April 26, 1999

August 16, 1999

3 years probation, 250

hours of community service

U.S. v. Juan C. Ortiz

District of Columbia,

December 17, 1998

Violation of Title 2 (Conduit

Contributions) and Title 18

(Aiding and Abetting)

Pled guilty to Acting as

Conduit Contributor and

Aiding and Abetting Illegal

Campaign Contributions

March 23, 1999

March 23, 1999

2 years probation, $20,000

in fines, and 200 hours of

community service

U.S. v. Future Tech

International Inc.

District of Columbia,

December 17, 1998

Violations of Title 26

(Tax Evasion)

Pled guilty to 2 counts of

Tax Evasion

October 5, 1998

February 5, 1999

$1 million in fines and

payment of all back taxes

and penalties

U.S. v. Johnny Chung

Central District of California,

March 5, 1998

Violations relating to Title 26

(Tax Evasion) and Title 18

(Bank Fraud and

Conspiracy to Violate the

Federal Election Campaign

Act)

Pled guilty to Bank Fraud,

Tax Evasion, and 2

misdemeanor violations of

Conspiracy To Violate

Federal Election Laws

March 5, 1998

December 14, 1998

Probation and 3,000 hours

of community service
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Summary of Prosecutions

(As of March 31, 2000)

Defendant and court

district Summary of charges Disposition of case Sentencing

U.S. v. Howard Glicken

District of Columbia,

July 9, 1998

Violating Title 2 (Criminal

Violation of Federal Election

Campaign Act) and 1 count

of Violating Title 18

(Causing, Aiding and

Abetting)

Pled guilty to Causing a

Political Contributions to be

Made by a Foreign

National and Procuring a

Conduit Contribution

July 20, 1998

November 24, 1998

18 months probation,

$80,000 fine, and 500

hours of community

service

U.S. v. Michael Brown

District of Columbia,

August 28, 1997

Violations of Title 2

(Exceeding Dollar Limits on

Contributions and Violating

Federal Election Campaign

Act)

Pled guilty to violating Title

2 (Exceeding Contribution

Limit)

August 28, 1997

November 21, 1997

3 years supervised

probation, $5,000 fine,

and $7,800 in

restitutions

U.S. v. Gene Lum

District of Columbia,

May 21, 1997

Violating Title 18

(Conspiracy to Defraud the

United States and Cause

False Statements to be

Made to the FEC)

Pled guilty to Conspiracy

August 5, 1997 and

Filing False Tax Returns

August 13, 1998

June 3, 1999

2 years in prison, 5

months in half-way

house, 5 months in

home detention, and

$30,000 fine

U.S. v. Nora Lum

District of Columbia,

May 21, 1997

Violating Title 18

(Conspiracy to Defraud the

United States and Cause

False Statements to be

Made to the FEC)

Pled guilty to Conspiracy

June 5, 1997

September 9, 1997

5 months in half-way

house, 5 months in

home detention, and

$30,000 fine
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Summary of Prosecutions

(As of March 31, 2000)

Defendant and court

district Summary of charges Disposition of case Sentencing

U.S. v. Trisha Lum

District of Columbia,

May 12, 1997

Violations of Title 2 (Making

Contribution in the Name of

Another and Penalty for

Violation of Federal Election

Campaign Act)

Pled guilty to violating

Title 2 (Making

Conduit Contribution)

June 5, 1997

August 27, 1997

3 years of supervised

probation, 150 hours of

community service,

$5,000 fine, and $7,800 in

restitutions

U.S. v. Franklin Haney

District of Columbia,

November 4, 1998

42 counts of violating Title 18

(Conspiracy, False Statements,

and Causing an Illegal Act to be

Done) and Title 2 (Criminal

Violations of the Federal

Election Campaign Act and

Making Contributions in

Another's Name)

Acquitted

June 30, 1999

N/A

U.S. v. Maria Hsia (Hsia

Ling) Central District of

California,

July 7, 1998

Violations of Title 18

(Conspiracy, False Statements,

and Willfully Causing the

Commission of an Offense)

Jury hung (7-5)

June 7, 1999

Case was not retried

by Justice and a

motion to dismiss was

filed

June 21, 1999

N/A
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