:FOLEY 

FOLEY & LARDNER LLP 

June 26, 2012 

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WRITER'S DIRECT LINE 

202.295.4081 

cmitchell@foley.com EMAIL 

CLIENT/MATTER NUMBER 

098295-0101 

Ms. Camilla Reminsky 

Mr. Marty Favin 

Audit Division 

Federal Election Commission 

999 E Street, NW 

Washington, DC 20463 

RE: Interim Audit Report of Friends of Sharron Angle 

Dear Ms. Reminsky and Mr. Favin: 

The undersigned serves as counsel to Friends of Sharron Angle, the principal authorized 

committee of Sharron Angle, Republican nominee for the US Senate from Nevada in 2010 ("the 

Committee"). We are in receipt of the May 7,2012 Interim Report of the Audit Division ofthe 

Federal Election Commission ("FEC") regarding the audit of the Committee ("the Report"). This is 

the response of the Committee to the Report. 

There are two primary findings of the audit staff regarding the Committee: 

1. Failure to File 48-Hour Notices of Late Contributions. The Report found that the Committee 

flailed to tile timely 48-hour notices of primary contributions from 81 donors representing $128,300 

and similarly failed to file 48-hour notices of general election contributions from 88 donors 

representing $115,450. 

The Committee makes no excuses for failure to timely file the required notices. In reviewing 

the intemal procedures and systems in place during the primary, which were upgraded during the 

general election, to try and ascertain why the 48-hour reports were not filed as required, it appears 

that the volume of contributions simply resulted in some minimal number falling through the cracks. 

By way of background, the Committee represented a candidate who was a true grassroots, tea 

party candidate, who was running against the U.S. Senate Majority Leader and, accordingly, became 

a national candidate virtually ovemight after she was endorsed by the Tea Party Express on April 15, 

2010. 

BOSTON 

BRUSSELS 

CHICAGO 

DETROIT 

JACKSONVILLE 

LOS ANGELES 

MADISON 

MIAMI 

MILWAUKEE 

NEW YORK 

ORLANDO 

SACRAMENTO 

SAN DIEGO 

SAN DIEGO/DEL MAR 

SAN FRANCISCO 

SHANGHAI 

SILICON VALLEY 

TALLAHASSEE 

TAMPA 

TOKYO 

WASHINGTON, D.C. 
: FOLEY 

FOLEY & LARDNER LLP 

Ms. Camilla Reminsky 

Mr. Marty Favin 

June 26,2012 

Page 2 

Sharron Angle was not the favored 'establishment' candidate in the GOP primary, but began 

to receive small dollar contributions from across the country in the May, 2010 time frame. That 

fundraising experience snowballed further after she won the June 2010 Nevada GOP primary. 

In the third quarter of 2010, the Committee raised $14 million from 194,000 donors, most of 

them in amounts under $200 (96%). The management of, accounting for and reporting the volume 

and number of donors and contributions were essentially equal to a presidential campaign - but 

without the massive infrastmcture of a presidential campaign to handle such a volume. 

Contributions were arriving via direct mail to the mail vendor's caging company, through 

online contributions to that fundraising vendor and through contributions sent directly to the 

campaign at both the Reno and Las Vegas offices. The campaign raised $3+ million in July 2010, 

$4+ million in August 2010, $7+ million in September 2010, $3.5+ million between October 1,2010 

and October 13, 2010, and another $6,264,509 between October 14 and November 22,2010. 

The various fimdraising and compliance vendors and the finance director all have expressed 

utter dismay and surprise at the news there were any unreported late contributions, because they each 

believed that they had put mechanisms in place to ensure that did not happen. Indeed, it was the 

practice ofthe finance director to call each of the vendors and the compliance consultant every day 

during the last twenty days before the general election to go over the reportable contributions and to 

try to make certain that every reportable contribution was, in fact, being reported. 

Again, not as an excuse, but by way of explanation, the amount ofthe unreported general 

election late contributions ($115,450) represents less than 2% of the total contributions received 

during the period from and after October 14, 2010 and demonstrates the volume of contributions from 

multiple sources that were being processed in a very short period of time. 

With regard to the primary election, the infrastmcture was less formal but even then, the 

treasurer made a yeoman effort to understand and follow the FEC regulations. Only $31,200 

representing 21 primary donors were not filed at all and another $97,100 in such contributions from 

60 donors were filed either late or after the primary. 

The Committee reported properly more than $717,000 in late contributions prior to the 

general election, but somehow didn't file the necessary reports for the 88 donors whose contributions 

should have been included in the daily reports filed between October 15 and November 1, 2010 but 

were not. 

Such mistakes constitute inadvertent errors, with absolutely no intent to fail to comply with 

the law. 
: FOLEY 

FOLEY & LARDNER LLP 

Ms. Camilla Reminsky 

Mr. Marty Favin 

June 26, 2012 

Page 3 

The bottom line is that there was a good faith effort by the Committee to comply fiilly with 

the late filing requirements, both during the primary which operated almost entirely with volunteers, 

and on through the general election with a small but capable fundraising and compliance team. 

There were systems in place which apparently were not sufficient to handle the massive 

contributions being processed from multiple sources and the Committee regrets the errors. 

2. Failure to Report Debts. The Report also found that there were $2,287,080 in debts that were not 

reported by the Committee on the 2010 October Quarterly and 2010 Pre-General Reports. The 

Committee's FEC reports have now been amended to reflect the debts identified by the Report. 

Apparently the information regarding the status of the unpaid invoices was not forwarded in a 

systematic and understandable manner from the vendor(s) to the Committee and its compliance 

consultant in order for the unpaid invoices to be reconciled to the payments and any outstanding / 

unpaid amounts timely reported to the FEC as debts. This appears to have been a breakdown in 

communications because each of the vendors was operating under the impression that the information 

had been timely and properly forwarded to the Committee, but somehow the Committee didn't realize 

that the information was either reportable, or that it had been received, or that it wasn't forwarded to 

the compliance consultant for reporting purposes. Whatever the cause of the breakdown, the amounts 

apparently were not timely reported as debts. 

In addition to amending its FEC reports, the Committee has also notified each of the 

fundraising vendors involved in the campaign that they should review their intemal 

procedures to make certain that their protocols for forwarding reportable information are 

updated and made more understandable and transparent in order to ensure compliance with 

the FEC reporting obligations of the Committees they serve. 

This constitutes the Committee's response to the Report. Please contact me at (202) 

295-4081 if you have any questions. Thank you. 

Sincerely, 

/cat. 

Cleta Mitchell, Counsel 

Friends of Sharron Angle