FEDERAL ELECTION COMMISSION 

WASHINGTON, D.C. 20463 

February 19, 2010 

MEMORANDUM 

TO: 

FROM: 

Joseph F. Stoltz 

Assistant StaffDirector 

Christopher Hughey 

Deputy General Counsel 

Lawrence L. Calvert, Jlr:''^"^' 

Associate General Coiins^/ C,... 

Lorenzo Holloway 

Assistant General Counsel 

For Public Finance and Audit Advice 

Delanie DeWitt Painter 

Attomey 

SUBJECT: Preliminary Audit Report for Chris Dodd for President, Inc. (LRA 744) 

The Office of the General Counsel has reviewed the proposed Preliminary Audit Report 

("PAR") for Chris Dodd for President, Inc. ("Committee"). Our comments primarily focus on 

several issues related to Finding 2 - Receipt of Contributions that Exceed Limits. Your cover 

memorandum requests comments on one apparent excessive contribution, a recreational vehicle 

("RV") provided by a union, and asks several questions about that transaction. We address those 

questions below, and we also comment on a contribution that was timely redesignated but never 

transferred. With respect to Finding 1 ~ Net Outstanding Campaign Obligations, we reiterate 

portions of the informal advice we provided about how to present investment accounts on the 

Statement of Net Outstanding Campaign Obligations CNOCO Statement") to inform the 

Commission of these issues, and comment on adjustments to figures related to general election 

contributions on the NOCO Statement. We concur with the remaining findings not specifically 

discussed in this memorandum. Ifyou have any questions, please contact Delanie DeWitt Painter, 

the attomey assigned to this audit. 
Memorandum to Joseph F. Stoltz 

Legal Analysis Preliminary Audit Report -

Chris Dodd for President (LRA 744) 

Page 2 

L RECEIPT OF CONTRIBUTIONS THAT EXCEED LIMITS (FINDING 2) 

A. RV Contribution - Factual Background 

You request our comments on issues related to an apparent in-kind contribution to the 

Committee from the Intemational Association of Firefighters ("lAFF"), a labor organization, 

and/or its separate segregated fimd, LAFF FIREPAC ("FIREPAC"). The possible contribution 

consists ofthe rental and decoration of a recreational vehicle or bus that seems to have been used 

by the Committee for a bus tour. These costs totaled $32,233. It appears that FIREPAC paid the 

costs of decorating the vehicle because FIREPAC reported the decoration costs as an independent 

expenditure on behalf of Senator Dodd. Because FIREPAC did not report the rental cost, the 

auditors believe that cost may have been paid for by the lAFF or by a non-federal account of 

FIREPAC. 

Although FIREPAC reported the decoration cost as an independent expenditure, the lAFF 

later billed the Committee for a share of the costs of both renting and decorating the vehicle. 

According to the invoice letter and attached documents, the Committee •*rented the bus from the 

lAFF for the period of December 17,2007 through January 4,2008, for a total of 18 days." The 

Iowa caucus was on January 3,2008, so the 18-day bus rental appears to cover the end ofthe Iowa 

campaign. The bus rental cost was $15,423 and the decorating wrap cost was $16,810, for a total 

cost of $32,233. The invoice states that overall, "between the lAFF and the Dodd campaign we 

had possession of the bus for a total of 48 days, which brings the daily rate to $671.53." The lAFF 

billed the Committee $12,087.54 for 18 days ofthe 48 day total. The invoice, dated February 12, 

2008, stated that the Committee should reimburse FIREPAC within 60 days of the Iowa caucus. 

A picture and several videos showed the bus entirely covered in a gold and black wrapping 

decoration that contains a large picture of Senator Dodd, the lAFF emblem, and the statement 

"lAFF Fire Fighters for Dodd President." See Attachment; see also http://vmw.youtube.com/ 

watch?V =2ln2WaPaRY4. An lAFF press release states that a 20-city eight-day "Firefigjhters for 

Dodd" bus trip from November 29,2007 through December 6,2007 was a "caucus 

get-out-the-vote effort" and was the "latest push" by the lAFF for Dodd's presidential candidacy. 

Id. The press release stated that lAFF members would travel around Iowa in the bus to boost 

support for Dodd, and at each stop, the union's general president would meet with fire fighters, 

"discuss Sen. Dodd's record of support for working families and their communities" and urge 

them to participate in the caucus. Id. The video showed brief footage of some of these meetings. 

The press release included a schedule indicating the times and locations of stops. It also stated that 

Senator Dodd "will meet the bus" at several stops. Id. From the schedule it appears the lAFF used 

the bus during at least 8 of the 30 days it had the bus before the Committee's 18-day period of bus 

rental. It is unclear how the bus was used for the other 22 days, or for the 18 days that the invoice 

charged rental to the Comniittee. For example, it is not known whether the bus was tumed over to 

the Committee for that 18-day period, or whether the lAFF and/or FIREPAC members continued 

to tour on the bus with the Committee. 
Memorandum to Joseph F. Stoltz 

Legal Analysis Preliminary Audit Report -

Chris Dodd for President (LRA 744) 

Page 3 

Notwithstanding both its earlier reporting of the decoration costs as an independent 

expenditure and lAFF's invoice to the committee for only l8/48ths ofthe combined rental and 

decoration costs, FIREPAC reported the fiill $32,233 cost ofthe bus as a debt owed by the 

Committee in its March 2008 disclosure report. FIREPAC continued to report the debt as 

outstanding until its December 2009 disclosure report, on which it reported the debt as having been 

paid in fiill by the Committee in October, 2009.^ Similarly, the Committee reported the same 

amount as a debt owed to FIREPAC beginning with its March 2008 report and continuing until it 

reported paying the debt as of October 2009. After the auditors discussed this issue with the 

Committee at the exit conference on May 7,2009, the Committee provided a copy of a 

non-negotiated reimbursement check to FIREPAC, dated October 21,2009, for the combined 

$32,233 cost of both rental and decoration of the bus, rather than the lower invoiced amount. But 

the auditors' review of FIREPAC's reports from June 2007 through November 2009 indicates that 

FIREPAC has never reported paying for the RV rental cost, and the auditors have been unable to 

determine who initially paid for the rental portion ofthe RV - the union itself or FIREPAC. 

The auditors' review of FIREPAC's reports also revealed a number of other reported 

independent expenditures on behalf of Dodd beginning in August 2007 and totaling $373,609 for 

expenses including various types of signs (billboards, banners, rally, yard, 4x8, podium), 

estimated travel costs, newspaper advertising, web site costs, bumper stickers, mugs, musical and 

entertainment services, catering, food for events and beverages, facility fee, tents, invitations, and 

portable lavatories. Many of these expenses appear to be related to rallies or other events. The 

"estimated travel costs" for several individuals were reported as paid on the same day the 

Committee's period of bus rental began according to the invoice. 

B. The RV Rental and Wrapping Costs Appear to Have Been Contributions to the 

Committee 

The audit of the Committee has not yet produced information sufficient to explain all ofthe 

facts surrounding the RV transaction. For instance, we do not yet know why the parties apparentiy 

characterized the transaction in three different ways at three different times. Nor do we know 

whether lAFF, FIREPAC, or some other actor paid for the original cost of renting the RV from a 

commercial vendor. Nevertheless, based on the infonnation to date, it appears most likely that the 

costs of both renting and decorating the RV were either excessive or prohibited contributions to the 

Committee. It appears that the lAFF and FIREPAC may have initially contemplated that the costs 

of decorating the bus would be an independent expenditure by FIREPAC on behalf of Senator 

Dodd's candidacy. Seell C.F.R. § 100.16(c). Certainly, FIREPAC reported the decoration costs 

that way. Ultimately, though, it appears that the parties decided that this transaction was not an 

independent expenditure, but was either a transaction in which lAFF and/or FIREPAC rendered 

goods and services to the Committee for hire (or for reimbursement pursuant to 11 C.F.R. 100.93), 

or a situation in which the Committee determined that it needed to reimburse lAFF br FIREPAC 

for prohibited or excessive contributions. This conclusion is supported by the fact that the 

Committee apparently paid the full cost of both renting and decorating the vehicle to FIREPAC, 

^ On its December 2009 disclosure report, FIREPAC also noted that it had inadvertently deposited the 

Committee check into its non-federal account. FIREPAC stated it would report a transfer on its 2009 year-end report 
Memorandum to Joseph F. Stoltz 

Legal Analysis Preliminary Audit Report -

Chris Dodd for President (LRA 744) 

Page 4 

and the Committee and FIREPAC both disclosed the full amount on their reports as a debt the 

Committee owed for a long period and eventually paid in 2009. 

Had the Committee timely made reimbursement to LAFF or FIREPAC, whoever was the 

appropriate party, for the cost of renting the RV, the rental cost would not have been a 

contribution. The Committee could have properly paid the cost of the bus rental, as an "other 

means of transportation" not operated for commercial passenger service, at the normal and usual 

charge for a comparable commercial conveyance within 30 days of receipt of the invoice or 60 

days after the travel began. See 11 C.F.R. § 100.93(d). But the Committee untimely reimbursed 

the bus costs, more than a year alter the travel occurred. Failure to make timely reimbursement 

under Section 100.93 results in an in-kind contribution. See 11 C.F.R. § 100.93 (b)(2). Because 

the reimbursement was not made properly under section 100.93, the bus cost is a contribution. 

While the rental cost of the bus itself reflects the bus' function as a means of transportation, 

and is thus plausibly subject to the section 100.93 travel rules, the bus also served as a type of 

rolling billboard. Therefore, the bus decoration cost is essentially a communication expense. If 

that communication was not independent - and the parties appear to have decided it was not •- then 

it was necessarily coordinated and thus a contribution from FIREPAC to the Committee. See 11 

CF.R. §§ 100.16(c); 109.20; 109.21. FIREPAC had already contributed $5,000 to the Committee 

for the primary election. Under these circumstances, the parties may have decided that the entire 

decoration cost was an excessive contribution from FIREPAC to the Committee that needed to be 

refunded, but was not for some time. Altematively, if the parties simply treated the decoration as a 

service provided for hire, it would still appear to be an excessive contribution, as FIREPAC 

extended credit to the Committee and does not appear to be in the commercial business of 

decorating buses with advertising messages. Moreover, even if the decorating cost were 

considered part of the total bus travel cost - and we do not believe it should be — it was not timely 

reimbursed under section 100.93, as discussed above, and thus, was an excessive contribution. 

Therefore, the RV bus rental and wrapping expenses appear to have been contributions. 

Because it appears that FIREPAC paid for the wrapping cost, the wrapping cost appears to have 

been an untimely resolved excessive contribution from FIREPAC. Because FIREPAC never 

reported paying the RV rental cost, it is possible the lAFF or FIREPAC's non-federal account paid 

that cost. Depending on who paid for it, the rental cost may have been a prohibited contribution 

from lAFF or a non-federal account of FIREPAC. It is also possible that the rental cost was an 

additional excessive contribution from FIREPAC that was not properly reported. We reconunend 

that the proposed PAR be revised consistent with this legal analysis. 

A related question you raise is whether, if FIREPAC did not pay the rental cost, the 

Committee's reimbursement of that portion of the cost to FIREPAC might be an excessive 

contribution to FIREPAC. Arguably, the Committee did not make any contribution to FIREPAC. 

A contribution is a gift, subscription, loan, advance, or deposit of money or anything of value made 

"for the purpose ofinfluencing" a federal election. 2 U.S.C. § 431(8)(A)(i); 11 C.F.R. § 100.52(a). 

The statute prohibits a candidate or political committee from "knowingly" making an expendimre 

in violation of the contribution and expenditure limitations. 2 U.S.C. § 441 a(f). There is no 
Memorandum to Joseph F. Stoltz 

Legal Analysis Preliminary Audit Report -

Chris Dodd for President (LRA 744) 

Page 5 

indication that the Committee had any knowledge or intent that by reimbursing FIREPAC instead 

of lAFF for the bus rental cost, it would have been making a contribution. The Committee's 

apparent intent, based on what we know so far, was either to resolve an excessive contribution it 

had received, or to pay a debt. The invoice instmcted the Committee to reimburse FIREPAC and 

the Committee did so. There is no available information indicating that the Committee knew or 

should have known who actually paid for the rental portion of the RV. Indeed, it remains unclear 

who actually paid that cost. 

Another question you ask is whether the RV transaction raises questions about the 

numerous other independent expenditures FIREPAC made on behalf of Dodd. In our view, the 

RV transaction in and of itself, in the absence of any other information, does not automatically call 

into question the independence of other FIREPAC independent expenditures that were unrelated 

to the RV transaction. Under the current coordination rules, the coordination of one 

communication does not automatically imply the coordination of others. The multi-part conduct 

and content tests for coordination must be applied to each particular communication. See 11 

C.F.R. §§ 100.16(c); 109.20; 109.21. Section 109.21 strongly implies that the coordination tests 

should be applied to each particular communication because it sets forth the requirements for 

determining whether "a communication" is coordinated, and does not refer to more than one 

communication. While FIREPAC's reporting those expenditures as independent expenditures 

would indicate that the content ofthose communications included express advocacy of Senator 

Dodd's election as president, you have not indicated that you have any other information at this 

time regarding the application of the conduct test to those expenditures. Of course, it is possible 

that you will develop such information in the course of obtaining further infbrmation about the RV 

transaction. We note, however, that the other independent expenditures began earlier, in August 

2007, and the types of expenses included signs, web expenses and event-related expenses. 

C. Other Excessive Contributions Issues 

The proposed PAR also addresses other excessive contributions, including one $4,000 

excessive contribution that the auditors consider unresolved because the Committee received a 

timely completed redesignation letter, but never actually transferred the fiinds at issue to the 

candidate's Senate committee or refunded them to the contributors. We note that, as we stated in 

our comments on the Biden PAR, "there is no legal authority that requires a committee to move 

redesignated fiinds from one campaign to another within the 60 day period." Memorandum to 

Joseph F. Stoltz, "Preliminary Report ofthe Audit Division on Biden for President, Inc." at 8 (Mar. 

17,2009). The regulations only require that a committee receive the redesignation letters from 

contributors within that timeframe. 11 C.F.R. § 110.1(b)(5)(ii)(A)(2). We noted that redesignated 

fiinds ultimately must be moved to another committee in order to practically effectuate the 

redesignation, and the Biden Committee transferred the funds "within a reasonable amount of time 

albeit not within the 60 day period required under 11 C.F.R. § 110.1(b)(5)(ii)(A)(2)." Id. We 
Memorandum to Joseph F. Stoltz 

Legal Analysis Preliminary Audit Report -

Chris Dodd for President (LRA 744) 

Page 6 

suggest that the proposed PAR recommendation be revised to make clear that a transfer of the 

redesignated funds will resolve this contribution. 

II. NOCO STATEMENT (Finding 1) 

A. Presentation of General Election Investment Account on NOCO Statement 

The NOCO Statement in the proposed PAR presents transactions related to an investment 

account for general election receipts ("General Account") as assets and liabilities. Since, however, 

this is an audit of the primary campaign, there is a question whether the assets and liabilities from 

the General Account should be included on the NOCO Statement. We conclude that the Audit 

Division can either include the General Account, as it has done, or exclude it from the NOCO 

Statement because nothing legally requires or prohibits its inclusion. 

The General Account only comprised general election contributions. The Committee 

accepted general election contributions during the primary election period under the conditions set 

forth in AO 2007-03 (Obama). See AO 2008-04 (Dodd). After Senator Dodd withdrew from the 

primary race on January 3,2008, he was no longer a potential general election candidate. The 

Committee, therefore, was required to refund or redesignate the general election contributions. ^ 

See l l C.F.R. § 102.9(e)(3); AO 2008-04; AO 2007-03; AO 2003-18 (Smith). 

There is nothing that legally either requires or prohibits the inclusion of the General 

Account and related transactions such as general election contributions, refiinds, and 

redesignations in the NOCO Statement.* See 11 C.F.R. § 9034.5. Thus, we conclude that the 

Audit Division may take either approach, provided that, if the General Account transactions are 

included in the NOCO Statement, they net each other out as assets (cash on hand) and liabilities 

(accounts payable). 

In our opinion, however, it appears that excluding the General Account from the NOCO 

Statement is the approach most consistent with both the purpose ofthe NOCO Statement and two 

recent Commission advisory opinions addressing the receipt of general election contributions by 

Presidential primary candidates. The General Account is related to the general election, not to the 

candidate's publicly-fiinded primary campaign for the nomination. The purpose of a NOCO 

Statement is to determine a candidate's financial status and entitiement to matching funds after the 

date of ineligibility with respect to that candidate's participation in the primary election under the 

Presidential Matching Payment Account Act ("Matching Payment Program"). See 11 C.F.R. 

§ 9034.5; Explanation and Justification for 11 CF.R. § 9034.5,44 Fed. Reg. 20,336,20,340 (Apr. 

4,1979). 

^ The Committee requested an advisory opinion about resolving these contributions. AO 2008-04. 

* This applies both to NOCO Statements submitted by committees after their dates of ineligibility ("DOI") in 

support of their requests for matching funds, and to the NOCO Statements as adjusted by the Audit Division that are 

included in its audit report of any publicly financed presidential primary committee. 
Memorandum to Joseph F. Stoltz 

Legal Analysis Preliminary Audit Report -

Chris Dodd for President (LRA 744) 

Page? 

Although section 9034.5 does not explicidy exclude general election fimds from what 

should be included on the NOCO Statement, an account containing only contributions designated 

for the general election but received during the primary election period should not affect a 

candidate's financial status or entitiement to matching fiinds with respect to the primary election. 

Once a candidate fails to qualify for the general election or, in the case of presidential candidates, 

elects to receive public financing for the general election campaign, the general election 

contributions become impermissible fiinds that must be refunded, redesignated, or disgorged. 11 

C.F.R. § 102.9; AO 2008-04; AO 2007-03; AO 2003-18. For this reason, candidates must use an 

acceptable accounting method to distinguish between contributions designated for the primary and 

contributions designated for the general election; must limit access to the general election funds; 

and may not use those fiinds for any purpose. Seell C.F.R. § 102.9(e); AO 2008-04; AO 2007-03. 

In the case of a committee such as the Dodd Committee that does not qualify for the general 

election, if one assumes that the committee has adequately segregated general election 

contributions firom its primary election fiinds, the amount of general election contributions 

received should exactly equal the obligation to make refunds, obtain redesignations or make 

disgorgement payments. Accordingly, if such a candidate has participated in the Matching 

Payment Program, the general election contributions and the refund obligation should net to zero 

and thus should neither increase nor decrease the amount of post-DOI matching funds to which a 

committee may otherwise be entitled. Because the general election accoimts should have no 

impact on post-DOI matching fund entitiement, we believe they should not be included on a 

committee's NOCO statement as a matter of policy. ^ 

In this case, however, there are some additional relevant facts: specifically, the Committee 

placed the general election contributions in an investment account, and the account lost $43,830 by 

the time of the Committee's DOI. These facts do not change our conclusion regarding the 

advisability of including the general election funds in tiie NOCO statement. In this case, to ensure 

that the general election contributions net out against the obligation to refiind those contributions, 

tiie auditors adjusted tiie NOCO Statement to offset the loss tiiat the Committee incurred when it 

invested the general election contributions. The proposed PAR includes a footnote explaining that 

the adjustment to the payable was to "ensure that general election contributions had no impact on 

matching fiind entitiement," and stating that the "general election loss may not influence the 

primary campaign's entitiement to matching fiinds." The necessity for this adjustment and its 

accompanying footnote is another reason why we believe it would be a better practice not to 

include general election account transactions on the NOCO statement in the first place. However, 

should the Audit Division determine to include these transactions on tiie NOCO statement, we 

agree with the adjustment. Adjustment in this manner prevents investment losses related to a 

privately fiinded general election campaign from possibly increasing a candidate's post-DOI 

' We recognize that one disadvantage to this approach is that it fails to provide an accurate "overall" picture of 

the Committee's financial status. However, the Audit Division could address this concem by adding an 

accompanying footnote to the NOCO Statement that explains the existence of the General Account and transactions 

related to general election funds. Moreover, the general election funds will be reflected on the Committee's disclosure 

reports. 
Memorandum to Joseph F. Stoltz 

Legal Analysis Preliminary Audit Report -

Chris Dodd for President (LRA 744) 

Pages 

entitiement to public funds related to the primary election. It is our understanding, however, that 

in tiiis instance, the candidate would not have received any additional matching fimds. 

Again, however, there is nothing that legally prevents the Audit Division from including 

the General Account and transactions in the NOCO Statement. See 11 CF.R. § 9034.5. 

Accordingly, the Audit Division may elect to include the General Account and related transactions 

in the NOCO Statement, as it did in this proposed PAR, so long as the amount of general election 

contributions and the obligations to make general election refunds, redesignations or disgorgement 

payments net each other out as assets and liabilities. 

B. Presentation of Investment Gains and Losses on NOCO Statement 

If the General Account (or any other investment account) is presented on the NOCO 

Statement, we recommend that it be presented as part of the Committee's cash on hand, and valued 

at fair market value as of the close of business on the Committee's last day of eligibility. 11 C.F.R. 

§ 9034.5(a)(2)(i). The regulation explicitiy states that "any other committee investments" should 

be included in cash on hand "at fair market value." Id. This result would differ from the reporting 

of investment accounts on disclosure reports, which this Office addressed in our comments on the 

Weiner audit. See Memorandum to Wanda J. Thomas, Audit Report on Friends of Weiner (Mar. 4, 

2009) at 3.. In that case, this Office concluded that as long as assets remain investments that are not 

transferred or converted, "there is no requirement to report unrealized gains or losses that reflect 

no more than fluctuations in current fair market value." Id. However, while section 104.3(a)(1) 

states that committee investments should be "valued at cost" on disclosure reports, section 

9034.5(a)(2)(i) states investments should be included in cash on hand on NOCO Statements at 

"fair market value." 

Attachment 

"Fire Fighters for Dodd Bus Tour Rolls tfirough Iowa Nov. 29-Dec-6," http://wviw.iaff.org/ 

Comm/Press/DODDbustour.htm (visited Feb. 18, 2010) and "Fire Fighters for Dodd: Bus tour 

rolls through Iowa Nov. 29- Dec.6." (Nov. 27,2007 press release) at 

http://www.gwu.edu/~action/2008/dodd/iafF112707pr.html (visited Jan. 26,2010) 
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Fire Fighters for Dodd Bus Tour Nov. 29-Dec. 6,2007 Page 1 of 4 

PRESS RELEASE from International Association of Fire Fighters via lowaPolltics.com 

November 27, 2007 

Fire Fighters For Dodd: Bus tour rolls through Iowa 

Nov. 29 - Dec. 6 

Goal: Caucus Mobilization 

Tour schedule attached and available oniine: 

http://www.firefighter8fordodd.com/bustour 

Contact: Amber Moore 703/276-2772 xl7 Bill Glanz 202/824-

1566 

Council Bluffs, Iowa The largest caucus get-out-the-vote effort by a labor union this year gets rolling in 

Iowa this week as the "Fire Fighters For Dodd" 20-city, eight-day bus trip through the state hits the road 

here Thursday, Nov. 29. It is the latest push by the Intemational Association of Fire Fighters (lAFF) for 

underdog Democratic presidential candidate Sen. Chris Dodd. 

Known as the hardest campaigners, the Fire Fighters will travel the state in a 42-foot gold-and-black RV 

with the "Fire Fighters for Dodd" wrap. Starting in Council Bluffs and ending in Des Moines on Dec. 6, 

Iowa fire fighters will seek to boost support for Dodd from Iowa's farm communities to its urban 

centers. 

At each stop, lAFF General President Harold Schaitberger will join presidents of Iowa lAFF locals and 

fire fighters to discuss Sen. Dodd's record of support for working families and their communities, 

particularly in providing resources for emergency response. Schaitberger also will urge fire fighters to 

participate in the Jan. 3 caucus so they can have an impact in the elections as they did m 2004 when fire 

fighters mobilized to ensure Sen. John Kerry's surprise caucus victory. 

"We need a president who can get things done and has the experience to lead, and Chris Dodd clearly 

has a record of accomplishment and a legacy of diplomacy that makes him the obvious choice," 

Schaitberger said. 

Photos and video will be available at: http://www.firefightersfordodd.com/bustour 

Stops include Council Bluffs, Sioux City, Ft. Dodge, Ames, Boone, Nevada, Marshalltown, Mason City, 

Waterloo, Cedar Rapids, Iowa City, Ottumwa, Keokuk, Burlington, Muscatine, Davenport, Clinton, 

Dubuque, West Des Moines and Des Moines. 

*** See schedule below.*** 

Sen. Dodd wrote two laws the Staffing for Adequate Fire and Emergency Response (SAFER) Act and 

Assistance to Firefighters Grant Program (FIRE Act) that provide funding to hire additional fire fighters 

and money for equipment and training. Those programs have resulted in direct federal aid to Iowa of 

nearly $64 million since 2001. 

In addition. Sen. Dodd authored the Family Medical Leave Act (FMLA) and fought for seven years and 

http://www.gwu.edu/~action/2008/dodd/iaffl 12707pr.html 

I 

'WE6/2010 
Fire Fighters for Dodd Bus Tour Nov. 29-Dec. 6,2007 Page 2 of 4 

through two presidential vetoes until it finally became law in 1993. An estimated 50 million workers 

have taken advantage of FMLA. 

The Intemational Association of Fire Fighters, headquartered in Washington, DC, represents more than 

287,000 full-time professional fire fighters and paramedics who protect 80 percent of the nation's 

population. More information is available at http://www.iafF.org. 

Fire Fighters for Dodd Iowa Bus Schedule: Nov. 29-Dec.6 

As of 11/27/07 

Times and locations may shift 

Thursday, Nov. 29 

Council Bluffs 9:00am 

Local 15 Union Hall 

1827 South 8th St. 

Sioux City 5:30pm 

Famous Dave's 

201 Pierce St. 

Friday, Nov. 30 

Ft. Dodge 9:00am 

Ft. Dodge Fire Station 

1515 Central Ave. 

Boone 2:15pm 

Location TBD 

Ames 4:00pm 

American Legion Hall 

225 Main St. 

Meeting with other unions 

Nevada 6:00pm 

Gates Memorial Hall 

825 15th St. 

Saturday, Dec. 1 

•Marshalltown 8:00am 

Location TBD 

Senator Dodd will meet the bus 

Mason City 2:00pm 

Location TBD 

Waterloo 7:00pm 

Sullivan Brothers Convention Center 

http://www.gwu.edu/-action/2008/dodd/iaffl 12707pr.html rac-0,„.Jrt-. ol' ^6/2010 
Fire Fighters for Dodd Bus Tour Nov. 29-Dec. 6,2007 Page 3 of 4 

205 West 4th St. 

Sunday, Dec. 2 

Cedar Rapids 12:00pm 

P3 Union Hall (old UFCW) 

116 14th Ave SE 

Iowa City 5:00pm 

Fire House # I 

410 E.Washington St. 

Monday, Dec. 3 

•Ottumwa 9:00am 

Ottumwa Hotel Parkview Plaza 

107 2nd Street 

Senator Dodd will meet the bus 

Keokuk 1:30pm 

Keokuk Labor Temple 

301 Blondeau St. 

Burlington 6:00pm 

Catfish Bend Casino 

3001 Winegard Dr. 

Tuesday, Dec. 4 

Muscatine 9:00am 

Location TBD 

Davenport 5:00pm 

Location TBD 

Wednesday, Dec. 5 

Clinton 9:00am 

Best Western Frontier Motor Inn 

2300 Lincoln Way 

Dubuque 7:00pm 

Happy's Place 

2323 Rockdale Rd. 

Thursday, Dec. 6 

West Des Moines 12:00pm 

Location TBD 

http://www.gwu.edu/~action/2008/dodd/iaffl 12707pr.html 1/26/2010 
Fire Fighters for Dodd Bus Tour Nov. 29-Dec. 6,2007 Page 4 of 4 

*Des Moines 5:00pm 

Location TBD 

Senator Dodd will meet the bus 

'^T-'^-^F'^ivJ 

http://www.gwu.edu/~action/2008/dodd/iaffll2707pr.html 1/26/2010