U.S. GOVERNMENT PUBLISHING OFFICE

WASHINGTON : 

1 

59–006 

" ! HOUSE OF REPRESENTATIVES 

114TH CONGRESS

2d Session 

REPORT

2016

114–643 

House Calendar No. 131 

IN THE MATTER OF ALLEGATIONS RELATING 

TO REPRESENTATIVE VERNON G. BUCHANAN 

R E P O R T 

OF THE

COMMITTEE ON ETHICS 

JUNE 24, 2016.—Referred to the House Calendar and 

ordered to be printed 


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(II) 

COMMITTEE ON ETHICS 

CHARLES W. DENT, Pennsylvania 

Chairman 

PATRICK MEEHAN, Pennsylvania 

TREY GOWDY, South Carolina 

SUSAN W. BROOKS, Indiana 

KENNY MARCHANT, Texas 

LINDA T. SA ́ NCHEZ, California 

Ranking Member 

MICHAEL E. CAPUANO, Massachusetts 

YVETTE D. CLARKE, New York 

TED DEUTCH, Florida 

JOHN B. LARSON, Connecticut 

REPORT STAFF 

THOMAS A. RUST, Chief Counsel/Staff Director 

PATRICK M. MCMULLEN, Director of Investigations 

CLIFFORD C. STODDARD, JR., Counsel to the Chairman 

DANIEL J. TAYLOR, Counsel to the Ranking Member 

MOLLY N. MCCARTY, Investigator 

MICHAEL KOREN, Investigative Clerk 


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LETTER OF TRANSMITTAL 

HOUSE OF REPRESENTATIVES, 

COMMITTEE ON ETHICS, 

Washington, DC, June 24, 2016. 

Hon. KAREN L. HAAS, 

Clerk, House of Representatives, 

Washington, DC. 

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

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

the attached report, ‘‘In the Matter of Allegations Relating to Representative Vernon G. Buchanan.’’ 

Sincerely, 

CHARLES W. DENT, 

Chairman. 

LINDA T. SA ́ NCHEZ, 

Ranking Member. 


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C O N T E N T S 

Page 

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

II. PROCEDURAL HISTORY ............................................................................ 3 

III. HOUSE RULES, LAWS, REGULATIONS, AND OTHER STANDARDS 

OF CONDUCT ............................................................................................ 6 

IV. BACKGROUND ............................................................................................. 6 

A. BUSINESS DISPUTES BETWEEN REPRESENTATIVE 

BUCHANAN AND MR. KAZRAN, AND THE DRAFT AFFIDAVIT ............................................................................................. 6 

B. ALLEGATIONS OF REPRESENTATIVE BUCHANAN’S INVOLVEMENT WITH, AND KNOWLEDGE OF, CONDUIT 

CONTRIBUTIONS TO VBFC ....................................................... 10 

1. SUNCOAST FORD (SCF) ............................................................. 10 

2. VENICE NISSAN DODGE (VND) ............................................... 11 

3. HYUNDAI OF NORTH JACKSONVILLE (HNJ) ....................... 12 

V. FINDINGS ...................................................................................................... 16 

A. 52 U.S.C. § 30122 ............................................................................. 16 

B. TITLE 18 ........................................................................................... 17 

C. HOUSE RULE XXIII, CLAUSES 1 AND 2 .................................... 22 

VI. CONCLUSION ............................................................................................... 25 

VII. STATEMENT UNDER HOUSE RULE XIII, CLAUSE 3(C) ...................... 25 

APPENDIX A: REPORT AND FINDINGS OF THE OFFICE OF CONGRESSIONAL ETHICS (REVIEW NO. 11–7565) ................................... 26 


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House Calendar No. 131 

114TH CONGRESS REPORT " ! HOUSE OF REPRESENTATIVES 2d Session 114–643 

IN THE MATTER OF ALLEGATIONS RELATING TO 

REPRESENTATIVE VERNON G. BUCHANAN 

JUNE 24, 2016.—Referred to the House Calendar and ordered to be printed 

Mr. DENT, from the Committee on Ethics, 

submitted the following 

R E P O R T 

In accordance with House Rule XI, clauses 3(a)(2) and 3(b), the 

Committee on Ethics (Committee) hereby submits the following Report to the House of Representatives: 

I. INTRODUCTION 

Since 2012, the Committee has investigated allegations regarding 

Representative Vernon G. Buchanan and his campaign, as well as 

his interactions with an investigation by the Federal Election Commission (FEC) of those allegations. Following its investigation, the 

Committee concluded that there is insufficient evidence to support 

a finding of any violation by Representative Buchanan. This Report 

details the Committee’s findings and conclusions. 

On January 27, 2012, the Office of Congressional Ethics (OCE) 

transmitted a Report and Findings (Referral) relating to Representative Buchanan to the Committee. OCE’s Referral recommended 

that the Committee further review allegations that Representative 

Buchanan ‘‘attempted to influence the testimony of a witness in a 

proceeding before the FEC’’ by coercing the witness to sign a false 

affidavit in violation of federal law and House Rules. OCE’s Referral provided additional information about the allegation that Representative Buchanan attempted to improperly influence the testimony of his former business partner, Sam Kazran, by presenting 

Mr. Kazran with an affidavit for his signature which included false 


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1 A referral from the OCE to the Committee may include a recommendation that the Committee further review an allegation or dismiss it and provide the Committee with certain types 

of information regarding the allegation, but not the names of any cooperative witnesses or any 

conclusions regarding the validity of the allegations or the guilt or innocence of the individual 

who is the subject of the review. See H. Res. 895 § 1(c)(2)(C). 2Some of the allegations reviewed by the Committee occurred prior to the 111th Congress, 

prior to the Committee’s general investigative jurisdiction, which includes the current and three 

previous Congresses. However, pursuant to House Rule XI, clause 3(b)(3) and Committee Rule 

18(d), the Committee voted to determine that these allegations were directly related to alleged 

violations that occurred within the Committee’s general jurisdiction and did investigate those 

allegations. 

statements about wrongdoing with respect to Representative 

Buchanan’s campaign.1

The Committee agreed with OCE’s recommendation and did further review the allegations in its Referral. On May 9, 2012, the 

Committee published OCE’s Referral and a response from Representative Buchanan, and announced that the Committee would 

investigate the matter under Committee Rule 18(a). 

In addition to the allegations regarding improperly influencing a 

witness, the Committee examined a broader range of allegations 

than the allegations for which OCE recommended further review. 

The Committee investigated allegations relating to Representative 

Buchanan’s campaign, including whether several car dealerships 

partly owned by Representative Buchanan illegally reimbursed 

their employees for contributions to Representative Buchanan’s 

House campaigns and whether Representative Buchanan himself 

may have been aware of the unlawful reimbursements at the time 

they occurred, or had some role in directing or approving of them.2

Together, these allegations were the subject of review by four different entities—the Committee, OCE, FEC, and Department of 

Justice (DOJ)—as well as related civil litigation in state court. In 

the course of its investigation the Committee reviewed over 6,000 

pages of materials, including statements by 22 witnesses. Much of 

this material was generated through the course of the related investigations and proceedings. The Committee also interviewed Representative Buchanan, who agreed to appear before the Committee 

for a voluntary interview. 

The FEC investigated the allegations of unlawful reimbursements and the allegations concerning Representative Buchanan’s 

knowledge of, and involvement with, the corporate reimbursement 

of campaign contributions, and the allegation that he attempted to 

influence Mr. Karzan’s testimony before the FEC. The FEC closed 

its investigation as it related to Representative Buchanan on February 1, 2011, taking no further action against him. 

Additionally, beginning in late 2011, the DOJ investigated similar allegations relating to Representative Buchanan. The DOJ 

closed its investigation around September 2012. 

The allegation related to attempting to improperly influence the 

testimony of Mr. Kazran was also one of several allegations that 

arose in a civil suit between Mr. Kazran and Representative 

Buchanan in Florida state court. On November 10, 2014, at the 

close of Mr. Kazran’s case-in-chief, the Florida Circuit Court for 

Sarasota County directed a verdict in favor of Representative 

Buchanan with regard to the allegation that he improperly influenced testimony. 

Finally, OCE reviewed the allegation that Representative 

Buchanan attempted to improperly influence the testimony of Mr. 


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Kazran before the FEC and ultimately recommended that the Committee further review that allegation. 

As is true with all of its investigations, the Committee conducted 

an independent review without deferring to the findings or conclusions of any other entity. In this matter, the Committee also reviewed the allegations that were the subject of proceedings before 

the FEC, DOJ, and in the Florida Circuit Court for Sarasota County. 

Consistent with the resolutions in the matters before the FEC 

and DOJ, as well as in the related civil litigation, the Committee 

concluded that there is insufficient evidence to sustain any of the 

aforementioned allegations or to warrant any action against Representative Buchanan. Specifically, the Committee concluded that 

three car dealerships partly owned by Representative Buchanan 

did, in fact, illegally reimburse their employees for contributions to 

Representative Buchanan’s House campaigns. However, the Committee found that the evidence is insufficient to conclude that Representative Buchanan himself was aware of the unlawful reimbursements when they were made, or had any role in directing or 

approving of them. The Committee further concluded that the evidence is insufficient to find that Representative Buchanan attempted to improperly influence the testimony of Mr. Kazran before the FEC. However, as discussed further in this Report, the 

Committee cautions Representative Buchanan to exercise more diligence over affairs related to his campaign. 

Accordingly, the Committee unanimously voted to release this 

Report and take no further action in this matter. 

II. PROCEDURAL HISTORY 

As noted above, the issues discussed in this Report were the subject of other investigations and hearings. On August 19, 2008, Citizens for Responsibility and Ethics in Washington (CREW) filed a 

complaint with the FEC against Representative Buchanan, as well 

as a number of corporations with which he was affiliated and officers and employees of those corporations, alleging violations of the 

Federal Election Campaign Act (FECA). Specifically, CREW alleged 

that employees at two car dealerships owned by Representative 

Buchanan were compelled to donate to Representative Buchanan’s 

campaign committee, Vern Buchanan For Congress (VBFC), and 

that their campaign contributions were later unlawfully reimbursed from corporate funds. On October 6, 2008, Representative 

Buchanan disclosed to the FEC that VBFC may have unknowingly 

violated the FECA by accepting contributions from employees of 

another car dealership owned by Representative Buchanan, who 

were then reimbursed by the dealership. While these allegations 

were similar in nature to the CREW allegations, CREW’s complaint 

related to different contributions and corporations. The FEC investigated both CREW’s complaint and Representative Buchanan’s 

self-report, including the allegations concerning Representative 

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3The FEC continued to investigate allegations of conduit contributions by other corporate entities and individuals, even after it concluded its investigation of Representative Buchanan himself. The FEC sued Mr. Kazran (eventually obtaining a settlement against him and a default 

judgment against the related corporate entity), and reached conciliation agreements with a number of other individuals and entities. See infra Part IV.B. The FEC appears to have concluded 

all business related to this investigation in March 2012. Additionally, in 2010, the FEC undertook an unrelated investigation of contributions to Representative Buchanan’s campaign that 

were reimbursed by a company not owned by or directly affiliated with Representative 

Buchanan; Representative Buchanan was not a party to that proceeding. See Federal Election 

Commission, In the Matter of Timothy F. Mobley, et al., MUR 6516. The FEC found that the 

companies in question, which were also targeted by a related DOJ investigation, knowingly reimbursed contributions to Representative Buchanan’s campaign, and the FEC entered into conciliation agreements with those companies and the individuals who owned and controlled them. 4See Letter from CREW Executive Director Melanie Sloan to FBI Assistant Director James 

W. McJunkin (Aug. 24, 2011), available at http://www.citizensforethics.org/legal-filings/entry/ 

crew-files-fbi-complaint-against-rep-vern-buchanan. 5DOJ has never publicly acknowledged a date by which it ended its investigation, publicly 

stating only that it had in fact closed the investigation. See CREW v. DOJ, No. 13-cv-2000 Docket #2 ¶ (Answer) (Mar. 6, 2014). But media reports indicate that this decision may have been 

made as early as September 2012. See, e.g., Adam C. Smith, Justice Department closes investigations against Vern Buchanan with no charges, Tampa Bay Times (Sept. 11, 2012), available at 

http://www.tampabay.com/blogs/the-buzz-florida-politics/content/justice-department-closes-investigations-against-vern-buchanan-w-no-charges. 6CREW v. DOJ, Docket #1 (Dec. 18, 2013). 7Id. 8The FECA violations investigated by the FEC occurred from 2005 through 2007; OCE’s investigative authority does not extend to violations that occurred prior to 2008. See H. Res. 895 § 4. 9OCE found that a number of witnesses, including Representative Buchanan, had failed to 

fully cooperate with OCE’s review, and accordingly noted in its Referral that it was permitted 

to draw a negative inference from that lack of cooperation. See OCE’s Referral ¶ 87. Despite 

this, OCE ‘‘judged the evidence adduced to be more than sufficient to support its determination,’’ 

irrespective of such an inference. Id. 10See OCE’s Referral ¶ 70–86. 

tigation as it related to Representative Buchanan on February 1, 

2011, taking no further action against him.3

On August 24, 2011, CREW wrote to the DOJ, requesting an investigation into not only the alleged violations of FECA previously 

disposed of by the FEC, but also a series of alleged crimes including obstruction of justice, witness tampering, and bribery, related 

to a draft affidavit prepared for Mr. Kazran.4 Representative 

Buchanan’s attorneys acknowledged a DOJ investigation, but that 

investigation was subsequently closed without formal charges.5 On 

December 18, 2013, CREW filed suit against the DOJ under the 

Freedom of Information Act (FOIA), seeking the release of its investigative file in that matter.6 The DOJ ultimately released certain documents regarding Representative Buchanan to CREW, and 

the parties settled their suit on June 29, 2015.7

On October 3, 2011, OCE notified the Committee that it had initiated a preliminary review of allegations that Representative 

Buchanan ‘‘may have attempted to influence a witness to sign a 

false affidavit related to an FEC investigation of campaign contributions to his campaign committee.’’ 8 On October 31, 2011, OCE 

notified the Committee that it commenced a second-phase review 

of these allegations. On January 27, 2012, OCE sent its Referral 

to the Committee, recommending further review of the allegations. 

OCE’s Referral found substantial reason to believe that a single 

paragraph of the draft affidavit may have been false, and that consequently, Representative Buchanan may have violated three separate criminal statutes.9 OCE also included in its Referral a section 

noting that, depending on the facts surrounding the FECA allegations, additional paragraphs in the draft affidavit ‘‘may’’ be false,10


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11Subsequent correspondence from OCE stated that ‘‘OCE did not adopt Mr. Kazran’s statement that Representative Buchanan directed him to reimburse campaign contributions.’’ Letter 

from David Skaggs and William Frenzel to Chairman and Ranking Member of Committee on 

Ethics at 4 (Apr. 2, 2012). 12See 1099 Mgmt. Co., LLC v. Gwinnett, LLC, No. 2008 CA11480 (Fla. Cir. Ct., Duval Cty.). 13Kazran v. Buchanan, 2008 CA 15448 (Fla. Cir. Ct., Sarasota Cty.). 14The Committee determined that this information was sufficient to dispose of this matter, 

and chose not to re-interview certain witnesses who had already been questioned, including Mr. 

Kazran. In part, this determination was based on independent concerns about Mr. Kazran’s 

credibility, as outlined infra at Part IV. Additionally, the Committee’s review of the extant testimony did not reveal sufficient evidentiary gaps to warrant duplicative interviews. Finally, because the Committee’s determination rested on a legal conclusion regarding the elements of the 

Continued 

but it is unclear as to whether OCE found substantial reason to believe those allegations.11

Some of the allegations in this matter were also the subject of 

a civil suit between Mr. Kazran and Representative Buchanan in 

the Florida Circuit Court for Sarasota County. Representative 

Buchanan’s holding company filed suit against Mr. Kazran in 

Duval County on September 4, 2008.12 The suit alleged that Mr. Kazran had failed to repay a $2.5 million loan. In turn, Mr. Kazran 

filed suit against Representative Buchanan in Sarasota County on 

September 25, 2008. His complaint was largely based on claims 

that Representative Buchanan had engaged in fraud related to his 

business dealings with Mr. Kazran, but the complaint also included 

allegations that Representative Buchanan abused the legal process 

by attempting to force Mr. Kazran to sign a false affidavit.13 It appears based on the dockets for both cases that Representative 

Buchanan eventually chose not to pursue his claims in Duval 

County, instead countersuing Mr. Kazran in Sarasota County and 

litigating his claims there. Representative Buchanan won summary 

judgment motions on some of the claims against him; Mr. Kazran’s 

remaining claims, as well as Representative Buchanan’s own 

causes of action, went to trial on November 3, 2014. On November 

10, 2014, at the close of Mr. Kazran’s case-in-chief, the court directed a verdict in favor of Representative Buchanan. On December 

5, 2014, following a jury verdict, the court entered judgment in 

favor of Representative Buchanan on his own claims against Mr. 

Kazran, and ordered Mr. Kazran to pay Representative Buchanan 

$2.5 million plus interest. 

A number of factors caused the Committee’s review of these allegations to take longer than normal, beginning with the convoluted 

set of parallel proceedings described above. Exacerbating that complication, Representative Buchanan initially responded to the Committee’s request for information by requesting that the Committee 

defer its inquiry at least until the conclusion of DOJ’s investigation, and then, once DOJ had closed the matter, Representative 

Buchanan requested that the Committee close its own inquiry with 

no further investigation based solely on DOJ’s decision. The Committee declined to do so, and continued its own investigation. These 

requests, and the Committee’s consideration of them, resulted in a 

delay of at least fifteen months. The Committee faced further 

delays as it attempted to obtain evidence collected in the other inquiries described above. 

As noted above, the Committee reviewed over 6,000 pages of materials, including statements by 22 witnesses. Much of this material was generated through the course of the parallel investigations 

described above.14 The Committee also interviewed Representative 


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offenses, the bulk of the outstanding factual questions were not relevant to its final conclusion. 

See infra Part V.A. 1511th Cir. Federal Criminal Pattern Jury Instructions at 347. 1618 U.S.C. § 1515(a)(1)(C). 17Previously codified as 2 U.S.C. §§ 431 et seq. 18See Representative Buchanan’s Financial Disclosure Statement for January 1, 2004–April 

30, 2006 (filed May 12, 2006). 19See FEC v. Kazran, No. 10-cv-1155, Docket # 1 at § 16 (M.D. Fla. Dec. 17, 2010). 

Buchanan, who agreed to appear before the Committee for a voluntary interview. 

III. HOUSE RULES, LAWS, REGULATIONS, AND OTHER 

STANDARDS OF CONDUCT 

A number of criminal statutes prohibit actions that intentionally 

interfere with ongoing government investigations. First, 18 U.S.C. 

201(b)(3) prohibits bribing a witness, which is the act of corruptly 

giving, offering, or promising anything of value to any witness with 

the intent to influence the witness’ testimony. Second, 18 U.S.C. 

§ 1505 prohibits persons from corruptly obstructing an executive 

branch agency proceeding. Obstruction of a proceeding is defined as 

‘‘do[ing] something to sway or change or prevent any action likely 

to be taken in the . . . proceeding.’’ 15 Finally, 18 U.S.C. 

§ 1512(b)(2)(A) prohibits witness tampering, which includes, among 

other things, corruptly persuading a witness in an official proceeding to fail to offer testimony, or to offer testimony that is false. 

An ‘‘official proceeding’’ includes agency proceedings as well as 

those in court.16

The Federal Election Campaign Act (FECA), 52 U.S.C. §§ 30101 

et seq., imposes a number of restrictions on campaign contributions, 

including a prohibition on making a campaign contribution in the 

name of another person.17 Contributions that violate FECA Section 

30122 are sometimes described as ‘‘reimbursed’’ or ‘‘conduit’’ contributions. Violations of Section 30122 are punishable based on the 

aggregate amount of offending contributions; contributions over 

$2,000 are misdemeanors punishable by a fine and up to a year imprisonment, while contributions over $25,000 are felonies punishable by a fine and up to five years imprisonment. 

Finally, House Rule XXIII, clauses 1 and 2 state that ‘‘[a] Member . . . of the House shall behave at all times in a manner that 

shall reflect creditably on the House,’’ and ‘‘shall adhere to the spirit and the letter of the Rules of the House . . .’’ (emphasis added). 

IV. BACKGROUND 

A. BUSINESS DISPUTES BETWEEN REPRESENTATIVE BUCHANAN AND

MR. KAZRAN, AND THE DRAFT AFFIDAVIT

From at least 2005 through 2008, Representative Buchanan, either directly or through a corporation he owned—1099 Management Company, LLC (1099 Management)—held an ownership interest in several car dealerships, including Venice Nissan Dodge 

(VND), Suncoast Ford (SCF), and Hyundai of North Jacksonville 

(HNJ).18 HNJ was, at the time relevant to this matter, a car dealership in Jacksonville, Florida. Representative Buchanan owned a 

majority stake in HNJ until 2008, when he sold his interest to Mr. 

Kazran, who had been up to that point the president and minority 

owner of HNJ.19


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20FEC, In the Matter of Vern Buchanan et al., MUR 6054 (hereinafter ‘‘FEC Investigation’’), 

Deposition of Representative Buchanan. 21 Id. 22 Id. 23 Id. It is worth noting that in 2008, a state court in Georgia held Mr. Kazran in contempt 

based on actions taken after a business he controlled entered receivership. See infra Part IV.B.3. 24See generally Kazran v. Buchanan, 2008 CA 15448 (Fla. Cir. Ct., Sarasota Cty.). 25See id.; see also 1099 Mgmt. Co., LLC v. Gwinnett, LLC., 16 2008 CA 011480 (Fla. Cir. Ct., 

Duval Cty.). 26FEC Investigation, General Counsel’s Report #7 at 4–5. 27 Id. 28OCE’s Referral, Ex. 8. 

Over the summer of 2008, Representative Buchanan’s business 

relationship with Mr. Kazran began to deteriorate. The fallout from 

that relationship was then litigated on a continuous basis and in 

a number of forums until at least late 2014. To summarize, when 

Representative Buchanan sold his interest in HNJ to Mr. Kazran, 

he loaned Mr. Kazran the funds used to purchase his equity interest, essentially converting his ownership in HNJ into a loan to Mr. 

Kazran.20 In 2008, Mr. Kazran sought additional funds from Representative Buchanan to purchase Kia dealerships in Jacksonville, 

which Representative Buchanan provided in the form of a $2.5 million personal unsecured loan.21 Representative Buchanan alleged 

that Mr. Kazran stopped repaying this loan in the summer of 

2008.22 Representative Buchanan was concerned that Mr. Kazran 

might declare bankruptcy, and he began negotiating a settlement 

that involved paying Mr. Kazran millions of additional dollars in 

exchange for ownership of other dealership properties.23 Mr. 

Kazran, for his part, claimed that Representative Buchanan 

breached a variety of agreements between them and their related 

businesses.24 Representative Buchanan and Mr. Kazran ended up 

filing suit against each other in at least two state courts.25

As discussed more fully below at Section IV.B.3., the evidence 

shows that before the breakdown in the relationship between Mr. 

Kazran and Representative Buchanan, over the course of two election cycles in 2006 and 2008, Mr. Kazran instructed HNJ employees and other individuals to contribute to VBFC.26 Mr. Kazran subsequently directed the HNJ controller to write checks drawn from 

HNJ accounts to those individuals to reimburse their contributions. 

The reimbursed contributions totaled $67,900.27 On September 8, 

2008, while the parties were discussing the resolution of their legal 

disputes, Mr. Kazran sent an email to John Tosch—the CEO of 

Representative Buchanan’s company, 1099 Management, LLC— 

stating that HNJ had reimbursed its employees for their contributions to VBFC: 

This is the 1st set of [reimbursement] checks, there are 

more to follow, It [sic] gives me great regret to have done 

this for Vern when he doesn’t even hesitates [sic] for a second to sue me and my wife over 20k. Maybe he can consider taking part of this 80k+ as one month of payment so 

my wife doesn’t cry out of fear of loosing [sic] our home.28

This September 8, 2008 email appears to have been the first 

clear indication to Representative Buchanan that Mr. Kazran had 

directed HNJ to reimburse contributions its employees made to 

VBFC. However, there had been prior communications between Mr. 

Kazran, Representative Buchanan, and their respective associates 

regarding campaign contributions generally. On August 26, 2008, 


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29OCE’s Referral ¶¶ 60, 61. 30 Id. 31For example, a review of Mr. Kazran’s contributions to VBFC would indicate that he did not make $80,000 in contributions to the campaign in his own name, which could raise the question of what the ‘‘over $80K’’ figure referred to. 32This attorney is not the same attorney that represented Representative Buchanan or VBFC 

in the FEC Investigation, OCE’s inquiry, or the Committee’s review. 33OCE’s Referral, Ex. 1. 34 Id. 35 Id. 36 Id. 37 Id. (emphasis added). 

Mr. Kazran emailed Representative Buchanan to discuss their 

legal dispute, and noted that he was ‘‘the only one in our group 

that has donated over 80k’’ to VBFC.29 On August 27, 2008, Joshua 

Farid, formerly the CFO of HNJ and Mr. Kazran’s brother-in-law, 

wrote to Mr. Tosch and referred to the support that ‘‘the dealership’’ had provided to Representative Buchanan’s campaign, ‘‘to a 

tune of $80K.’’ 30 While neither of these communications clearly alleged that HNJ had reimbursed its employees for their contributions to Representative Buchanan’s campaign, they might have 

alerted Representative Buchanan or his associates and counsel that 

something was amiss.31

On October 2, 2008—approximately three weeks after Mr. 

Kazran’s September 8, 2008 email to Mr. Tosch—Mike Lindell, the 

attorney representing Representative Buchanan in his civil dispute 

with Mr. Kazran,32 transmitted a Term Sheet outlining a proposed 

settlement of the outstanding disputes between Mr. Kazran and 

Representative Buchanan. Representative Buchanan’s signature 

appears on this Term Sheet, but during his testimony before the 

Committee, he could not recall signing the document, and stated 

that he may have signed it without reading it. 

Much of this Term Sheet was similar to previous settlement proposals between the parties, insofar as it proposed that Representative Buchanan and Mr. Kazran would settle their disputes, in exchange for which Representative Buchanan would purchase certain 

dealership assets from Mr. Kazran and help him pay off obligations 

at another dealership, through a cash payment of $2.9 million.33

Unlike the previous proposals, however, this Term Sheet included 

a draft affidavit regarding the reimbursed campaign contributions.34 The draft affidavit was prepared for Mr. Kazran’s signature, and accordingly refers to him in the first person.35 It stated 

that ‘‘[d]uring the course of tense and somewhat hostile negotiations between my lawyers and me, and representatives for [Representative] Buchanan, I advised a representative of [Representative] Buchanan that one or more of the dealerships of which I was 

in operational control had reimbursed certain individuals who had 

contributed to [VBFC].’’ 36 It went on to state that ‘‘[b]efore September 2008 neither I, nor to my knowledge any other person who 

had ever advised [Representative] Buchanan or any of his representatives had any information that [these dealerships] reimbursed certain individuals for contributions made to [VBFC].’’ 37

The affidavit further stated that Mr. Kazran had not heard Representative Buchanan threaten discrimination or reprisal to dealership employees for failing to make a contribution, had not heard 

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38 Id. 39FEC Investigation, Deposition of Representative Buchanan. 40 VGB–HCE 004296. 41 VGB–HCE 004312. 42FEC Investigation, Deposition of John Tosch. Representative Buchanan noted in his testimony that the time period in question included his wedding anniversary (during which he would 

have been unavailable for a dinner with Mr. Kazran). FEC Investigation, Deposition of Representative Buchanan. Additionally, Representative Buchanan recorded votes on bills in the 

House on the evening of October 2, 2008, and on the afternoon of October 3, 2008. 154 Cong. 

Rec. H10671–05 (2008) (Roll Call No. 676); 154 Cong. Rec. H10805 (Roll Call No. 681). 43OCE’s Referral, Ex. 2 §§ 31–33. 

tions, and had not been advised by any third party that Representative Buchanan was aware of plans to reimburse contributions.38

The precise nature of Representative Buchanan’s involvement in 

the process of either constructing the draft affidavit or attempting 

to get Mr. Kazran to sign it is very much in dispute. Representative Buchanan claimed in testimony before the FEC and the Committee that he had not seen the draft affidavit at the time it was 

provided to Mr. Kazran, although it was attached to the settlement 

term sheet that he signed.39 Indeed, during his testimony before 

the Committee, Representative Buchanan stated that he could not 

remember ever having reviewed the affidavit, despite it being a 

central part of both the FEC and OCE investigations. 

All of Mr. Kazran’s written communications regarding the reimbursed contributions and the settlement were directed at either Mr. 

Tosch or Representative Buchanan’s litigation counsel, and not to 

Representative Buchanan directly. However, Mr. Kazran stated to 

OCE that he had dinner with Representative Buchanan and Mr. 

Tosch in early October 2008, and at that dinner the two men pressured Mr. Kazran to sign the draft affidavit. Representative 

Buchanan, in his testimony before the FEC and the Committee, denied ever speaking directly to Mr. Kazran about the affidavit, and 

noted that Mr. Kazran stated in two emails that Mr. Kazran ‘‘attempted to speak with [Representative Buchanan] directly but he 

did not answer,’’ 40 and ‘‘[a]t no time [did Representative Buchanan 

and I] discuss[] signing documentation that has nothing to do with 

our agreement [sic].’’ 41 Mr. Tosch, for his part, denied ever discussing the affidavit in person with Mr. Kazran, and stated that 

all of his participation in negotiations during this period consisted 

of either conversations between the two sides’ attorneys, or unsolicited and unreciprocated contact from Mr. Kazran to Mr. Tosch, not 

the other way around.42

On the other hand, it is clear that Representative Buchanan 

knew by at least October 2008 of the allegation that HNJ reimbursed its employees for contributions to VBFC, as evidenced by a 

voicemail message that Representative Buchanan appears to have 

left for Mr. Kazran. While the transcript of the voicemail does not 

indicate its date, Mr. Kazran told OCE that he received and recorded the voicemail after he received the draft affidavit on October 

2, 2008, and after he allegedly had a conversation during which 

Representative Buchanan urged Mr. Kazran to sign the draft affidavit. 43 In the voicemail, Representative Buchanan did not specifically discuss the draft affidavit, but on one occasion he did assert 

that Mr. Kazran faced legal liability for any reimbursed contributions, while at the same time denying his own involvement: 

I think the threatening of the political stuff and all that, 

you got more liability than you know if you start telling 


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44FEC Investigation, Deposition of Sam Kazran. Representative Buchanan appears to have 

left a second voicemail message for Mr. Kazran, which did not directly mention reimbursed contributions, and instead focused on the private business disputes between him and Mr. Kazran, 

encouraging him to agree to a settlement. Nothing in the transcript of the recorded voicemails 

indicated the dates on which they occurred, but it is worth noting that by October 6, 2008, the 

draft affidavit had been removed from the proposed Term Sheet. 45See FEC Investigation, Sua Sponte Submission from VBFC (Oct. 6, 2008). 46 VGB–HCE 004315–19. 47 Kazran v. Buchanan (Aug. 10, 2012) (Third Amended Complaint). 48 Kazran v. Buchanan (Dec. 5, 2014) (Final Judgment). 49 Id. 50See FEC Investigation, Conciliation Agreement with Gary Scarbrough at ¶ 4 (Dec. 20, 2011). 

people that you reimbursed people, because technically you 

have that liability. All I told you, and I’ve always made it 

clear is that you can’t reimburse people. They’ve got to 

give it under their free will. You know that. At 12, 18 

points, we’re going to win the election anyway.44

Mr. Kazran ultimately refused to sign the draft affidavit, and on 

October 6, 2008, VBFC filed a self-report to FEC disclosing the improper contributions from HNJ and asking for guidance on how to 

dispose of those funds.45 VBFC ultimately disgorged the contributions, consistent with FEC’s recommendation. Also on October 6, 

2008, Representative Buchanan’s litigation counsel recirculated a 

revised Term Sheet, which did not contain the draft affidavit.46 On 

October 16, 2008, Representative Buchanan’s litigation counsel revised the Term Sheet again and sent it to Mr. Kazran’s attorneys; 

this version still excluded the draft affidavit, but increased Representative Buchanan’s proposed cash payout to $3 million. In the 

end, no agreement was reached. 

The parties continued to litigate their dispute in Florida state 

court. Mr. Kazran included in subsequent versions of his civil complaint allegations related to the draft affidavit, among other allegations.47 Specifically, Mr. Kazran alleged that Representative 

Buchanan abused the legal process by attempting to force Mr. 

Kazran to sign a false affidavit. Ultimately, the court granted partial summary judgment in favor of Representative Buchanan for 

some of Mr. Kazran’s claims, then entered a directed verdict 

against Mr. Kazran and in favor of Representative Buchanan on 

the rest of Mr. Kazran’s claims.48 While that disposition indicated 

that the court had rejected Mr. Kazran’s claims about the draft affidavit, the record does not make clear the court’s legal or factual 

rationale for doing so. Representative Buchanan prevailed on his 

own claims against Mr. Kazran after a jury trial.49

B. ALLEGATIONS OF REPRESENTATIVE BUCHANAN’S INVOLVEMENT

WITH, AND KNOWLEDGE OF, CONDUIT CONTRIBUTIONS TO VBFC

1. Suncoast Ford (SCF) 

SCF was, at the time relevant to this matter, a car dealership 

in Port Richey, Florida. Representative Buchanan owned a majority 

stake in SCF, but was not involved in its day-to-day operations; 

Gary Scarbrough was the operating minority partner. Four SCF officers and employees—Mr. Scarbrough, Kenneth Lybarger, Harold 

Glover, and M. Osman Ally—each contributed $4,600 to VBFC in 

March 2007 via personal check.50 According to Mr. Lybarger, SCF’s 

controller, Mr. Scarbrough, subsequently directed him to cut checks 

from SCF’s bank account to reimburse the four SCF officers and 


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51See FEC Investigation, General Counsel’s Report #10 at 3 (Apr. 29, 2011). 52See Id. at 4. 53See FEC Investigation, Conciliation Agreement with Gary Scarbrough at ¶ 8. 54FEC Investigation, General Counsel’s Report #10 at 6. 55See FEC Investigation, Conciliation Agreement with SCF at VI (Dec. 20, 2011); FEC Investigation, Conciliation Agreement with Gary Scarbrough at VI. 56FEC Investigation, General Counsel’s Report #9 at 12, 15 (Jan. 25, 2011). 57FEC Investigation, Conciliation Agreement with VND and Donald Caldwell at ¶¶ 1–2 (Aug. 

11, 2010). 58 Id. at ¶ 12. 59 Id. at ¶ 11. 60 Id. at ¶ 13. 61FEC Investigation, General Counsel’s Report #4 at 3 (June 2, 2010). 62FEC Investigation, Complaint at Ex. A. David Padilla, a former VND employee, similarly 

alleged that he was approached with an offer to contribute to VBFC and be reimbursed by VND; 

Mr. Padilla stated that he refused to participate. See Id. at Ex. D. 

employees for their VBFC contributions.51 Mr. Scarbrough told the 

FEC that, while Representative Buchanan had asked him on a 

number of occasions to contribute to VBFC, he could recall very little about the reimbursements themselves.52 Eventually, an auditor 

who worked for Buchanan Automotive Group reviewed SCF’s books 

and discovered the reimbursements. SCF then notified VBFC of the 

reimbursements, and VBFC refunded the contributions to the individuals in question.53 Mr. Scarbrough testified that, at the time he 

caused SCF to reimburse the individual contributions, he did not 

know that such reimbursement violated campaign finance laws, 

and that doing so was a ‘‘mistake.’’ 54 The FEC found, based on 

these uncontested facts, that SCF and Mr. Scarbrough had both 

knowingly violated 52 U.S.C. 30122, and directed SCF and Mr. 

Scarbrough to pay fines of $7,000 and $8,500, respectively.55 However, the FEC found no evidence that Representative Buchanan 

was involved in or aware of SCF’s decision to reimburse its employees’ contributions to VBFC.56 Representative Buchanan testified 

before the Committee that he was not involved in or aware of reimbursed contributions at SCF at the time they occurred. 

2. Venice Nissan Dodge (VND) 

VND was, at the time relevant to this matter, a car dealership 

in Venice, Florida. Representative Buchanan owned a majority 

stake in VND, but was not involved in its day-to-day operations, 

which were handled jointly by minority owner Shelby Curtsinger 

and general sales manager Donald Caldwell.57 On or about September 15 or 16, 2005, Caldwell met with VND employees Jack 

Prater, Carlo Bell, Jason Martin, Marvin White, and William 

Mullins, and gave each man $1,000 in cash.58 Mr. Caldwell obtained the funds he used for this distribution from the VND accounting office, and the funds were drawn from a VND bank account.59 Each of the five VND employees who received the $1,000 

in cash contributed the same amount to VBFC through personal 

checks written within a day or two after they received the cash.60

Mr. Caldwell admitted that, around the same time he gave the 

$1,000 to each of the five VND employees, he discussed with each 

of them the possibility that they might contribute to VBFC.61 The 

import of that conversation, however, was a matter of some disagreement. Mr. Bell alleged that Mr. Caldwell had explained that 

the $1,000 was a reimbursement for donating to VBFC, and that 

when Mr. Bell objected, Mr. Caldwell asked him if he was ‘‘on the 

team’’ or not.62 Messrs. Prater, Martin, White, and Mullins, howVerDate Sep 11 2014 07:33 Jun 28, 2016 Jkt 059006 PO 00000 Frm 00017 Fmt 6659 Sfmt 6602 E:\HR\OC\HR643.XXX HR643

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63See FEC Investigation, Statement of Reasons by Vice Chair Caroline C. Hunter at 4–5 (Dec. 

19, 2011). 64 Id. at 4–5. 65FEC Investigation, Conciliation Agreement with VND and Donald Caldwell at ¶ 15. 66 Id. at V–VI. It is important to note that the FEC’s vote to accept this agreement with VND 

and Mr. Caldwell was not unanimous—one Commissioner credited the testimony of Mr. 

Caldwell and the VND employees other than Mr. Bell and concluded that the evidence did not 

‘‘establish probable cause that a violation did occur.’’ FEC Investigation, Statement of Reasons 

by Vice Chair Caroline C. Hunter at 7. 67FEC Investigation, General Counsel’s Report #9 at 15. 68FEC v. Kazran, No. 10–cv–1155 Docket #1 (M.D. Fla. Dec. 17, 2010). 69FEC v. Kazran, Docket #65 (Feb. 29, 2012). HNJ appears to be a defunct entity and did 

not enter an appearance in the case. Thus, the district court entered default judgment against 

HNJ for the full amount of the reimbursed contributions. FEC v. Kazran, Docket #69 (Mar. 8, 

2012). 70FEC Investigation, Deposition of Sam Kazran; see also OCE’s Referral, Ex. 2 ¶ 14. 

ever, asserted that the bonuses were not connected to their contributions and that they gave to VBFC of their own free will.63

These four VND employees, as well as Mr. Caldwell, testified that 

the $1,000 cash payments were not unusual in the car sales business, and that they were paid to the VND employees for reaching 

certain performance targets.64 Despite this factual dispute, the 

FEC determined that there was probable cause to believe that the 

$1,000 cash payments, and the subsequent donations to VBFC, constituted a violation of 2 U.S.C. 441f.65 While VND and Mr. 

Caldwell never admitted guilt or responsibility for the violations, 

they nevertheless agreed to pay a fine of $11,000, and to request 

that VBFC disgorge the $5,000 in question.66 VBFC disgorged 

those funds on October 7, 2010, by check to the U.S. Treasury. As 

was the case for the contributions for SCF, FEC found no evidence 

that Representative Buchanan was involved with or aware of 

VND’s decision to reimburse its employees’ contributions to 

VBFC.67 Representative Buchanan testified to the Committee that 

he was not involved in or aware of reimbursed contributions at 

VND at the time they occurred. 

3. Hyundai of North Jacksonville (HNJ) 

Similar to both SCF and VND, the FEC found that Mr. Kazran 

and HNJ had violated 52 U.S.C. 30122 by reimbursing HNJ employees for contributions to VBFC. However, unlike the other two 

dealerships, the FEC was unable to reach an agreement with Mr. 

Kazran in its ordinary process, and instead filed suit against him 

and HNJ in the United States District Court for the Middle District of Florida.68 Mr. Kazran never admitted liability for his actions, but did ultimately settle the suit and agree to pay a fine of 

$5,500.69

The question of Representative Buchanan’s involvement in the 

HNJ reimbursements is subject to substantially more dispute than 

his apparent lack of involvement in reimbursements from the other 

two dealerships. Mr. Kazran alleged in his testimony before FEC 

and OCE that all the actions he took were at the repeated direction 

of Representative Buchanan: 

I instructed them to write a check and reimburse themselves for—because Mr. Buchanan had asked me to get 

money. And he specifically told me to get someone you 

trust and run it through the corporation.70

Other witnesses testified that, while they did not directly witness 

Representative Buchanan directing conduit contributions at HNJ, 


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71OCE’s Referral, Ex. 5 ¶ 13–15. 72Mr. Farid’s testimony is inconsistent with others, including Mr. Kazran himself, on this 

point. See infra n. 76 and accompanying text. 73 Id. at 10. 74FEC Investigation, General Counsel’s Report #9 at 14. 75 Id. at 7, 9. 76See OCE’s Referral, Ex. 2 ¶ 25 (‘‘There was no instance when [Mr. Kazran] allowed someone 

to overhear a phone call with Representative Buchanan when reimbursements were discussed. 

Anyone who said that is lying.’’) (emphasis added); FEC Investigation, General Counsel’s Report 

#9 at 8 (Mr. Farid’s understanding of Representative Buchanan’s involvement was ‘‘based on 

subsequent conversations [Mr. Farid] had with Mr. Kazran’’). 

they had observed other conversations and conduct that tended to 

show Representative Buchanan approving of such conduct. For example, HNJ’s controller, Gayle Lephart, who reimbursed several 

HNJ employees for contributions to VBFC, stated that she overheard Mr. Kazran tell Representative Buchanan, during a phone 

call, ‘‘Vern, I’ll handle it right now.’’ 71 Immediately after that call, 

Mr. Kazran directed Ms. Lephart to reimburse her own contribution to VBFC from HNJ funds. Joshua Farid stated that he overheard both sides of a telephone conversation during which Representative Buchanan told Mr. Kazran to reimburse contributions 

from HNJ employees with HNJ funds.72 Steve Silverio, one of Representative Buchanan’s former business partners, testified that 

during a lunch in August or September 2005, Dennis Slater, who 

worked for Representative Buchanan’s companies as Chief Operating Officer (COO), suggested that corporate funds could be used 

to reimburse contributions to Representative Buchanan’s first 

House campaign.73 More tangentially, Sal Rosa, a former officer in 

one of Representative Buchanan’s companies, stated that before 

Representative Buchanan ran for office himself, Representative 

Buchanan asked Mr. Rosa to have his company reimburse a political contribution for another candidate. Mr. Rosa claimed that 

when he objected, Representative Buchanan told him to ‘‘finesse 

it.’’ 74

However, the evidence described above was in many ways 

flawed, inconsistent, and ultimately insufficient to prove that Representative Buchanan was directly involved in, or was even aware 

of, the reimbursed contributions from HNJ. None of the documents 

contemporaneous with the reimbursed contributions corroborated 

Mr. Kazran’s testimony; indeed, his testimony consistently referred 

to oral direction from Representative Buchanan, as opposed to 

memos or emails instructing him to reimburse contributions. Similarly, none of the witness testimony described above could consistently corroborate Mr. Kazran’s allegations. By her own admission, 

Ms. Lephart never heard Representative Buchanan tell Mr. Kazran 

to reimburse contributions,75 and Mr. Kazran explicitly rejected 

Mr. Farid’s claim that Mr. Farid directly overheard Representative 

Buchanan tell Mr. Kazran to reimburse contributions during telephone conversations between Mr. Kazran and Representative 

Buchanan.76

Mr. Silverio’s testimony, similarly, did not directly connect Representative Buchanan to any of the reimbursed contributions, much 

less those that specifically took place at HNJ. While Mr. Silverio 

alleged that someone associated with Representative Buchanan 

suggested using corporate funds for contributions to VBFC generally, he did not connect Representative Buchanan directly to the 

suggestion, nor did he provide evidence that this suggestion led to 


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77 Compare OCE’s Referral, Ex. 2 ¶ 12 with FEC Investigation, Deposition of Sam Kazran. 

In his OCE statement, Mr. Kazran referred to a conversation he allegedly heard between Representative Buchanan and two of his colleagues in late 2005 or early 2006, where reimbursements were discussed. But the other alleged participants in that conversation denied hearing 

Representative Buchanan authorize reimbursed contributions. See, e.g., OCE’s Referral, Ex. 10 

¶ 23. 78FEC Investigation, General Counsel’s Report # 9 at 3–4. Mr. Kazran’s motives for attacking 

Representative Buchanan are discussed more fully in the section above. 79 Id. at 3. 80 Id. 81FEC Investigation, Notification to Vernon G. Buchanan (Feb. 7, 2011). 

any reimbursement of campaign contributions from corporate 

funds. In the same way, Mr. Rosa’s uncorroborated testimony suggests that Representative Buchanan may have failed to comply 

with federal election laws when he raised funds for a different candidate, prior to entering politics himself. But other than an isolated 

comment to ‘‘finesse’’ the legality of a contribution, Mr. Rosa provided no additional information about Representative Buchanan 

knowing or approving of a specific scheme to reimburse those contributions. Put another way, the one-off comments that Mr. Silverio 

and Mr. Rosa heard and testified to were made in different contexts and without any contextual connection to the contributions at 

HNJ. 

Mr. Kazran’s uncorroborated testimony suffered from another, 

larger problem: his lack of credibility. Mr. Kazran’s statement to 

OCE was inconsistent with his testimony before the FEC: he testified to the former that Representative Buchanan first directed Mr. 

Kazran to reimburse contributions in June 2006, whereas Mr. 

Kazran told the FEC that first occurred in November 2005.77 Because HNJ first reimbursed contributions to VBFC in 2005, Mr. 

Kazran’s testimony to OCE makes it less likely that Representative 

Buchanan was involved in at least those initial contributions, if not 

the entire series of reimbursements. Mr. Kazran also appeared at 

times during the investigations to be motivated by personal and 

professional animus for Representative Buchanan. For example, in 

the weeks leading up to the 2010 election, he threatened to publicize the FEC investigation, in potential violation of the FEC’s confidentiality rules, by filing a lawsuit related to the investigation.78

Perhaps most concerning, a Georgia state court ordered Mr. 

Kazran to serve jail time for contempt of court, arising out of his 

fraudulent transfer of over $100,000 from car dealerships owned by 

Mr. Kazran that were in receivership.79 The FEC found that Mr. 

Kazran’s conduct in that case reflected both on his honesty and his 

respect for the law.80

Viewed in this context, Mr. Kazran’s claims about what happened at HNJ fit less tidily into the totality of the circumstances. 

Without corroboration of Representative Buchanan’s instruction to 

reimburse contributions, the pressure he may have exercised on his 

colleagues to donate to his campaigns appears less like a prelude 

to an illegal conduit scheme and more like hard-sell fundraising, 

which is not illegal. In the end, the flaws in Mr. Kazran’s story and 

his character made it at least equally likely that he decided to reimburse the contributions himself, without Representative 

Buchanan’s knowledge or involvement. The FEC appears to have 

reached this conclusion, and took no further action with respect to 

Representative Buchanan.81 In his testimony before the Committee, Representative Buchanan again asserted that he had not 


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82See FEC Investigation General Counsel’s Report #9 at 20. 83 Id. at 19. 84 Id. at 21. 85 Id. at 22. 86 Id. 

been involved in or had any knowledge of the reimbursed contributions at HNJ at the time they occurred. 

When recommending that the FEC close its investigation of Representative Buchanan, the FEC’s Acting General Counsel noted 

that Representative Buchanan’s testimony was ‘‘not particularly 

credible.’’ 82 For example, the FEC’s Acting General Counsel concluded that, despite Representative Buchanan’s testimony to the 

contrary, it was unlikely that Representative Buchanan was not involved in the drafting of the affidavit.83 In addition, Representative 

Buchanan testified that he could not remember asking Mr. Kazran 

to raise funds for VBFC, and testified that he did not ‘‘know what 

anybody has raised.’’ However, the FEC’s Acting General Counsel 

noted that VBFC kept lists of the amounts that Representative 

Buchanan’s partners had raised, and his campaign treasurer testified that Representative Buchanan would regularly discuss fundraising activities with his partners at business meetings and 

through personal follow-ups.84 Despite these issues, the FEC’s Acting General Counsel recommended dismissal of the investigation of 

Representative Buchanan because these ‘‘inconsistencies on background issues do not necessarily show that [Representative] 

Buchanan directed [Mr.] Kazran to reimburse contributions.’’ 85

However, the FEC’s Acting General Counsel stated that Representative Buchanan’s ‘‘inability to remember basic facts as to these 

uncontroversial, routine issues detracts from his credibility.’’ 86

When the Committee interviewed Representative Buchanan, his 

recollection of details regarding fundraising from business partners 

was similarly vague. He had very little specific recollection of having solicited campaign donations from any particular partner or 

group of partners, although he acknowledged that ‘‘sometimes people would ask me if they could help in the campaign’’ after having 

meetings with his partners. He noted that the campaign did track 

donors, but that his own focus was on ‘‘relationships and people 

that I’ve worked with over the years [and soliciting a] maxed out 

contribution,’’ as opposed to asking his colleagues to host largescale fundraisers or bundle contributions from their own networks. 

When asked about the similarities between the alleged conduit 

contributions at the aforementioned companies, Representative 

Buchanan denied that he had any knowledge or involvement in any 

of them, or of any coordination between these entities. Rather, Representative Buchanan postulated: 

I have 55 entities. You’re talking about Dodge where 

there is five or six people reimbursed $1,000. You’re talking about a Ford store that’s up in the Clearwater area 

that was $10,000, and Sam Kazran, that I’m aware of, and 

we raised in excess of $10 million [in campaign contributions]. [T]he reality of it is, when you raise that much 

money over a period of 12 years almost, you’re going to 

have some incidences. . . . I do think that we had partners that were naı ̈ve. . . . Unfortunately some of them 

were just overzealous to some extent. I don’t think it’s a 


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87Previously codified as 2 U.S.C. § 441f. 88 11 C.F.R. § 110.4(b)(1)(iii); 54 Fed. Reg. 34098 (1989). 89See 52 U.S.C. § 30109(a)(5)(B), 30109(d), previously codified as 2 U.S.C. § 437g. 90 United States v. Hopkins, 916 F.2d 207, 214 (5th Cir. 1990). 91FEC Investigation, General Counsel’s Report #9 at 27. 92 Id. 

lot in terms of the magnitude over all, but it’s too much 

by any standard . . . we don’t take employee contributions 

anymore. 

V. FINDINGS 

A. 52 U.S.C. 30122 87

A federal campaign finance statute, 52 U.S.C. 30122, prohibits 

persons from making contributions in the name of another. The 

prohibition applies not only to persons who make such contributions, but also to persons who assist in such contributions, including ‘‘those who initiate or instigate or have some significant participation in a plan or scheme to make a contribution in the name of 

another[.]’’ 88 The statute applies to ‘‘knowing’’ and ‘‘willful’’ violations,89 which is not to say that violations require a specific knowledge of the law, but rather that the defendant ‘‘acted deliberately 

and with knowledge that the representation was false.’’ 90 The FEC 

investigated the reimbursed contributions from Buchanan-affiliated 

companies to VBFC, and did not find that Representative 

Buchanan was responsible for violations of Section 441f.91 While 

the FEC staff noted that the matter ‘‘came close’’ to such a finding 

with respect to reimbursed contributions from one of the dealerships—HNJ—the FEC nevertheless voted to close the matter and 

take no further action.92

The Committee’s own review of the evidence led to the same conclusion reached by the FEC. The witnesses to Representative 

Buchanan’s involvement with the conduit contributions at HNJ 

contradicted each other and could not substantiate a direct link between Representative Buchanan and the reimbursed contributions. 

Ms. Lephart heard only Mr. Kazran’s side of a telephone conversation, which did not include any explicit direction from Representative Buchanan. Mr. Farid, who was Mr. Kazran’s relative, claimed 

to have heard both sides of a conversation between Mr. Kazran and 

Representative Buchanan, but Mr. Kazran said that was a lie. Mr. 

Kazran himself had provided inconsistent testimony when speaking 

to the FEC and OCE, and his credibility was further compromised 

when a state court in Georgia convicted him of contempt in 2008 

for diverting funds from one of his companies in violation of a court 

order. 

The Committee was initially troubled that three different 

Buchanan-affiliated companies were caught reimbursing contributions to VBFC, along with a fourth company owned and controlled 

by Representative Buchanan’s close friend, Timothy Mobley. Such 

facts reasonably raise questions about Representative Buchanan’s 

involvement in the various schemes and explain why so many entities investigated these allegations. The Committee was also concerned that Mr. Silverio testified that one of Representative 

Buchanan’s close associates suggested reimbursing contributions as 

a general matter, and that Mr. Rosa testified that, before Representative Buchanan even ran for office himself, he suggested reVerDate Sep 11 2014 07:33 Jun 28, 2016 Jkt 059006 PO 00000 Frm 00022 Fmt 6659 Sfmt 6602 E:\HR\OC\HR643.XXX HR643

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93FEC General Counsel’s Report #9 at 11. 94See, e.g., Arthur Andersen v. United States, 544 U.S. 696 (2005); United States v. Bhagat, 

436 F.3d 1140 (9th Cir. 2006). 95 Arthur Andersen, 544 U.S. at 706. 

imbursing contributions for another candidate from corporate 

funds. 

However, when viewed in the context of all the available evidence, these facts, on their own, were not sufficient to conclude 

that Representative Buchanan knew of the unlawful reimbursements prior to September 2008, or had some role in directing or approving of them. Indeed, it is not unreasonable to conclude that 

each dealership’s management, in response to intense fundraising 

efforts from VBFC, made a similar error in judgment and reimbursed contributions independent of the choices of one another. 

Moreover, none of the witnesses could credibly claim that they 

heard Representative Buchanan direct the reimbursement of campaign contributions to VBFC, or even show that he knew of them. 

While Mr. Silverio did testify that an associate of Mr. Buchanan 

suggested reimbursing contributions through corporate funds, as 

the FEC said, Mr. Silverio’s testimony ‘‘eliminated [Representative] 

Buchanan’s involvement in this incident.’’ 93 The witness who came 

closest to implicating Representative Buchanan directly—Mr. 

Rosa—testified about a conversation that occurred before Representative Buchanan even ran for his House seat and concerned 

a different candidate. All told, there was insufficient evidence to 

conclude that Representative Buchanan knew of or directed conduit 

contributions at any companies with which he was affiliated. 

Accordingly, the Committee did not find that Representative 

Buchanan violated Section 30122. 

B. TITLE 18

Three statutes criminalize improper influence over the testimony 

of witnesses before federal tribunals. Those statutes—sections 

201(b)(3), 1505, and 1512(b)(1) of Title 18—criminalize related conduct in slightly different ways. First, 18 U.S.C. 201(b)(3) prohibits 

persons from knowingly and corruptly giving, offering, or promising 

anything of value to a witness, with the intent of influencing that 

witness’ testimony. Second, 18 U.S.C. 1505 prohibits persons from 

knowingly and corruptly influencing, obstructing, or impeding 

pending proceedings before a federal agency, such as the FEC, or 

from knowingly and corruptly endeavoring to influence, obstruct, or 

impede such a proceeding. Third, 18 U.S.C. 1512(b)(1) prohibits 

persons from knowingly and corruptly intimidating, threatening, 

engaging in misleading conduct, or corruptly persuading another 

person with the intent of influencing a person’s testimony. All of 

these statutes prohibit ‘‘knowing’’ and ‘‘corrupt’’ actions, which is to 

say that a particular act only violates the law if it was taken with 

the intent to accomplish the wrongful end.94 The Supreme Court 

has clarified that, at least with respect to Section 1512, liability is 

limited to ‘‘persuaders conscious of their wrongdoing.’’ 95 And the 

statutes themselves state that they do not apply to actions that 

‘‘consisted solely of lawful conduct and [where] the defendant’s sole 

intention was to encourage, induce, or cause the other person to 


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96 18 U.S.C. § 1512(e). 97 18 U.S.C. § 1515(c). 98OCE’s Referral § 37. 99 Id. ¶ 38–41, Ex. 2. 100 Id. ¶ 43–50. 101 Id. ¶ 87. 102 Id. ¶ 53–57. 103 Id. ¶ 62–63. 104 Id. ¶ 65. 

testify truthfully,’’ 96 as well as ‘‘the providing of lawful, bona fide, 

legal representation services in connection with or anticipation of 

an official proceeding.’’ 97

Paragraph 5 of the draft affidavit would have required Mr. 

Kazran to swear that he, Mr. Kazran, did not know that HNJ reimbursed its employees’ contributions to VBFC until September 2008, 

after the reimbursements occurred.98 However, the record shows 

that Mr. Kazran did know of the reimbursed contributions before 

September 2008. First, Mr. Kazran has admitted directing the reimbursements in 2005, 2006, and 2007.99 Additionally, Ms. Lephart 

and Mr. Farid both testified that Mr. Kazran was involved in the 

reimbursements.100 However, to demonstrate that Representative 

Buchanan attempted to improperly influence Mr. Kazran’s testimony would require a showing that Representative Buchanan 

knew the statement about Mr. Kazran’s knowledge was in the draft 

affidavit, and knew that statement was false. 

The Committee reviewed the available evidence and ultimately 

concluded that the evidence was insufficient to find that Representative Buchanan knowingly or corruptly attempted to influence Mr. 

Kazran’s testimony in an unlawful way. This finding was consistent with the reviews of the FEC, DOJ, and the Florida state 

court. OCE, however, found substantial reason to believe Representative Buchanan improperly influenced Mr. Kazran’s testimony before the FEC. OCE noted in its Referral that the fact that 

some witnesses, including Representative Buchanan, failed to cooperate with its investigation permitted it to draw an adverse inference against those witnesses. However, OCE determined that, 

even without such an inference, the evidence was ‘‘more than sufficient’’ to support its determination.101

Thus, despite the lack of cooperation from Representative 

Buchanan, OCE found there was substantial reason to believe that 

Representative Buchanan knew that paragraph 5 was false. This 

finding was based on certain communications between Mr. Kazran 

and either Representative Buchanan or Representative Buchanan’s 

employees. As a threshold matter, OCE noted that the September 

8, 2008 email itself disclosed Mr. Kazran’s involvement in the reimbursed contributions, giving Representative Buchanan notice that 

Mr. Kazran would have known about them before that date.102

OCE further relied on two emails sent by Mr. Kazran and Mr. 

Farid to employees of Representative Buchanan in August 2008, 

discussing campaign contributions, noting that HNJ had supported 

Representative Buchanan ‘‘to a tune of $80K’’ and that Mr. Kazran 

was ‘‘the only one in our group that has donated over 80k’’ to 

VBFC.103 Finally, OCE noted that Representative Buchanan himself stated in an October 2008, voicemail that Mr. Kazran had legal 

responsibility for the reimbursed contributions, and therefore must 

have known of Mr. Kazran’s own involvement.104


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105Letter from Counsel to Representative Buchanan to OCE (‘‘Representative Buchanan’s 

OCE Response’’) at 3. 106 Id. at 3–4. 107 Id. at 4. 108 It is worth noting that OCE did not cite any case law or other precedent supporting its 

application of the three statutes in question to the facts as OCE found them. 

Representative Buchanan has offered two responses to the allegation that he intended to cause Mr. Kazran to sign a false affidavit. First, he has stated that Paragraph 5 of the draft affidavit 

was true on its face.105 However, Representative Buchanan reaches 

this conclusion by ignoring key language from Paragraph 5, namely 

the statement that Mr. Kazran did not know of the illegal reimbursements before September 2008. FEC’s Acting General Counsel 

found that this portion of the affidavit was false,106 and the Committee reached the same conclusion. 

Second, and more persuasively, Representative Buchanan asserts 

that Paragraph 5, while it is ‘‘admittedly inartful and contains 

typos,’’ was intended to establish that Representative Buchanan 

had no knowledge of the reimbursed campaign contributions prior 

to Mr. Kazran’s September 8, 2008, email to Mr. Tosch.107 In other 

words, Representative Buchanan claims that the false language in 

Paragraph 5 was a drafting error, and that this is clear from the 

general purpose of the draft affidavit, the circumstances surrounding it, and the sections other than Paragraph 5. Representative Buchanan also claims that he did not see the draft affidavit 

until years after it was provided to Mr. Kazran. 

While OCE focused on the plain reading of Paragraph 5, and the 

false statement it contained, it did not explain why Representative 

Buchanan would have wanted Mr. Kazran to swear that Mr. 

Kazran was unaware of the reimbursed contributions prior to September 2008, given that the draft affidavit was intended to be filed 

with the FEC, to establish Representative Buchanan’s lack of 

knowledge of the reimbursement scheme. However, Representative 

Buchanan’s intentions regarding the draft affidavit are critical to 

the determination of whether his provision of an admittedly false 

affidavit to Mr. Kazran was a violation of any of the criminal statutes OCE cited. 

Ultimately, the Committee did not find sufficient evidence that 

Representative Buchanan knowingly or corruptly attempted to influence Mr. Kazran’s testimony in an unlawful way. As a threshold 

matter, an offer of a monetary settlement in exchange for the execution of an affidavit, without further evidence of corrupt intent, is 

not illegal. Indeed, such offers are a standard element of settlement 

discussions in commercial litigation. Of course, if Representative 

Buchanan knowingly or corruptly attempted to cause Mr. Kazran 

to sign a false affidavit, he may have violated the statutes OCE 

cited in its Referral.108 But proof of such a violation requires an 

analysis of Representative Buchanan’s intent; it is not enough 

merely to show that Representative Buchanan’s attorney presented 

an affidavit containing a single false statement to Mr. Kazran. 

Thus, the Committee considered the totality of the circumstances 

surrounding the language at issue. 

This analysis necessarily begins with Representative Buchanan’s 

knowledge of the contents of the affidavit. Representative 

Buchanan testified that he had not seen the affidavit at the time 

it was presented to Mr. Kazran, and OCE’s Referral did not cite 


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109FEC General Counsel’s Report #9 at 19. 110Of course, the October 2, 2008 Term Sheet does bear Representative Buchanan’s signature. 

Representative Buchanan acknowledged that he may have signed the signature page of the October 2, 2008 term sheet without reviewing the rest of the document, including the affidavit. 

The signature lines are on a separate page from the settlement terms and the affidavit. 111See OCE’s Referral, Ex. 2 ¶ 31; FEC Investigation, Deposition of Sam Kazran. 112See FEC Investigation, General Counsel’s Report #9 at 17–19. 113See FEC Investigation, Deposition of Sam Kazran; FEC General Counsel’s Report #2, 20. 114See, e.g., United States v. Brand, 775 F.2d 1460, 1469 (11th Cir. 1985); see also Resolution 

Trust Corp. v. Bright, 6 F.3d 336, 341 (5th Cir. 1993) (‘‘Placing statements in a draft affidavit 

that have not been previously discussed with a witness does not automatically constitute badfaith conduct’’); Harrington v. United States, 267 F. 97, 101 (8th Cir. 1920) (‘‘It is not an unlawful attempt to influence or impede a witness, or the due administration of justice, for one to 

any evidence to the contrary. While the FEC’s Acting General 

Counsel found that ‘‘[i]t is improbable that Buchanan’s attorneys 

drafted the affidavit and presented it to Kazran without 

Buchanan’s involvement,’’ 109 there is no evidence, either in documents or testimony, showing that Representative Buchanan actually reviewed the final document, including the disputed language 

in Paragraph 5, before his attorney presented it to Mr. Kazran.110

Thus, the Committee could not conclude that Representative 

Buchanan provided an affidavit to Mr. Kazran that Representative 

Buchanan had read and knew to be false. 

Moreover, as Representative Buchanan has explained, the idea 

that Paragraph 5 was intended to establish Mr. Kazran’s lack of 

knowledge of the reimbursed contributions before September 2008 

makes very little sense given the context of the draft affidavit and 

the surrounding dispute. By October 2, 2008, Representative 

Buchanan had been aware for a month that HNJ employees had 

made improper contributions to VBFC. If indeed he was not involved in those contributions, he understood that liability would 

rest on those who were responsible, namely Mr. Kazran. The 

voicemail recorded by Mr. Kazran confirms Representative 

Buchanan’s understanding, when he stated that ‘‘technically [Mr. 

Kazran has] that liability.’’ In fact, not only did Representative 

Buchanan appear to understand Paragraph 5 (and the rest of the 

draft affidavit) to disclaim only his own knowledge and not Mr. 

Kazran’s knowledge, Mr. Kazran himself understood the draft affidavit in this way, stating that the draft affidavit made him the 

‘‘fall guy’’ and ‘‘blame[d] everything on [Mr. Kazran.]’’ 111 The FEC 

also appears to have adopted this understanding of Paragraph 5,112

as both its questioning of Mr. Kazran and an initial report from the 

General Counsel focused on the draft affidavit only insofar as it 

might disclaim knowledge on the part of Representative 

Buchanan.113 Put another way, many persons used context clues to 

read paragraph 5 in a way that, while inconsistent with its plain 

text, placed it in line with the rest of the circumstances. 

Such a conclusion is even more reasonable considering the nature of the draft affidavit itself. It is not uncommon for attorneys 

to secure statements from witnesses in anticipation of a proceeding, 

which can include drafting a proposed statement for discussion 

with that witness. It is also not fair to assume, without other evidence, that such drafts represent a premeditated and intentional 

attempt to put words in a witness’s mouth, or that they are not 

subject to negotiation and revision. Courts that have confronted 

similar issues have held that simply providing a potential witness 

with a draft affidavit for his signature does not, by itself, constitute 

the obstruction of justice.114


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seek to obtain from a witness a statement of the facts as he believes them to be, without the 

exercise of undue influence, even though such a statement may conflict with prior testimony 

given by the one making the statement. Such an effort is not regarded with favor, because of 

the temptation to influence the witness unduly; but the mere request for a statement believed 

to be true . . . is not corrupt conduct.’’). 115G–I Holdings, Inc. v. Baron & Budd, 179 F.Supp.2d 233 (S.D.N.Y. 2001). 116Philadelphia Reserve Supply Co. v. Nowalk & Assoc., Inc., No. 91–CV–0449, 1992 WL 

210590 at *6 (E.D. Pa. Aug. 25, 1992). 

On a similar note, it is unclear that simply providing paragraph 

5 in the course of settlement negotiations constituted ‘‘corrupt persuasion’’ under Section 1512, or obstruction of justice, or witness 

bribery. There appear to have been no consequences for Mr. 

Kazran’s refusal to sign the draft affidavit in terms of the ongoing 

dispute between him and Representative Buchanan. The Term 

Sheets before and after the one that included the draft affidavit do 

not evidence an attempt to increase the value of any settlement 

that included the draft affidavit; rather, the monetary value of Representative Buchanan’s settlement offer to Mr. Kazran increased 

after the draft affidavit was dropped from the agreement. Similarly, far from being a nonnegotiable condition for Representative 

Buchanan, the evidence suggests that his attorneys continued to 

negotiate in the same way they had, irrespective of whether the 

draft affidavit was included. Even Mr. Kazran’s September 8, 2008 

email disclosing the reimbursed contributions came in the context 

of these same settlement negotiations, and so it appears that it was 

Mr. Kazran, not Representative Buchanan, who injected the campaign finance issues into the unrelated commercial dispute between 

the two men. Nor does the fact that Representative Buchanan 

countersued Mr. Kazran in the commercial dispute establish any 

corrupt intent to influence his testimony. Courts considering allegations of witness tampering in settlement negotiations have held 

that ‘‘threats of litigation do not form the basis of a witness tampering allegation,’’ 115 and that ‘‘[i]n a litigious society such as ours, 

it is thin-skinned to think that a threatened counter-suit, or otherwise, in response to an initial threat of legal action is witness intimidation rather than a mere puffing or power play among negotiators.’’ 116

It is notable that DOJ received a citizen complaint regarding 

these same allegations, and chose not to pursue criminal charges 

against Representative Buchanan. Similarly, Mr. Kazran included 

related allegations regarding the draft affidavit in his complaint 

against Representative Buchanan in Florida state court, and Representative Buchanan prevailed in that case. The Committee is not 

privy to the internal rationale for DOJ’s decision, and did not observe the Florida state proceedings firsthand. The Committee 

would not defer to these decisions, even if their basis was clear. 

But based on the Committee’s own analysis above, it has found no 

reason to deviate from the result reached in those two forums. Accordingly, the Committee found insufficient evidence that Representative Buchanan violated Section 201, 1505, or 1512 of Title 

18. 


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117See, e.g., Comm. on Ethics, In the Matter of Allegations Relating to Representative Alcee 

L. Hastings, H. Rept. 113–663, 113th Cong. 2d Sess. at 14–15 (2014); In the Matter of Allegations Relating to Representative Don Young, H. Rept. 113–487, 113th Cong. 2d Sess. 45–46 

(2014); In the Matter of Allegations Relating to Representative Shelley Berkley, H. Rept. 112– 

716, 112th Cong. 2d Sess. 36–37 (2012). 118 114 Cong. Reg. 8778 (Apr. 3, 1968) (Statement of Representative Price). 119 Ethics Manual at 16. 120 114 Cong. Reg. 8778 (Apr. 3, 1968) (Statement of Representative Price). 121 House Comm. on Standards of Official Conduct, Report under the Authority of H. Res. 418, 

H. Rept. 90–1176, 90th Cong. 2d Sess. 17 (1968). 122 114 Cong. Reg. 8778 (Apr. 3, 1968) (Statement of Representative Price). 123 Ethics Manual at 17 (citing House Select Comm. on Ethics, Advisory Opinion No. 4, H. 

Rept. 95–1837, 95th Cong. 2d Sess. app. 61 (1979)). 124See generally United States v. Wiltberger, 18 U.S. (5 Wheat.) 35, 43 (1820). 

C. HOUSE RULE XXIII, CLAUSES 1 AND 2

As stated in previous reports,117 the Committee observes two 

basic principles when applying the first two clauses of the Code of 

Conduct. First, Members must at all times act in a manner that 

reflects creditably upon the House. This standard was created to 

provide the Committee ‘‘the ability to deal with any given act or 

accumulation of acts which, in the judgment of the [C]ommittee, 

are severe enough to reflect discredit on the Congress.’’ 118 Clause 

1 ‘‘encompass[es] violations of law and abuses of one’s official position.’’119 It is a ‘‘purposefully . . . subjective’’ standard.120

Second, the Committee notes the proposition that the Code of 

Conduct and other standards of conduct governing the ethical behavior of the House community are not criminal statutes to be construed strictly, but rather—under clause 2 of House Rule XXIII— 

must be read to prohibit violations not only of the letter of the 

rules, but of the spirit of the rules. Ethical rules governing the conduct of Members were created to assure the public of ‘‘the importance of the precedents of decorum and consideration that have 

evolved in the House over the years.’’ 121 The standard ‘‘provide[s] 

the House with the means to deal with infractions that rise to trouble it without burdening it with defining specific charges that 

would be difficult to state with precision.’’ 122 The practical effect 

of Clause 2 is to allow the Committee to construe ethical rules 

broadly, and prohibit Members, officers and employees of the 

House from doing indirectly what they would be barred from doing 

directly. The Ethics Manual states that ‘‘a narrow technical reading of a House Rule should not overcome its ‘spirit’ and the intent 

of the House in adopting that and other rules of conduct.’’ 123

The Committee has endeavored to read the applicable laws and 

rules in this matter in light of these provisions in the Code of Conduct. This is somewhat in tension with the general rule that criminal statutes such as those that formed the basis of OCE’s Referral 

are to be construed narrowly.124 But even a broad reading of applicable rules does not create liability in the absence of substantial 

evidence of wrongdoing. Clause 2 of the Code of Conduct is intended to capture instances where there is such evidence that a 

party violated the spirit of the rule, not to create a lower standard 

of proof. Innuendo is not evidence. In this case, the FEC, DOJ, and 

a Florida state court examined the facts of Representative 

Buchanan’s relationship with Mr. Kazran, and none of them were 

able to substantiate any violations of election laws or witness intimidation. The Committee has reviewed the evidence and does not 

find sufficient basis to reach an alternative conclusion. 


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125See FEC Investigation General Counsel’s Report #9 at 20–22. 126 Id. at 19. 127 It would have been prudent for Representative Buchanan to have read the affidavit before 

his attorneys transmitted it to Mr. Kazran, particularly given that Representative Buchanan 

signed the Term Sheet to which the affidavit was attached. 

Having said that, the Committee is concerned that, when recommending that the FEC dismiss the investigation of Representative 

Buchanan, the FEC’s Acting General Counsel found that the evidence ‘‘comes close’’ to showing that Representative Buchanan directed or was aware of reimbursed contributions from HNJ. Moreover, if indeed that evidence of his involvement had been more substantial, even Representative Buchanan’s proffered interpretation 

of Paragraph 5 of the draft affidavit—that he did not know of reimbursed contributions at HNJ before September 2008—would have 

been false, and consequently, the Committee’s conclusion regarding 

the import of the draft affidavit may have been different. 

Indeed, it is troubling that part of the ‘‘close’’ case for the FEC’s 

Acting General Counsel was its determination that parts of Representative Buchanan’s own testimony were ‘‘not particularly credible.’’ 125 To be clear, the Committee’s own review of Representative 

Buchanan’s testimony led the Committee to slightly different conclusions about Representative Buchanan’s candor. For example, the 

FEC’s Acting General Counsel concluded it unlikely that Representative Buchanan was not involved in the drafting of the affidavit, because (1) the affidavit related to matters outside the scope 

of the private dispute between Representative Buchanan and Mr. 

Kazran, which was the primary focus of the negotiations, and (2) 

because it related to a matter that could have had electoral consequences for Representative Buchanan in advance of the 2008 

House elections.126 Representative Buchanan’s testimony before 

the Committee was similarly vague and unclear regarding his role 

in drafting the affidavit, especially his continued lack of recall with 

respect to the document, despite no fewer than three investigations 

regarding it. It would be more understandable if Representative 

Buchanan claimed that the passage of time had made it difficult 

to recall the process of drafting an eight-year-old affidavit, but it 

is more difficult to ascertain precisely how he might have remained 

ignorant of a two-page document that has become so central to his 

own reputation. 

But despite this lack of clarity, the evidence is simply insufficient 

to show precisely what role he had in drafting the affidavit, if any. 

Apart from the circumstances the FEC’s Acting General Counsel 

describes, the General Counsel cited no evidence to contradict Representative Buchanan’s testimony that he had almost nothing to do 

with the affidavit, and even if he had been more engaged, that does 

not suggest that he would have caught the false statement in paragraph 5 that so many others apparently missed.127

On the other hand, some of the FEC’s Acting General Counsel’s 

concerns about Representative Buchanan’s credibility arose because 

other, credible evidence contradicted his testimony, especially as it 

related to his involvement in his campaign’s fundraising activities. 

While Representative Buchanan testified that he could not remember asking Mr. Kazran to raise funds for VBFC, and testified that 

he did not ‘‘know what anybody has raised,’’ the FEC noted that 

VBFC kept lists of the amounts that Representative Buchanan’s 


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128 Id. at 21. 129 Id. at 22. 130 Id. 

partners had raised, and his campaign treasurer testified that Representative Buchanan would regularly discuss fundraising activities with his partners at business meetings and through personal 

follow-ups.128 Indeed, Representative Buchanan’s lack of recall 

about basic details of his fundraising, while perhaps explainable by 

his tendency to rely on others to work out the details of his strategies, made his testimony before the Committee at least difficult to 

follow, if not difficult to believe. 

The FEC’s Acting General Counsel concluded, and the Committee agreed, that ‘‘inconsistencies on background issues do not 

necessarily show that [Representative] Buchanan directed [Mr.] 

Kazran to reimburse contributions.’’ 129 But as the recommendation 

of the FEC’s Acting General Counsel stated, Representative 

Buchanan’s ‘‘inability to remember basic facts as to these 

uncontroversial, routine issues detracts from his credibility.’’ 130 If 

there were additional evidence that, beyond simply failing to recall 

basic and uncontroversial facts, a Member had provided false testimony on material facts to a government agency, the Committee 

would likely consider such false testimony a violation of Clauses 1 

and 2 of the Code of Conduct. Representative Buchanan, and all 

Members, should assiduously guard their credibility, as it is an integral part of the public trust they inherit through their service. 

The Committee notes that in both the circumstances surrounding 

contributions to VBFC reimbursed through Buchanan-affiliated 

companies, and in the circumstances surrounding the draft affidavit, Representative Buchanan has put forth very little evidence, 

if any, regarding his own oversight and compliance efforts. He testified to the FEC that VBFC sent a letter to Buchanan-affiliated 

companies regarding election laws after he learned of problems 

with reimbursed contributions, but never produced such a letter to 

the FEC or the Committee, and, while he testified that he no 

longer accepts contributions from employees of Buchanan-affiliated 

companies, he apparently took no corrective action with respect to 

any employees implicated in the conduit contributions. In his testimony before the Committee, Representative Buchanan could not 

explain the unusual pattern of reimbursed contributions from multiple corporate entities with which he was affiliated, beyond stating 

that such violations are bound to occur, and that perhaps his colleagues became ‘‘overzealous’’’ in their desire to assist his campaign. The Committee does not believe such violations are bound 

to occur in every campaign, and like Representative Buchanan, is 

unable to explain how multiple corporate entities came to participate in similar but separate conduit contributions schemes benefitting Representative Buchanan’s campaign. Had Representative 

Buchanan or his campaign been more proactive in explaining the 

law to colleagues at the time they were soliciting donations—particularly after they first became aware there were concerns about 

compliance with respect to contributions associated with a company 

associated with Representative Buchanan—perhaps the subsequent 

similar issues could have been avoided. Similarly, issues with respect to the draft affidavit might have been avoided had Representative Buchanan read the affidavit. The Committee cautions RepVerDate Sep 11 2014 07:07 Jun 28, 2016 Jkt 059006 PO 00000 Frm 00030 Fmt 6659 Sfmt 6602 E:\HR\OC\HR643.XXX HR643

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resentative Buchanan to exercise more diligence over affairs related to his campaign. 

VI. CONCLUSION 

VBFC accepted campaign donations from individuals who were 

subsequently reimbursed through the corporate funds of companies 

affiliated with Representative Buchanan. The FEC investigated 

those donations and failed to find sufficient evidence that Representative Buchanan directed or knew of any unlawful reimbursements. DOJ also reviewed allegations against Representative 

Buchanan and similarly closed its investigation. A Florida state 

court hearing a private dispute between Mr. Kazran and Representative Buchanan, including claims that the draft affidavit was 

an abuse of the civil process, held against Mr. Kazran and for Representative Buchanan. OCE’s Referral recommended further review 

regarding the wording of a single paragraph in a draft affidavit 

Representative Buchanan’s attorney’s proposed to Mr. Kazran, for 

use in the FEC investigation. The Committee has independently reviewed the evidence in this case and reached a conclusion in accord 

with the FEC, DOJ, and the state trial court. The Committee concluded that the existing evidence is insufficient to sustain any of 

the aforementioned allegations or to warrant any action against 

Representative Buchanan. However, the Committee noted that 

Representative Buchanan admitted that he had relatively limited 

knowledge or involvement with certain facets of his campaign. 

Because the evidence is insufficient to conclude that Representative Buchanan himself was aware of the unlawful reimbursements 

at the time they occurred, or had any role in directing or approving 

of them, and the evidence is insufficient to find that Representative 

Buchanan attempted to improperly influence the testimony of Mr. 

Kazran before the FEC, the Committee has determined to take no 

further action in this matter, and upon publication of this Report, 

considers the matter closed. 

VII. STATEMENT UNDER HOUSE RULE XIII, CLAUSE 3(c) 

The Committee made no special oversight findings in this Report. 

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

measure in this Report. 


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emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 110 here HR643.079
105 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 111 here HR643.080
106 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 112 here HR643.081
107 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 113 here HR643.082
108 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 114 here HR643.083
109 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 115 here HR643.084
110 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 116 here HR643.085
111 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 117 here HR643.086
112 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 118 here HR643.087
113 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 119 here HR643.088
114 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 120 here HR643.089
115 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 121 here HR643.090
116 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 122 here HR643.091
117 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 123 here HR643.092
118 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 124 here HR643.093
119 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 125 here HR643.094
120 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 126 here HR643.095
121 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 127 here HR643.096
122 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 128 here HR643.097
123 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 129 here HR643.098
124 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 130 here HR643.099
125 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 131 here HR643.100
126 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 132 here HR643.101
127 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 133 here HR643.102
128 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 134 here HR643.103
129 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 135 here HR643.104
130 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 136 here HR643.105
131 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 137 here HR643.106
132 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 138 here HR643.107
133 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 139 here HR643.108
134 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 140 here HR643.109
135 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 141 here HR643.110
136 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 142 here HR643.111
137 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 143 here HR643.112
138 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 144 here HR643.113
139 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 145 here HR643.114
140 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 146 here HR643.115
141 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 147 here HR643.116
142 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 148 here HR643.117
143 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 149 here HR643.118
144 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 150 here HR643.119
145 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 151 here HR643.120
146 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 152 here HR643.121
147 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 153 here HR643.122
148 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 154 here HR643.123
149 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 155 here HR643.124
150 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 156 here HR643.125
151 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 157 here HR643.126
152 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 158 here HR643.127
153 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 159 here HR643.128
154 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 160 here HR643.129
155 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 161 here HR643.130
156 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 162 here HR643.131
157 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 163 here HR643.132
158 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 164 here HR643.133
159 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 165 here HR643.134
160 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 166 here HR643.135
161 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 167 here HR643.136
162 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 168 here HR643.137
163 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 169 here HR643.138
164 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 170 here HR643.139
165 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 171 here HR643.140
166 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 172 here HR643.141
167 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 173 here HR643.142
168 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 174 here HR643.143
169 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 175 here HR643.144
170 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 176 here HR643.145
171 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 177 here HR643.146
172 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 178 here HR643.147
173 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 179 here HR643.148
174 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 180 here HR643.149
175 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 181 here HR643.150
176 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 182 here HR643.151
177 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 183 here HR643.152
178 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 184 here HR643.153
179 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 185 here HR643.154
180 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 186 here HR643.155
181 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 187 here HR643.156
182 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 188 here HR643.157
183 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 189 here HR643.158
184 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 190 here HR643.159
185 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 191 here HR643.160
186 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 192 here HR643.161
187 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 193 here HR643.162
188 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 194 here HR643.163
189 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 195 here HR643.164
190 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 196 here HR643.165
191 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 197 here HR643.166
192 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 198 here HR643.167
193 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 199 here HR643.168
194 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 200 here HR643.169
195 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 201 here HR643.170
196 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 202 here HR643.171
197 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 203 here HR643.172
198 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 204 here HR643.173
199 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 205 here HR643.174
200 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 206 here HR643.175
201 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 207 here HR643.176
202 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 208 here HR643.177
203 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 209 here HR643.178
204 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 210 here HR643.179
205 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 211 here HR643.180
206 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 212 here HR643.181
207 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 213 here HR643.182
208 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 214 here HR643.183
209 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 215 here HR643.184
210 


emcdonald on DSK9F6TC42PROD with HEARINGInsert offset folio 216 here HR643.185