" ! HOUSE OF REPRESENTATIVES 

111TH CONGRESS

1st Session 

REPORT

111–320 

House Calendar No. 126 

IN THE MATTER OF 

REPRESENTATIVE SAM GRAVES 

R E P O R T 

OF THE

COMMITTEE ON STANDARDS OF 

OFFICIAL CONDUCT 

OCTOBER 29, 2009.—Referred to the House Calendar and ordered to be 

printed 


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IN THE MATTER OF REPRESENTATIVE SAM GRAVES 


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U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON : 

1 

53–070 

" ! HOUSE OF REPRESENTATIVES 

111TH CONGRESS

1st Session 

REPORT

2009

111–320 

House Calendar No. 126 

IN THE MATTER OF 

REPRESENTATIVE SAM GRAVES 

R E P O R T 

OF THE

COMMITTEE ON STANDARDS OF 

OFFICIAL CONDUCT 

OCTOBER 29, 2009.—Referred to the House Calendar and ordered to be 

printed 


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(II) 

COMMITTEE ON STANDARDS OF OFFICIAL CONDUCT 

ZOE LOFGREN, California 

Chair 

BEN CHANDLER, Kentucky 

G.K. BUTTERFIELD, North Carolina 

KATHY CASTOR, Florida 

PETER WELCH, Vermont 

JO BONNER, Alabama 

Ranking Republican Member 

MIKE CONAWAY, Texas 

CHARLES DENT, Pennsylvania 

GREGG HARPER, Mississippi 

MICHAEL MCCAUL, Texas 

REPORT STAFF 

R. BLAKE CHISAM, Chief Counsel/Staff Director 

C. MORGAN KIM, Deputy Chief Counsel 

DAN TAYLOR, Counsel to the Chair 

TODD UNGERECHT, Counsel to the Ranking Republican Member 

TOM RUST, Counsel 

SHERIA CLARKE, Counsel 

FRANK DAVIES, Senior Investigator 


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(III)

LETTER OF TRANSMITTAL 

HOUSE OF REPRESENTATIVES, 

COMMITTEE ON STANDARDS OF OFFICIAL CONDUCT, 

Washington, DC, October 29, 2009. 

Hon. LORRAINE C. MILLER, 

Clerk, House of Representatives, 

Washington, DC. 

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

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

the attached Report, ‘‘In the Matter of Representative Sam 

Graves.’’ 

Sincerely, 

ZOE LOFGREN, 

Chair. 

JO BONNER, 

Ranking Republican Member. 


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(V)

EXECUTIVE SUMMARY 

After a three-month review, the Committee on Standards of Official Conduct (Standards Committee) has concluded that Representative Sam Graves did not violate any U.S. House of Representatives rule or standard of conduct for his role in inviting a witness, 

Brooks Hurst, to testify before the Committee on Small Business 

on March 4, 2009. 

The Standards Committee considers the matter against Representative Graves closed, and no further inquiry is warranted. The 

question of whether Representative Graves violated any House rule 

or standard of conduct was referred to the Standards Committee by 

the Office of Congressional Ethics (OCE) on August 6, 2009. 

At issue was a financial connection between Mr. Hurst, who is 

a friend of Representative Graves, and Representative Graves’ wife. 

Both are investors in two renewable fuel cooperatives, Golden Triangle Energy Cooperative (Golden Triangle) and Biofuels LLC 

(Biofuels). Representative Graves approved of Mr. Hurst as a witness. At the hearing, Mr. Hurst, representing the Missouri Soybean 

Association, advocated on behalf of the members of the association, 

and not for either of the entities in which Representative Graves’ 

wife owns an interest. 

OCE’s report and findings did not assert that Representative 

Graves violated any House rule or standard of conduct, but suggested that his actions created an ‘‘appearance of a conflict of interest.’’ 

The Standards Committee found that no relevant House rule or 

other standard of conduct prohibits the creation of an appearance 

of a conflict of interest when selecting witnesses for a committee 

hearing. In addition, neither the Standards Committee nor OCE 

identified any evidence that the March 4, 2009, hearing or Mr. 

Hurst’s testimony resulted in any action that could benefit Representative Graves, Mrs. Graves, or Mr. Hurst. 

But the appearance question highlights the importance of financial disclosure statements. Representative Graves’ financial disclosure statements fully and accurately reflect his financial interests, 

including his wife’s 0.18% interest in Golden Triangle and 0.125% 

interest in Biofuels. Separately, Mr. Hurst fully complied with all 

disclosure requirements for witnesses. The Standards Committee 

learned that Mr. Hurst had a 0.5% interest in Golden Triangle and 

a 0.33% in Biofuels. 

Members are required to disclose assets on the principle that 

conflicts of interest are best resolved by the political process. Timely filing of accurate financial disclosure statements is fundamental 

to the House ethics system. Any financial connection between Representative Graves and Mr. Hurst appears tenuous, but in this 

case, the public has the information to make such judgments. 


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VI

The process for inviting Mr. Hurst to testify—and the criteria 

used to select him as a witness—followed normal procedure of the 

Committee on Small Business. 

Representative Graves was appointed the ranking member of the 

Committee on Small Business at the beginning of the 111th Congress. The Committee on Small Business’s majority staff notified 

the minority staff, approximately one week before the hearing, that 

the committee would hold a hearing on March 4, 2009. 

The hearing involved no legislation that would ultimately come 

to the House floor, and was held solely as a fact-gathering hearing 

about the impact of the current economic crisis on the renewable 

fuels industry. The minority staff established reasonable and objective criteria for choosing a potential witness, that he or she should 

be: (1) from Representative Graves’ congressional district; (2) familiar with the renewable fuels industry; and (3) not employed by a 

company in which Representative Graves or his wife was invested. 

The decision regarding inviting witnesses was largely staff-driven. During the minority staffs deliberations, Paul Sass, Representative Graves’ then-deputy chief of staff, sent an email to Representative Graves seeking input as to possible witnesses, and suggested 

Brooks Hurst among several possibilities. Representative Graves 

approved of Mr. Hurst as a possible witness. Mr. Hurst met each 

of the requirements for a witness. Although he held investments in 

the two cooperatives in which Representative Graves’ wife was invested, he was not employed by either company. 

After further deliberations, the staff selected Mr. Hurst to testify 

at the hearing, and Mr. Hurst was one of five witnesses. The other 

four witnesses were selected by the majority on the Committee on 

Small Business. The Missouri Soybean Association prepared Mr. 

Hurst’s written testimony and provided him with talking points for 

his oral testimony. 

The Graves investigation is one of the first matters to be referred 

by OCE and resolved by the Standards Committee. The Standards 

Committee regrets that it finds deficiencies in OCE’s handling of 

this case, including procedural problems that are outlined in detail 

in this report. 

OCE’s assertion that ‘‘there is substantial reason to believe that 

an appearance of conflict of interest was created’’ by Representative 

Graves was not supported by the facts in this case or the law. 

The Standards Committee reviewed Representative Graves’ conduct under the House rules and standards identified by OCE and 

other House rules and standards of conduct. OCE reviewed Representative Graves’ conduct pursuant to House Rule 3, clause 1, 

House Rule 23, clause 2, and what it identified as ‘‘House precedent regarding conflict of interest.’’ 

Based on the facts presented in OCE’s report and findings, as 

well as the facts gathered by the Standards Committee’s independent investigation, the Standards Committee concluded that 

none of the House rules or standards of conduct identified by OCE 

applied to Representative Graves’ conduct. 

The Standards Committee determined that Representative 

Graves’ conduct should more appropriately be analyzed under 

House Rule 23, clause 3, and Section 5 of the Code of Ethics for 

Government Service. Under those provisions, the Standards ComVerDate Nov 24 2008 06:31 Nov 04, 2009 Jkt 053070 PO 00000 Frm 00008 Fmt 7633 Sfmt 7633 E:\HR\OC\HR320.XXX HR320

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VII

mittee concluded that Representative Graves’ involvement with the 

witness selection process for the March 4 hearing did not violate 

any applicable House rule or standard of conduct. The Standards 

Committee also concluded that Mr. Hurst met all of the reasonable 

and objective requirements the Committee on Small Business minority staff established for a witness. 

Moreover, given Mr. Hurst’s qualifications, the Standards Committee further concluded that even if Representative Graves had 

greater involvement in the selection process than he did have, he 

still would not have violated any applicable House rule or standard 

of conduct. 


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(IX)

OVERVIEW 

This Report addresses the findings and conclusions of the Standards Committee with regard to the conduct of Representative 

Graves and OCE’s review in this matter. 

Part I briefly summarizes the Standards Committee’s findings 

and conclusions in this matter. 

Part II (summarized in Subpart A) contains the Standards Committee’s factual findings, including a discussion of the Committee 

on Small Business’s jurisdiction (Subpart B), the process by which 

Mr. Hurst was selected as a witness for the Committee on Small 

Business hearing (Subparts C, D, and E), the financial interest putatively shared by Mr. Hurst and Representative Graves (Subpart 

F), and the substance and results of Mr. Hurst’s testimony before 

the Committee on Small Business (Subparts G and H). 

Part III contains the Standards Committee’s statement of jurisdiction in this matter. 

Part IV contains the Standards Committee’s legal analysis with 

regard to Representative Graves’ conduct. The Standards Committee analyzed Representative Graves’ conduct under the House 

rules and standards identified by OCE (Subpart A) and under additional House rules and standards identified by the Standards Committee (Subpart B). 

Part V contains the Standards Committee’s conclusions and recommendation with respect to the conduct of Representative Graves. 

Part VI (summarized in Subpart A) addresses OCE’s review, as 

well as the Standards Committee’s investigation in this matter. 

Part VI summarizes pertinent sections of OCE’s authorizing resolution and rules (Subpart B), and discusses the procedural history of 

OCE’s review (Subpart C) and the nature of OCE’s Report and 

Findings (Subpart D). In addition, Part VI summarizes both the 

Standards Committee’s investigation in this matter (Subpart E.1) 

and a response to OCE’s Report and Findings that Representative 

Graves submitted to the Standards Committee (Subpart E.2). Finally, Part VI provides the Standards Committee’s findings with 

regard to certain regrettable deficiencies in OCE’s review (Subpart 

F). 

Part VII of this Report contains the Standards Committee’s 

statement under House Rule 13, clause 3(c). 


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(XI) 

C O N T E N T S 

Page 

I. Introduction .................................................................................................... 1 

II. Factual Findings ............................................................................................ 1 

A. Summary of Factual Findings ............................................................. 1 

B. The Jurisdiction of the Small Business Committee ........................... 3 

C. Notification of the March 4, 2009, Small Business Committee 

Hearing ................................................................................................... 3 

D. Criteria for Selecting a Witness for the March 4, 2009, Small 

Business Committee Hearing ............................................................... 4 

E. Selection of Mr. Hurst for the March 4, 2009, Small Business 

Committee Hearing ............................................................................... 5 

F. Financial Interest Putatively Shared by Brooks Hurst and Representative Graves ................................................................................. 9 

G. Brooks Hurst and the March 4, 2009, Small Business Committee 

Hearing ................................................................................................... 10 

H. Actions Taken Following the Small Business Committee Hearing . 11 

III. Jurisdiction of the Standards Committee .................................................... 12 

IV. Legal Analysis ................................................................................................ 13 

A. Analysis Based on Rules Identified by OCE ...................................... 13 

B. Analysis Based on Relevant Rules and Statutes ............................... 18 

V. Conclusions and Recommendations .............................................................. 20 

VI. OCE’s Review ................................................................................................. 21 

A. Summary of OCE’s Review .................................................................. 21 

B. OCE’s Authorizing Resolution and Rules ........................................... 23 

C. Procedural History of OCE’s Review .................................................. 25 

D. OCE’s Report and Findings ................................................................. 26 

E. The Standards Committee’s Investigation ......................................... 28 

F. Findings and Conclusions Regarding Deficiencies in OCE’s Review ......................................................................................................... 31 

VII. Statement Under Rule 13, Clause 3(c) of the Rules of the House of 

Representatives .......................................................................................... 37 


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I. INTRODUCTION 

Following a unanimous vote, the Committee on Standards of Official Conduct (Standards Committee) submits this Report pursuant to House Rule 11, clause 3(a)(2), which authorizes the Standards Committee to investigate any alleged violation by a Member, 

officer, or employee of the House of Representatives, of the Code of 

Official Conduct or of any law, rule, regulation, or other standard 

of conduct applicable to the conduct of such Member, officer, or employee; and pursuant to House Rule 11, clause 3(b)(8)(A), which authorizes the Standards Committee to report on matters referred to 

the Standards Committee by the Office of Congressional Ethics 

(OCE). 

On August 6, 2009, OCE forwarded to the Standards Committee 

a report and findings (Report and Findings) recommending further 

review of allegations involving Representative Sam Graves. OCE’s 

Report and Findings asserted that ‘‘there is substantial reason to 

believe that an appearance of conflict of interest was created’’ when 

Representative Graves invited a friend, Brooks Hurst, who held investments in the same renewable fuel cooperatives as Representative Graves’ wife, to testify before a hearing of the House of Representatives Committee on Small Business (Small Business Committee) on issues facing the renewable fuels industry. OCE’s Report 

and Findings did not assert that Representative Graves violated 

any current rule or standard of conduct. 

No relevant House Rule or other standard of conduct prohibits 

creation of an appearance of conflict of interest when selecting witnesses for a committee hearing. Thus, OCE did not find that Representative Graves violated any current House Rule or other standard of conduct. 

The Standards Committee’s independent investigation also failed 

to conclude that Representative Graves violated any current House 

Rule or other standard of conduct. For this reason, the Standards 

Committee decided and reports that no further action should be 

taken with regard to OCE’s review of Representative Graves’ alleged conduct, and the Standards Committee considers the matter 

closed and no further inquiry is warranted. 

The Standards Committee’s findings and conclusions are set 

forth in this Report. 

II. FACTUAL FINDINGS 

A. Summary of Factual Findings 

Representative Graves was appointed the Ranking Member of 

the Small Business Committee at the beginning of the 111th Congress. Approximately one week in advance, the Small Business 

Committee’s majority staff notified the minority staff that the committee would hold a hearing on March 4, 2009, regarding the renewable fuels industry, and that the minority staff would be perVerDate Nov 24 2008 06:31 Nov 04, 2009 Jkt 053070 PO 00000 Frm 00015 Fmt 6659 Sfmt 6602 E:\HR\OC\HR320.XXX HR320

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1 COS 00065. The documents designated with ‘‘COS’’ numbers constitute the documents collected by the Standards Committee in the course of its investigation. Pertinent portions of the 

documents collected by the Standards Committee can be found at Appendix A. The Standards 

Committee notes that certain personal information, such as personal email addresses, direct-dial 

phone numbers, individual’s signatures, and personal cell phone numbers have been redacted 

from the documents collected by the Standards Committee. The Standards Committee has redacted this information based on privacy considerations, and because the information is irrelevant to any question at issue in this Report. 2 Id. 3 COS 00065; COS 00067; COS 00069; COS 00071; COS 00073; COS 00082; COS 00084; 

Memorandum of Interview of Paul Sass by OCE staff, June 16, 2009, ¶¶ 4, 11; Interview of Paul 

Sass by Standards Committee staff, September 16, 2009. Pertinent portions of the OCE’s memoranda of interview can be found at Appendix D. 4 Id. 5Memorandum of Interview of Rep. Graves by OCE staff, June 15, 2009, ¶ 3, 4; Memorandum 

of Interview of Paul Sass by OCE staff, June 16, 2009, ¶ 57. 6 Interview of Paul Sass by Standards Committee staff, September 16, 2009; Memorandum of 

Interview of Thomas Brown by OCE staff, June 16, 2009, ¶ 12; Memorandum of Interview of 

Paul Sass by OCE staff, June 16, 2009, ¶ 16. 7 COS 00072 

8 COS 00065; COS 00067; COS 00069; COS 00071; COS 00073; COS 00082; COS 00084; 

Memorandum of Interview of Paul Sass by OCE staff, June 16, 2009, ¶¶ 4, 11; Interview of Paul 

Sass by Standards Committee staff, September 16, 2009; Interview of Brooks Hurst by Standards Committee staff, September 18, 2009; Memorandum of Interview of Rep. Graves by OCE 

staff, June 16, 2009, ¶ 13; Memorandum of Interview of Brooks Hurst by OCE staff, July 13, 

2009, ¶ 9. 9Memorandum of Interview of Rep. Graves by OCE staff, June 15, 2009, ¶ 5; Interview of 

Paul Sass by Standards Committee staff, September 16, 2009. 10 COS 00123. The other four witnesses were selected by the majority staff and testified on 

behalf of the majority. 11 COS 00192–COS 195. 

mitted to invite one witness to testify at the hearing.1 The hearing 

involved no legislation that would ultimately come to the House 

floor for Representative Graves and other Members upon which to 

vote, and was held solely as a fact-gathering hearing about the impact of the current economic crisis on the renewable fuels industry.2 Prior to selecting a witness for the hearing, the minority staff 

established criteria for a potential witness.3 The criteria that the 

staff established sought a witness who was: from Representative 

Graves’ congressional district; familiar with the renewable fuels industry; and not employed by a company in which Representative 

Graves or his wife had invested financially.4

As was the normal procedure for the Small Business Committee, 

Representative Graves had limited involvement in selecting a witness for the hearing.5 The final decision as to which individual was 

invited was left up to and actually was made by the minority staff.6

However, during the staff’s deliberations, Paul Sass, Representative Graves’ then-Deputy Chief of Staff, sent an email to Representative Graves seeking his input as to possible witnesses once 

the field had been narrowed by the minority staff to a few candidates by staff.7 In his email, Mr. Sass suggested several possible 

witnesses to Representative Graves, including Brooks Hurst. Mr. 

Hurst met each of the previously identified requirements for a witness.8 Although Mr. Hurst had investments in two renewable energy cooperatives in which Representative Graves’ wife was invested, he was not employed by either company. 

After their deliberations, the staff selected Mr. Hurst to testify 

at the hearing.9 Mr. Hurst testified on behalf of the Missouri Soybean Association (MSA) and was one of five witnesses at the March 

4, 2009, hearing.10 The MSA prepared Mr. Hurst’s written testimony and provided him with talking points for his oral testimony. 

Mr. Hurst’s written and oral testimony advocated on behalf of the 

members of the MSA generally, and not for any specific business.11


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12 House Rule X, clause 1(p). 13 COS 00151–COS 00156. 14 House Rule X, clause 2(b). 15 House Rule X, clause 3(l). 16 COS 00065. 17 COS 00019. 

The purpose of the March 4, 2009, hearing was informational in 

nature, and was not directed at the passage of any specific legislation. Neither the Standards Committee nor OCE identified any evidence that the March 4, 2009, hearing resulted in specific action 

benefitting Representative Graves, Mrs. Graves, Mr. Hurst, or any 

other person or entity. 

B. The Jurisdiction of the Small Business Committee 

The Small Business Committee’s legislative jurisdiction includes: 

(1) Assistance to and protection of small business, including 

financial aid, regulatory flexibility, and paperwork reduction; 

and 

(2) Participation of small-business enterprises in Federal 

procurement and Government contracts.12

Through its referrals of legislation to the Small Business Committee, the Office of the Parliamentarian has interpreted the Small 

Business Committee’s jurisdiction to include the Small Business 

Act, 15 U.S.C. §§ 631–57f; the Small Business Investment Act, 15 

U.S.C. §§ 661–97g; Pub. L. No. 94–305 (the statute that created the 

Office of Chief Counsel for Advocacy at the United States Small 

Business Administration); the Regulatory Flexibility Act, 5 U.S.C. 

601–12; and the Paperwork Reduction Act, 44 U.S.C. §§ 3501–49.13

The Small Business Committee, as a standing House committee, 

has general oversight responsibility to determine whether the laws 

and programs within its jurisdiction ‘‘are being implemented and 

carried out in accordance with the intent of Congress and whether 

they should be continued, curtailed, or eliminated[.]’’ 14 In addition, 

the Small Business Committee has a special oversight function to 

‘‘study and investigate on a continuing basis the problems of all 

types of small business.’’ 15

C. Notification of the March 4, 2009, Small Business Committee 

Hearing 

Representative Graves became a Member of the Small Business 

Committee at the beginning of the 107th Congress. At the beginning of the 111th Congress, he was named Ranking Member of the 

Small Business Committee. On February 24, 2009, the Small Business Committee’s majority staff informally notified the committee’s 

minority staff that the full committee would hold a hearing regarding alternative fuels on March 4, 2009.16 On February 25, 2009, 

the Small Business Committee officially announced that the title of 

the March 4, 2009, hearing would be ‘‘The State of the Renewable 

Fuels Industry in the Current Economy.’’ 17

The Small Business Committee’s rules state: 

Whenever any hearing is conducted by the committee or 

any subcommittee upon any measure or matter, the minority party members on the committee shall be entitled, 

upon request to the Chairwoman by a majority of those 


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18Small Business Committee Rules and Procedures, Rule 6(B). 19 COS 00065. Pursuant to the Small Business Committee’s rules, the majority staff on the 

Small Business Committee is required to announce hearing topics at least one week in advance. 

Small Business Committee Rules and Procedures, Rule 4. Mr. Sass told the Standards Committee that on some occasions the majority staff notified the minority staff as much as two 

weeks in advance of a hearing. Interview of Paul Sass by Standards Committee staff, September 

16, 2009. 20 COS 00065. 21 COS 00071. 22 COS 00084. 23 Representative Graves represents the Sixth Congressional District of Missouri. 

minority members, to call a witness or witnesses selected 

by the minority to testify with respect to that measure or 

matter. The minority shall be entitled to a ratio of onethird of the witnesses testifying.18

Upon receiving the February 24, 2009, hearing notification, a 

member of the minority staff of the Small Business Committee sent 

an email to Mr. Sass. That email contained the following text: 

‘‘Chances that we’ll find someone and be able to get them here by 

next week is slim, but thought I’d ask. The majority needs to do 

a better job on letting us know what the schedule is.’’ 19

D. Criteria for Selecting a Witness for the March 4, 2009, Small 

Business Committee Hearing 

After receiving the February 24, 2009, notification, Representative Graves’ staff and the minority staff for the Small Business 

Committee exchanged emails regarding possible witnesses to invite 

to testify at the hearing. On February 24, 2009, a member of the 

minority staff on the Small Business Committee sent an email at 

1:47 p.m. to Mr. Sass. That email contained the following text: 

The majority just let us know (about 15 minutes ago) 

that next week there will be a hearing on renewable fuels. 

I know nothing other than that. I have made the calls to 

the majority to find out. Don’t know what the angle is, but 

is there anybody back in the district who has come to the 

office to talk alternative fuels that might be a good witness? 20

Both in discussions and in emails, the staff developed a series of 

criteria for potential witnesses. One such criterion was that the 

witness should have knowledge of the issues facing the renewable 

energy industry. On February 24, 2009, Mr. Sass sent an email at 

1:53 p.m. to several staff members. That email contained the following text: ‘‘Please see the email below and let me know if you 

have any suggestions on who can testify next week on renewable 

energy.’’ 21 The next day, a staff member sent an email at 10:50 

a.m. in response to Mr. Sass’ inquiries. That email contained the 

following text: ‘‘Also might be good to get an actual grain farmer 

to come in if it fits.’’ 22

Another staff criterion for a potential witness was that the witness should be from the congressional district represented by Representative Graves.23 A member of the minority staff on the Small 

Business Committee sent an email on February 24, 2009, at 1:56 

p.m. to Mr. Sass. That email contained the following text: ‘‘I don’t 

want to pass this along to you but with no notice at all, it makes 

it tough for me to go through channels here in DC to find someone 


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24 COS 00082. 25 COS 00073. 26Memorandum of Interview of Paul Sass by OCE staff, June 16, 2009, ¶ 4. 27 Interview of Paul Sass by Standards Committee staff, September 16, 2009. 28 Id. 29 Id. 30 Id. 31 COS 00069 and COS 00073. 32 COS 00067. 33Memorandum of Interview of Paul Sass by OCE staff, June 16, 2009, ¶ 11. 34 Interview of Paul Sass by Standards Committee staff, September 16, 2009. 35 Id. 

from MO–6.’’ 24 Mr. Sass sent an email to two members of the minority staff on the Small Business Committee on February 24, 

2009, at 4:05 p.m. That email contained the following text: ‘‘We 

should not have any problem finding a person from the 6th to testify at this hearing, We have extensive Ag contacts in the district.’’ 25

According to OCE’s interview memorandum, Mr. Sass told OCE 

that ‘‘[h]is boss was new to the Ranking Member position and 

wanted the witness to come from the 6th district and to be competent.’’ The interview memorandum further states that Mr. Sass 

‘‘started looking for witnesses from the district and then branched 

out from there to other parts of the state.’’ 26

Mr. Sass told the Standards Committee that the process for selecting a witness for Small Business Committee hearings had 

evolved over time.27 He stated that the staff usually started their 

search for a witness by looking for witnesses within the Sixth District of Missouri.28 He further stated that, depending on the topic, 

the staff sometimes looked for witnesses from the districts of other 

minority Members on the Small Business Committee.29 He explained that because the March 4, 2009, hearing dealt with agriculture and renewable fuels, he believed that the staff would have 

no difficulty finding a witness from the Sixth District of Missouri.30

A third staff criterion for a potential witness was that the witness should not be an officer or employee of a renewable energy 

company in which Representative Graves had a direct financial interest.31 Representative Graves’ Communications Director sent an 

email to Mr. Sass on February 24, 2009, at 2:56 p.m. That email 

contained the following text: ‘‘Lets [sic] make sure that we do not 

get a renewable company that [Representative Graves] or his wife 

is invested in.’’ 32 Mr. Sass told OCE that, ‘‘he did not want a witness from any companies that Representative Graves was invested 

in—someone with their name on a business card.’’ 33 Mr. Sass explained to the Standards Committee that the staff was concerned 

with selecting a witness, such as a president or CEO, who was actually employed by a company in which Representative Graves or 

his wife was invested.34 Mr. Sass also told the Standards Committee that the staff usually looked for a witness that was involved 

with an association of some kind, because the association would 

usually pay for the trip to Washington, D.C.35

E. Selection of Mr. Hurst for the March 4, 2009, Small Business 

Committee Hearing 

1. The Staff Considered Several Potential Witnesses 

The Small Business Committee staff and Representative Graves’ 

personal staff considered a number of potential witnesses based on 


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36 COS 00084. 37 COS 00066. 38 COS 00071. 39 COS 00088. 40See Memorandum of Interview of Paul Sass by OCE staff, June 16, 2009, ¶ 15. (‘‘He threw 

out the idea of inviting Steve Flick because he wasn’t from the 6th district. He did not believe 

that he worked for any of the companies but he resided outside the district.’’); see also COS 

00069 (noting that Show Me Energy is ‘‘just south of the district’’). 41 COS 00072. Mr. Sass told the Standards Committee that sometimes, including in this case, 

when he referred to Representative Graves as taking some action he meant Representative 

Graves’ office took the action, and not necessarily Representative Graves personally. Interview 

of Paul Sass by Standards Committee staff, September 16, 2009. 42Memorandum of Interview of Rep. Graves by OCE staff, June 15, 2009, ¶ 113. 43 Id., at ¶ 4. 

the criteria they developed. On February 25, 2009, at 10:50 a.m., 

a member of Representative Graves’ personal staff sent an email 

to Mr. Sass, suggesting possible witnesses. That email contained 

the following text: ‘‘Anyone at Golden Triangle in Craig. Bill Becker 

at Lifeline would be good.’’ 36 The staff also considered Steve Flick, 

President of the Board of Show Me Energy, a biomass cooperative 

located in Centerview, Missouri.37 One member of the staff sent an 

email to Mr. Sass on February 24, 2009, at 4:36 p.m., stating: 

‘‘Only folks that come to mind are the heads of the soybean and 

ethanol groups . . . Dale Ludwig, etc.’’ 38 Another member of the 

staff wrote an email to Mr. Sass on February 25, 2009, at 10:04 

a.m., noting that members of the Missouri Corn Growers Association would be in Washington, D.C., during the week of the hearing.39

The staff excluded certain of the potential witnesses for failure 

to meet one or more of the criteria they had established. For example, the staff dismissed one potential witness because he was not 

from Representative Graves’ congressional district.40

2. The Staff Solicited Suggestions From Representative Graves 

In addition to their own deliberations, the staff also asked Representative Graves if he had suggestions as to possible witnesses; 

however, the evidence indicates that, consistent with the standard 

practice for the minority on the Small Business Committee, Representative Graves had limited involvement in the selection of a 

witness to testify at the March 4, 2009, hearing. On February 24, 

2009, at 4:44 p.m., Mr. Sass sent an email to Representative 

Graves. That email contained the following text: 

The Small Business Committee is doing a hearing on renewable fuels next week. Do you have anybody off the top 

of your head who we should invite? Last time we had a 

hearing on the topic you invited Brooks and Charlie Hurst. 

Any one you want me to call? Steve Flick? 41

This message appears to be the first written communication to 

Representative Graves regarding the hearing. Notably the staff solicited suggestions from Representative Graves after they developed their criteria for selecting a witness. 

Representative Graves told OCE that ‘‘[h]e was not aware of the 

process for finding witnesses for hearings, staff handles finding 

witnesses.’’ 42 The interview memorandum further states ‘‘Many 

times, [Representative Graves] does not know who the witness will 

be until the hearing.’’ 43 Mr. Sass told OCE that ‘‘Representative 


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44Memorandum of Interview of Paul Sass by OCE staff, June 16, 2009, ¶ 57. 45 Interview of Paul Sass by Standards Committee staff, September 16, 2009. The Standards 

Committee notes that Representative Graves told OCE that in response to a request for a recommendation, he ‘‘threw out Brooks Hurst’s name for consideration.’’ Memorandum of Interview 

of Rep. Graves by OCE staff, June 15, 2009, ¶ 6. However, Representative Graves’ recollection 

is not supported by any other witness testimony, nor by the documentary record. See e.g., COS 

00072; Interview of Paul Sass by Standards Committee staff, September 16, 2009. 46 COS 00192–COS 195. 47 Id. 48 Interview of Brooks Hurst by Standards Committee staff, September 18, 2009. 49 Id. 50 Id. 51 Id. 52 Id. 53Memorandum of Interview of Rep. Graves by OCE staff, June 16, 2009, ¶ 13. 54Memorandum of Interview of Brooks Hurst by OCE staf, July 13, 2009, ¶ 9. 55 Interview of Brooks Hurst by Standards Committee staff, September 18, 2009. The Standards Committee was able to confirm independently that, in addition to his testimony during the 

hearing at issue, Mr. Hurst testified at a hearing before the Small Business Committee on 

March 15, 2000, entitled ‘‘Helping Agricultural Producers ‘Re-Grow’ Rural America: Providing 

the Tools’’ and a February 23, 2004, hearing before the Small Business Subcommittee on Rural 

Enterprises, Agriculture, and Technology, entitled ‘‘The Endangered Species Act’s Impact on 

Small Businesses and Farmers, Field Hearing, St. Joseph, MO.’’ 56 Id. 

Graves doesn’t get involved in the weeds, everything is staff driven. 

Decisions can be made better that way.’’ 44

One of the potential witnesses discussed by Representative 

Graves and Mr. Sass was Mr. Hurst.45 Mr. Hurst is a farmer who 

resides in Representative Graves’ congressional district 46 and who 

is a member of the Board of Directors of a majority-farmer-owned 

biodiesel production facility located in Missouri.47 Mr. Hurst is currently on the board of Paseo-Cargill.48 Mr. Hurst told the Standards Committee that he was previously involved in various agricultural cooperatives, and that he had served on the boards of several 

cooperatives.49

Mr. Hurst currently serves on the Board of the MSA and was 

President of the MSA for three terms from 2000 through 2002.50

Mr. Hurst told the Standards Committee that while he was President of the MSA, he spoke several times a year to different groups 

regarding renewable fuel issues and that he was interviewed on 

various agriculture radio programs at least once a month.51 He further stated that since 2002, he has spoken to various groups on renewable fuel issues approximately once every two years.52 Representative Graves told OCE that Mr. Hurst ‘‘is the President of 

the Missouri Soybean Association, he is involved with the corn 

growers, and he testifies throughout the country on renewable 

fuels.’’ 53

Mr. Hurst has previously testified at Congressional hearings on 

issues related to renewable fuels. Mr. Hurst told OCE that: 

[h]e had been invited to testify before the Committee on 

Small Business on two previous occasions. He recalled 

being invited for the first time by then-Representative Jim 

Talent. He could recall that it was Representative Talent 

because it was his first time testifying before Congress.54

Mr. Hurst told the Standards Committee that he recalled being invited to testify at Congressional hearings on at least four occasions.55 Each time he was invited to testify on behalf of the MSA.56

In addition to being invited to testify before the Small Business 

Committee twice by Representative Graves and once by formerVerDate Nov 24 2008 06:31 Nov 04, 2009 Jkt 053070 PO 00000 Frm 00021 Fmt 6659 Sfmt 6602 E:\HR\OC\HR320.XXX HR320

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57 Representative Talent served as a Member of Congress from Missouri’s Second Congressional District from 1993 to 2000. 58 Id. Representative Hulshof served as a Member of Congress from Missouri’s Ninth Congressional District from 1997 to 2009. 59Memorandum of Interview of Brooks Hurst by OCE staff, July 13, 2009, ¶ 5. 60Memorandum of Interview of Rep. Graves by OCE staff, June 15, 2009, ¶ 2. 61 Interview of Paul Sass by Standards Committee staff, September 16, 2009. 62 Id. 63Memorandum of Interview of Rep. Graves by OCE staff, June 15, 2009, ¶ 22. 64 Id., at ¶ 29. 65 Id., ¶ 5. 66Memorandum of Interview of Paul Sass by OCE staff, June 16, 2009, ¶¶ 23, 29. 67Memorandum of Interview of Thomas Brown by OCE staff, June 16, 2009, ¶ 12; Memorandum of Interview of Paul Sass by OCE staff, June 16, 2009, ¶ 16. 68 Interview of Paul Sass by Standards Committee staff, September 16, 2009. On February 

25, 2009, Mr. Sass sent an email at 9:53 a.m. to two other staff members. That email contained 

the following text: ‘‘Back in 2004 SG had a friend . . . who is a member of the MO Soybean 

Assn testify on a similar topic and he wants to extend an invitation to him. I am calling him 

today to gauge his interest.’’ COS 00089. Mr. Sass told the Standards Committee that his word 

choice in this email could be misread. Interview of Paul Sass by Standards Committee staff, 

September 16, 2009. Mr. Sass explained that often times, including in this case, when he referred to Representative Graves as wanting something, he meant Representative Graves’ personal office, as opposed to the Small Business Committee minority staff. Id. 

Representative Talent,57 Mr. Hurst said that he recalled being invited to testify in front of the Committee on Ways and Means by 

former-Representative Kenny Hulshof.58

Mr. Hurst told OCE ‘‘he was the first person that Representative 

Graves thought of because he was the President of the MSA and 

he had worked on biodiesel issues in the past and because the 

hearing was scheduled with such [short] notice.’’ 59 Representative 

Graves also told OCE that, among other reasons for selecting Mr. 

Hurst, he ‘‘was the easiest witness to find for the hearing that was 

held in March given the short time frame for locating witnesses 

and he was one of the most knowledgeable persons available.’’ 60

3. Brooks Hurst Was Selected To Testify at the Hearing 

Mr. Sass told the Standards Committee that the Small Business 

Committee’s minority staff eventually identified two witnesses who 

satisfied their initial requirements, one of whom was Mr. Hurst.61

The other potential witness was already scheduled to be in Washington, D.C. on the day of the hearing.62 Representative Graves 

told OCE that he did not want the other witness to testify at the 

hearing because he believed that the Small Business Committee 

may have assisted the other witness’s company with grants.63

OCE’s interview memorandum of Representative Graves states, 

‘‘[w]hen asked about the members of the corn growers being in 

town at the time of the meeting, Representative Graves stated that 

‘‘ ‘if he remembered correctly’ the Committee already had an ‘ethanol guy’ and they were looking for a ‘biodiesel guy’ to balance out 

the witness list as much as possible.’’ 64

Representative Graves told OCE that he ‘‘was not sure who chose 

Brooks Hurst to testify at the hearing; he believed that it might 

have been Paul Sass.’’ 65 Mr. Sass told OCE that he believed that 

he suggested Mr. Hurst to Representative Graves.66 Representative 

Graves’ Chief of Staff and Mr. Sass told OCE that they believed 

that Representative Graves did not choose Mr. Hurst to be a witness and that Representative Graves did not get involved in the 

process of selecting witnesses for Small Business Committee hearings.67 Mr. Sass told the Standards Committee that he made the 

ultimate decision to invite Mr. Hurst.68


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69 Interview of Paul Sass by Standards Committee staff, September 16, 2009. 70 COS 00092. 71 COS 00061; COS 00063. 72 COS 00061; Rep. Graves’ 2008 Financial Disclosure Statement. 73 COS 00063; Rep. Graves’ 2008 Financial Disclosure Statement. Mrs. Graves is one of 400 

investors in Biofuels. COS 00063. 74 Rep. Graves’ 2008 Financial Disclosure Statement. 75 COS 00114; COS 00115. 76 Id. 77 COS 00115. 78Memorandum of Interview of Rep. Graves by OCE staff, June 15, 2009, ¶ 39. 79Memorandum of Interview of Brooks Hurst by OCE staff, July 13, 2009, ¶¶ 14 and 18. 80Memorandum of Interview of Paul Sass by OCE staff, June 16, 2009, ¶ 11. 81 Id., at if ¶ 45. 

Mr. Sass told the Standards Committee that he placed telephone 

calls and sent emails to Mr. Hurst to invite him to the hearing, but 

Mr. Hurst did not immediately return his calls or reply to his 

emails.69 It appears that instead of replying to Mr. Sass, Mr. Hurst 

called Representative Graves directly to confirm his availability. 

On February 26, 2009, Mr. Sass sent an email at 5:09 p.m. to three 

staff members. That email contained the following text: ‘‘Ok, I just 

spoke with Sam and apparently Brooks Hurst is back on board. It 

will get nailed down tomorrow. I got Sam to agree to allowing [the 

other witness] to testify if Brooks doesn’t work out.’’ 70

F. Financial Interest Putatively Shared by Brooks Hurst and 

Representative Graves 

At the time of the hearing, Representative Graves’ wife had investments in two Missouri non-profit cooperative marketing associations specializing in renewable fuels: Golden Triangle Energy 

Cooperative (Golden Triangle) and Biofuels LLC (Biofuels).71 Mrs. 

Graves’ investment in Golden Triangle represents a 0.18% interest 

in the cooperative and is valued between $1,000 and $15,000.72

Mrs. Graves’ investment in Biofuels represents a 0.125% interest 

and is valued between $15,000 and $50,000.73 Mrs. Graves’ investments in Golden Triangle and Biofuels were disclosed on Representative Graves’ Financial Disclosure Statements.74 Mr. Hurst 

also has investments in both Golden Triangle and Biofuels.75 Mr. 

Hurst’s investment in Golden Triangle represents a 0.50% interest 

in the cooperative.76 Mr. Hurst’s investment in Biofuels represents 

an interest of less than 0.33%.77

Representative Graves told OCE that ‘‘[i]nvestments are not 

something that he talks about with Brooks Hurst. He could not say 

what Brooks Hurst was invested in; he goes in and out of investments so he wouldn’t know what he was invested in.’’ 78 Similarly, 

Mr. Hurst told OCE that he was not aware of any of Representative Graves’ investments.79 Representative Graves’ staff also stated 

that they did not know of any shared investments between Representative Graves and Mr. Hurst. Mr. Sass told OCE that ‘‘[h]e 

does not have discussions of witnesses’ personal financial 

records.’’ 80 Representative Graves’ staff was aware that Mr. Hurst 

was a friend of Representative Graves. However, the staff did not 

view that as problematic. OCE’s interview memorandum of Mr. 

Sass states, ‘‘When asked if the Congressman’s friendship with 

Brooks Hurst was an issue, he stated that it was not because 

Brooks Hurst was a credible witness, he is involved with all the associations so it was not a concern.’’ 81


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82See, e.g., ‘‘Biofuels, Flights Benefit Graves,’’ Paul Singer, Roll Call, November 7, 2007. 83See ‘‘Family ties to ethanol plant draw questions for Rep. Sam Graves,’’ Steve Kraske, The 

Kansas City Star, December 6, 2007. 84Memorandum of Interview of Rep. Graves by OCE staff, June 15, 2009, ¶ 53. 85 House Rule XI, clause 2(g)(4). 86 Id. 87 COS 00013. 88 A member of Representative Graves’ personal staff coordinated Mr. Hurst’s travel to Washington, D.C. The electronic confirmation for Mr. Hurst’s travel to and from Washington, D.C., 

indicates that Mr. Hurst departed Kansas City for Washington, D.C. on March 3, 2009, at 9:00 

a.m., and departed Washington, D.C., for Kansas City on March 4, 2009, at 6:35 p.m. COS 

00099. The cost of the airplane ticket appears to be $165.20, and Mr. Hurst paid for his travel 

to and from Washington, D.C. COS 00125. 89 COS 00183–00186; COS 00175–00182; COS 00187–00191; COS 00170–00174. 90On March 2, 2009, at 3:10 p.m., Mr. Hurst sent an email to a member of the minority staff 

on the Small Business Committee replying to a prior email that inquired as to what Mr. Hurst 

‘‘would like [his] affiliation to be for the hearing.’’ Mr. Hurst’s email contained the following text: 

‘‘Go ahead and use my title as member of the board of directors of the Paseo-Cargill Biofuels 

plant and Missouri Soybean Association.’’ COS 00123. 

OCE asserts that Representative Graves may have been aware 

at one time of Mr. Hurst’s investments in Golden Triangle and 

Biofuels several years prior to Mr. Hurst’s testimony at the hearing. Media reports of a 2004 hearing of the Small Business Subcommittee on Rural Enterprises, Agriculture, and Technology, at 

which Mr. Hurst testified, referenced Mrs. Graves’ and Mr. Hurst’s 

shared investments.82 One such article stated: ‘‘Graves told The 

Kansas City Star . . . that his failure to disclose his connection to 

Golden Triangle at the hearing was a mistake. ‘Looking back on it, 

I probably should have,’ the Tarkio Republican said.’’ 83 However, 

Representative Graves told OCE that this quotation was incomplete and that his full statement was that he probably should have 

disclosed his connection to Golden Triangle ‘‘if he had known what 

his ([Brooks Hurst]’s) investments were.’’ 84 Even if Representative 

Graves was aware at any time of Mr. Hurst’s investments, this 

knowledge would not have been a violation of House Rules in either 2004 or in the present case. 

G. Brooks Hurst and the March 4, 2009, Small Business 

Committee Hearing 

Pursuant to House Rules, when a non-governmental witness is 

selected to testify at a hearing, the witness must submit a written 

copy of the statement that will be made part of the hearing record, 

a curriculum vitae, and: 

a disclosure of the amount and source (by agency and program) of each Federal grant (or subgrant thereof) or contract (or subcontract thereof) received during the current 

fiscal year or either of the two previous fiscal years by the 

witness or by an entity represented by the witness.85

Under House Rules, this is the only information that a committee 

must receive regarding the background of a witness.86 Mr. Hurst 

complied with these rules.87

Mr. Hurst was one of five witnesses at the March 4, 2009, Small 

Business Committee hearing.88 The other witnesses included a representative of an ethanol plant, a representative of a biofuels plant 

equipment manufacturer, a representative from the National Biodiesel Board, and a representative from the National Corn Growers 

Association.89 Mr. Hurst represented the MSA at the hearing.90


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91 COS 00103; COS 00116; COS 00117. 92Memorandum of Interview of Brooks Hurst by OCE staff, July 13, 2009, ¶ 10; see also COS 

00103 (email from the MSA sending Mr. Hurst’s written testimony to Mr. Hurst with a copy 

to Representative Graves’ Staff Assistant/Assistant Scheduler). 93 Interview of Brooks Hurst by Standards Committee staff, September 18, 2009. 94 Id. 95 COS 00192–00195. 96 Id. 97 Id. 98See COS 00192–00195; COS 00187–00191. 99 Interview of Paul Sass by Standards Committee staff, September 16, 2009; Interview of 

Brooks Hurst by Standards Committee staff, September 18, 2009. 100 Interview of Michael Day by Standards Committee staff, September 25, 2009. 

The MSA both prepared Mr. Hurst’s written testimony and provided him with talking points for his oral testimony.91 Mr. Hurst 

told OCE, ‘‘He works with the Missouri Soybean Association. The 

Missouri Soybean Association provided him with written testimony 

and prepped him for the March hearing, as they have done on 

other occasions when he testified on behalf of the association.’’ 92

Mr. Hurst told the Standards Committee that the MSA assisted to 

varying degrees with the drafting of all of his Congressional testimony.93 Mr. Hurst further stated that the MSA provided more assistance for the March 4, 2009, hearing than in the past because 

the week leading up to Mr. Hurst’s testimony was in the middle 

of the planting season for Mr. Hurst’s farm.94

During his testimony, Mr. Hurst recommended an extension of 

the Biodiesel Blender’s Credit program, inclusion of glycerin in the 

Bio-based Fuel Blender’s Credit program, and implementation of 

the Renewable Fuels Standard.95 Mr. Hurst’s written and oral testimony made anecdotal references to specific renewable fuel 

plants.96 The testimony, however, advocated on behalf of the members of the MSA generally, and not for either of the entities in 

which Representative Graves’ wife owned an interest or any other 

specific business.97 There was, moreover, significant overlap between the positions taken by Mr. Hurst and those taken by the 

representative of the National Biodiesel Board, a witness who was 

called to testify at the hearing by the Small Business Committee 

majority.98

H. Actions Taken Following the Small Business Committee 

Hearing 

OCE’s Report and Findings do not contain evidence that the 

March 4, 2009, Small Business Committee hearing resulted in action benefitting anyone, including Representative Graves, Mrs. 

Graves, or Mr. Hurst. The Standards Committee has also uncovered no direct evidence that the hearing resulted in action benefitting Representative Graves, Mrs. Graves, Mr. Hurst, or any other 

person or entity. 

Neither Mr. Hurst nor Mr. Sass was aware of any action on any 

of the issues discussed in his testimony.99 The Staff Director for 

the majority on the Small Business Committee also was not aware 

of any action on any of the issues discussed in Mr. Hurst’s testimony.100

As noted previously, the Small Business Committee has limited 

legislative jurisdiction. Representative Graves told OCE that the 

Small Business Committee: 


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101Memorandum of Interview of Rep. Graves by OCE staff, June 15, 2009, ¶ 62. 102Memorandum of Interview of Paul Sass by OCE staff, June 16, 2009, ¶ 5. 103Memorandum of Interview of Rep. Graves by OCE staff, June 15, 2009, ¶ 72. 104 Id., at ¶ 73. 

is an oversight committee; it does not do legislation except 

the authorization of the Small Business Association. The 

hearings are ‘‘feel good hearings.’’ . . . The committee can 

look at venture capital, healthcare, animal pharmaceuticals, anything. The committee doesn’t have a real 

agenda other than the Small Business Association so they 

look at all types of industries.101

Mr. Sass told OCE that the Small Business Committee ‘‘has limited jurisdiction so they can talk about anything at hearings. The 

‘take-away’ is to try and get press. Other than getting press on an 

issue, the Committee can’t really do anything.’’ 102

According to OCE’s interview memorandum of Representative 

Graves: ‘‘[w]hen asked if he talked to Brooks Hurst about the hearing, Representative Graves stated that he had not, ‘other than this 

issue and how ridiculous it is.’ ’’ 103 OCE’s interview memorandum 

of Representative Graves further states: 

When asked why it is a ridiculous issue, Representative 

Graves stated that it was simply a lot of money and time 

that was being used to look into the matter and there was 

not anything there; he thought the OCE ‘‘must not have 

anything better to do.’’ 104

III. JURISDICTION OF THE STANDARDS COMMITTEE 

The Standards Committee has jurisdiction over the matters addressed in this Report pursuant to House Rule 11, clause 3(a)(2), 

which authorizes the Standards Committee to investigate any alleged violation by a Member, officer, or employee of the House of 

Representatives, of the Code of Official Conduct or of any law, rule, 

regulation, or other standard of conduct applicable to the conduct 

of such Member, officer, or employee. 

The Standards Committee conducted its investigation in this 

matter pursuant to Standards Committee Rule 18(a), which authorizes the Committee to consider any information in its possession indicating that a Member, officer, or employee may have committed a violation of the Code of Official Conduct or any law, rule, 

regulation, or other standard of conduct applicable to the conduct 

of such Member, officer, or employee in the performance of the duties or the discharge of the responsibilities of such individual. 

Standards Committee Rule 18(a) further authorizes the Chair and 

Ranking Minority Member to jointly gather additional information 

concerning such an alleged violation by a Member, officer, or employee unless and until an investigative subcommittee has been established. 

The Standards Committee has authority to issue this Report pursuant to House Rule 11, clause 3(a)(2), under which the Standards 

Committee shall report to the House its findings of fact and recommendations, if any, for the final disposition of any investigation 

and action as the committee may consider appropriate under the 

circumstances; and House Rule 11, clause 3(b)(8)(A), which authorizes the Standards Committee to report on matters forwarded to 


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105 House Rule III, clause 1. 106 House Rule XXIII, clause 2. 107 House Rule III, clause 1. The Standards Committee notes that OCE’s references to House 

Rule 3 are only found in OCE’s Findings, and not OCE’s Report. Further, OCE’s notifications 

to the Standards Committee and Representative Graves also did not mention that OCE was 

analyzing Representative Graves’ conduct under House Rule 3. Because OCE did not provide 

Representative Graves with a copy of its Findings, Representative Graves was not made aware 

that his conduct was being analyzed under House Rule 3 until the Standards Committee forwarded a copy of OCE’s Findings to Representative Graves on September 16, 2009. 108 House Rule XXIII, clause 2. 

the Standards Committee by the Office of Congressional Ethics 

(OCE). 

IV. LEGAL ANALYSIS 

OCE reviewed Representative Graves’ conduct pursuant to House 

Rule 3, clause 1; House Rule 23, clause 2; and what OCE identified 

as ‘‘House precedent on conflicts of interest.’’ For this reason, the 

Standards Committee also reviewed Representative Graves’ conduct pursuant to these rules and standards of conduct. Based on 

the facts presented in OCE’s Report and Findings, as well as the 

facts gathered by the Standards Committee’s independent inquiry, 

the Standards Committee concluded that Representative Graves’ 

conduct did not implicate any of the rules or standards of conduct 

identified by OCE. Thus, the Standards Committee further determined that OCE analyzed Representative Graves’ conduct pursuant to the incorrect rules. 

Instead, the Standards Committee determined that Representative Graves’ conduct should more properly have been analyzed 

under House Rule 23, clause 3; and section 5 of the Code of Ethics 

for Government Service (Code of Ethics). After reviewing Representative Graves’ conduct pursuant to House Rule 23, clause 3, 

and section 5 of the Code of Ethics, the Standards Committee concluded that Representative Graves’ involvement with the witness 

selection process for the March 4, 2009, Small Business Committee 

hearing did not violate any applicable rule or standard of conduct. 

A. Analysis Based on Rules Identified by OCE 

1. Voting on Matters Affecting a Direct Personal Interest (House 

Rule 3, Clause 1) 

OCE analyzed Representative Graves’ conduct pursuant to House 

Rule 3, clause 1; 105 and House Rule 23, clause 2.106 The Standards 

Committee determined that Representative Graves’ conduct did not 

implicate these rules. 

House Rule 3, clause 1 provides: 

Every Member . . . shall vote on each question put, unless having a direct personal or pecuniary interest in the 

event of such question.107

House Rule 23, clause 2 provides: 

A Member . . . shall adhere to the spirit and the letter 

of the Rules of the House. . . .108

OCE initially alleged that Representative Graves’ conduct may 

have implicated House Rule 3, clause 1, and House Rule 23, clause 

2, because his involvement in selecting Mr. Hurst to appear before 


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109OCE Review No. 09–7000, Findings of Fact and Citations of Law (OCE Findings), ¶ 82. 110 Id. 111 House Ethics Manual, Committee on Standards of Official Conduct, 110th Congress, 2nd 

Sess. (2008 ed.) (House Ethics Manual) at 237. 112OCE Report. A copy of the report can be at Appendix E. 113OCE Findings, ¶¶ 81, 82 (emphasis added). 

the Small Business Committee may have violated ‘‘the spirit of 

House Rule 3.’’ 109 However, OCE ultimately concluded: 

any disqualifying interest that Representative Graves had 

in this matter would likely have affected Representative 

Graves only as a member of a class; therefore, there is not 

substantial reason to believe that Representative Graves’ 

invitation to [Mr. Hurst] violated the spirit of House Rule 

3.110

The Standards Committee agrees with OCE’s conclusion that 

Representative Graves did not violate the letter or spirit of House 

Rule 3. However, the Standards Committee feels compelled to note 

that the underlying premise of OCE’s analysis was flawed because 

the Standards Committee finds that Representative Graves’ conduct did not implicate House Rule 3. 

House Rule 3 applies in one situation only—when a Member is 

voting on the House floor. 111 Representative Graves was not voting, to the contrary, the March 4, 2009, hearing involved no legislation that would ultimately come to the House floor for Representative Graves and other Members upon which to vote. Therefore, 

House Rule 3 was inapplicable to Representative Graves’ conduct. 

Moreover, because House Rule 3 was inapplicable to Representatives Graves’ conduct, the ‘‘spirit’’ of House Rule 3 was equally inapplicable. For these reasons, OCE’s analysis was flawed because 

OCE analyzed Representative Graves’ activities with respect to 

witness selection under the rule applicable to voting. 

2. House ‘‘Precedent’’ on Conflict of Interest 

OCE alleged Representative Graves’ conduct may have violated 

what OCE identified as House ‘‘precedent’’ on conflict of interest.112

OCE ultimately concluded: 

the Board finds there is substantial reason to believe that 

the guidance in the House Ethics Manual—advising Members to employ ‘‘added circumspection’’ when participating 

in actions that may affect their personal financial interest 

and to guard against taking any action that would give the 

appearance of any impropriety or conflict of interest— 

would compel Representative Graves to disclose the financial interests he shared with [Mr. Hurst] at the time of the 

Committee hearing or refrain from extending [Mr. Hurst] 

an invitation to appear. . . . 

[T]here is substantial reason to believe that Representative Graves’ invitation to [Mr. Hurst] created an appearance of a conflict of interest[.] 113

Notably, OCE did not cite any House Rule or other standard of 

conduct in reaching this conclusion. The House Ethics Manual provides guidance to assist Members, officers, and staff in complying 

with the Code of Official Conduct or any law, rule, regulation, or 

other standard applicable to their conduct in the performance of 


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114 House Ethics Manual, Preface; House Rule XI, clause 3(a). 115The Standards Committee notes that it has exclusive jurisdiction over the interpretation, 

administration, and enforcement of the Code of Official Conduct. See House Rule 1(q); Standards 

Committee Rule 17A(a). 116 House Ethics Manual at 237. 117 Under the facts in this matter, the Standards Committee determined that Representative 

Graves’ conduct did not create a conflict of interest. In addition, even assuming arguendo that 

there was a rule prohibiting creating the appearance of a conflict of interest, Representative 

Graves’ conduct would not have created such an appearance. 118 House Ethics Manual at 250 (quoting House Bipartisan Task Force on Ethics, Report on 

H.R. 3360, 101st Cong., 1st Sess. 22 (Comm. Print, Comm. On Rules 1989), reprinted in 135 

Cong. Rec. H9253, H9259 (daily ed. Nov. 21, 1989)). 119 House Ethics Manual at 251 (‘‘Review of a Member’s financial conduct occurs in the context 

of the political process’’). 120 Id. (quoting House Comm’n on Admin. Review, Financial Ethics, H. Doc. 95–73, 95th Cong. 

1st Sess., at 9 (1977) (hereinafter ‘‘Financial Ethics’’) (‘‘[p]otential conflicts of interest are best 

deterred through disclosure and the discipline of the electoral process.’’) 121 House Ethics Manual at 251. 122 Id. 

their duties or the discharge of their responsibilities.114 The House 

Ethics Manual does not create independent duties outside of the 

rules and other standards discussed therein. The Standards Committee is particularly concerned that OCE’s analysis in this matter 

may create confusion regarding Standards Committee precedent 

with respect to conflicts of interest.115

The pertinent section of the House Ethics Manual cited by OCE 

states: 

[A]ctions that Members may normally take on particular 

matters in connection with their official duties, such as 

sponsoring legislation, advocating or participating in an 

action by a House committee, or contacting an executive 

branch agency . . . entail a degree of advocacy above and 

beyond that involved in voting, and thus a Member’s decision on whether to take any such action on a matter that 

may affect his or her personal financial interests requires 

added circumspection.116

However, no relevant House Rule or other standard of conduct 

prohibits creation of an appearance of a conflict of interest when selecting witnesses for a committee hearing.117 In fact, the House 

Ethics Manual recognizes that some actual conflicts of interests are 

inevitable: ‘‘[s]ome conflicts of interest are inherent in the representative system of government, and are not in themselves necessarily improper or unethical.’’ 118 Instead, Members are required 

to disclose assets based on the principle that conflicts of interest 

are best resolved by the political process.119 ‘‘The objectives of financial disclosure are to inform the public about the financial interests of government officials in order to increase public confidence 

in the integrity of government and to deter potential conflicts of interest.’’ 120

‘‘The House has required public financial disclosure by rule since 

1968, and by statute since 1978.’’ 121 Public disclosure of assets, financial interests, and investments is intended to regulate possible 

conflicts of interest to ‘‘provide the information necessary to allow 

Members’ constituencies to judge their official conduct in light of 

possible financial conflicts with private holdings.’’ 122

Thus, the timely filing of complete and accurate Financial Disclosure Statements is essential to the political process and is fundamental to the House ethics system. 


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123 House Ethics Manual at 248. 124 House Rule XXVI; Title I of the Ethics in Government Act of 1978 (5 U.S.C. App. ¶¶ 101– 

111). 125 House Ethics Manual at 251. 126 Id. (quoting Financial Ethics at 9). 127 House Ethics Manual at 250. 128 Rep. Graves’ 2008 Financial Disclosure Statement. 129 COS 00013. The Standards Committee notes that OCE was made aware of Mr. Hurst’s full 

compliance, but omitted that fact from its Report and Findings. 130 ‘‘Graves’ Friend Gets a Soapbox,’’ Paul Singer, Roll Call, March 9, 2009; see generally 

‘‘Family ties to ethanol plant draw questions for Rep. Sam Graves,’’ Steve Kraske, The Kansas 

City Star, December 6, 2007. 

‘‘No federal statute, regulation or rule of the House absolutely 

prohibits a Member or House employee from holding assets that 

might conflict with or influence the performance of official duties.’’ 123 A conflict of interest becomes problematic when a Member 

uses his position to enhance his personal financial interests or his 

personal financial interests impair his judgment in conducting his 

public duties. To prevent a Member’s personal interest from interfering with his official duties, a member is required to make public 

disclosure of assets, financial interests, and investments.124

‘‘Public disclosure is intended to provide the information necessary to allow Members’ constituencies to judge their official conduct in light of possible financial conflicts with private holdings.’’ 125 In recommending broader public disclosure as the preferred method of regulating possible conflicts of interest in lieu of 

other restrictions on investment income, the House Commission on 

Administrative Review of the 95th Congress noted: 

[P]otential conflicts of interest are best deterred through 

disclosure and the discipline of the electoral process. Other 

approaches are flawed both in terms of their reasonableness and practicality, and threaten to impair, rather than 

to protect, the relationship between the representative and 

the represented.126

As noted in the House Ethics Manual: 

A Member may often have a community of interests with 

the Member’s constituency, and may arguably have been 

elected because of and to serve these common interests, 

and thus would be ineffective in representing the real interests of the constituents if the Member was disqualified 

from voting on issues touching those matters of mutual 

concern.127

Here, there is no evidence that Representative Graves failed to 

comply with any disclosure requirement applicable to him at the 

time of the hearing. In fact, Representative Graves’ Financial Disclosure Statements fully and accurately reflects his financial interests, including his wife’s 0.18% interest in Golden Triangle and 

0.125% interest in Biofuels.128 The evidence further shows that Mr. 

Hurst fully complied with all disclosure requirements for witnesses 

appearing at House committee hearings.129 Moreover, the evidence 

shows that the House disclosure rules were effective, because this 

issue was immediately covered by the press.130

The Standards Committee concludes that Representative Graves’ 

involvement with the witness selection process for the March 4, 

2009, Small Business Committee hearing did not create a conflict 

of interest for the following reasons: 


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131See generally House Rule X, clause 1(p); see also Memorandum of Interview of Rep. Graves 

by OCE staff, June 15, 2009, ¶ 62; Memorandum of Interview of Paul Sass by OCE staff, June 

16, 2009, ¶ 5; Memorandum of Interview of Rep. Graves by OCE staff, June 15, 2009, ¶¶ 72, 

73. 132 COS 00019; COS 00065; see also, Memorandum of Interview of Rep. Graves by OCE staff, 

June 15, 2009, ¶ 62; Memorandum of Interview of Paul Sass by OCE staff, June 16, 2009, ¶ 5; 

Memorandum of Interview of Rep. Graves by OCE staff, June 15, 2009, in ¶¶ 72, 73. 133 House Rule X, clauses 1(p), 2(b); and 3(l). 134 COS 00192–COS 195. 135 Id. 136 Id. 137 Id.; House Rule X, clause 1(p). 138 COS 00065; COS 00067; COS 00069; COS 00071; COS 00073; COS 00082; COS 00084; 

Memorandum of Interview of Paul Sass by OCE staff, June 16, 2009, ¶¶ 4, 11; Interview of Paul 

Sass by Standards Committee staff, September 16, 2009; Interview of Brooks Hurst by Standards Committee staff, September 18, 2009; Memorandum of Interview of Rep. Graves by OCE 

staff, June 16, 2009, ¶ 13; Memorandum of Interview of Brooks Hurst by OCE staff, July 13, 

2009, ¶ 9. 139 COS 00192–COS 195. 140See id.; COS 00187–00191. 

First, neither Representative Graves nor Mrs. Graves could derive a financial benefit from Mr. Hurst’s testimony.131 Mr. Hurst 

was invited to testify before the Small Business Committee at a 

hearing that was held solely as a fact-gathering hearing about the 

impact of the current economic crisis on the renewable fuels industry.132 The Small Business Committee’s jurisdiction does not extend to any legislative function over the renewable fuels industry.133 Also, Mr. Hurst did not use his testimony as an opportunity 

to request any particular action from the Small Business Committee.134

Second, there is no indication Representative Graves actually received a financial benefit from Mr. Hurst’s testimony. During his 

testimony, Mr. Hurst recommended an extension of the Biodiesel 

Blender’s Credit program, inclusion of glycerin in the Biobased 

Fuel Blender’s Credit program, and implementation of the Renewable Fuels Standard.135 Mr. Hurst’s recommendations applied generally to the biofuels industry as a whole and not to any particular 

company.136 Neither the facts contained in OCE’s Report and Findings nor the Committee’s independent investigation revealed that 

the Small Business Committee took any action in relation to Mr. 

Hurst’s recommendations. As stated previously, the Small Business 

Committee did not have the ability to take any action on Mr. 

Hurst’s recommendation because such action was outside of the 

Small Business Committee’s jurisdiction.137

Third, assuming arguendo that Representative Graves or his wife 

benefited financially from Mr. Hurst’s testimony, Mr. Hurst met all 

of the reasonable and objective requirements the staff established 

for a witness, for the March 4, 2009, Small Business Committee 

hearing.138 Moreover, Representative Graves’ putative interest was 

not an interest unique to him but was instead an interest that he 

held as part of a large class of investors. Mr. Hurst’s testimony addressed issues of concern to the members of the MSA generally, 

and not to any particular entity.139 In fact, the testimony presented 

by Mr. Hurst significantly overlapped with the positions taken by 

the representative of the National Biodiesel Board, another witness 

who spoke at the hearing.140 Thus, even if Representative Graves 

or his wife had derived a financial benefit from Mr. Hurst’s testimony, such benefit would only have been as a member of a class 

of investors in renewable fuel companies. Moreover, Mrs. Graves’ 

investments in both companies in which Mr. Hurst held stock were 


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141 COS 00061; COS 00063. Mrs. Graves was one of 400 investors in Biofuels LLC. See COS 

00063. 142 House Rule XXIII, clause 3. 143 Code of Ethics for Government Service, section 5. Pertinent portions of the Code of Ethics 

for Government Service can be found at Appendix C. 144 House Rule XXIII, clause 3. 

minimal. She owned a 0.18% interest in Golden Triangle and a 

0.125% interest in Biofuels.141 As such, even if Mr. Hurst’s testimony benefited only the two companies in which Mrs. Graves was 

invested, Representative Graves’ or Mrs. Graves’ personal financial 

interest in either investment would have been affected as members 

of a class of investors and not as individuals. 

For all the reasons stated herein, after reviewing the evidence 

gathered by OCE and conducting its own independent investigation, the Standards Committee finds that Representative Graves 

did not violate any law, rule, regulation, or other standard of conduct applicable to him in connection with the invitation of Mr. 

Hurst to testify before the Small Business Committee. 

B. Analysis Based on Relevant Rules and Statutes 

Based on the facts presented by OCE’s Report and Findings as 

well as the facts gathered by the Standards Committee’s independent investigation, the Standards Committee determined that 

Representative Graves’ conduct was more properly analyzed under 

House Rule 23, clause 3,142 and section 5 of the Code of Ethics.143

However, the Standards Committee ultimately determined that 

Representative Graves’ conduct did not violate House Rule 23, 

clause 3, or section 5 of the Code of Ethics. 

1. Improper Use of Official Position (House Rule 23, clause 3) 

House Rule 23, clause 3, provides: 

A Member . . . of the House may not receive compensation and may not permit compensation to accrue to the 

beneficial interest of such individual from any source, the 

receipt of which would occur by virtue of influence improperly exerted from the position of such individual in Congress.144

To establish a violation under House Rule 23, clause 3, in connection with inviting a witness to testify before a committee hearing, it must be shown that a Member improperly used his or her 

official position by inviting the witness to appear before the committee and that the Member received a direct pecuniary benefit 

that resulted from the witness’ testimony. After reviewing the evidence collected by OCE and conducting its own independent investigation, the Standards Committee concluded that Representative 

Graves did not improperly use his official position in connection 

with Mr. Hurst’s invitation to testify before the Small Business 

Committee. 

After the minority staff of the Small Business Committee received notification from the majority staff that a hearing entitled 

‘‘The State of Renewable Fuels Industry in the Current Economy’’ 

was scheduled to be held on March 4, 2009, and before selecting 

a witness, the minority staff established criteria for selecting potenVerDate Nov 24 2008 06:31 Nov 04, 2009 Jkt 053070 PO 00000 Frm 00032 Fmt 6659 Sfmt 6602 E:\HR\OC\HR320.XXX HR320

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145 COS 00065; COS 00067; COS 00069; COS 00071; COS 00073; COS 00082; COS 00084; 

Memorandum of Interview of Paul Sass by OCE staff, June 16, 2009, ¶¶ 4, 11; Interview of Paul 

Sass by Standards Committee staff, September 16, 2009. 146 Id. The Standards Committee finds that the criteria developed by the Small Business Committee’s minority staff were reasonable and objective. 147 Interview of Paul Sass by Standards Committee staff, September 16, 2009; Memorandum 

of Interview of Thomas Brown by OCE staff, June 16, 2009, ¶ 12; Memorandum of Interview 

of Paul Sass by OCE staff, June 16, 2009, ¶ 16. However, the Standards Committee notes that, 

even if Representative Graves had greater involvement in the selection of Mr. Hurst to testify 

at the hearing, this would not have been improper. 148The Standards Committee notes that there is no evidence that anyone or any entity received any financial benefit as a result of Mr. Hurst’s testimony before the Small Business Committee on March 4, 2009. 149 House Rule XXIII, clause 3. 150 Code of Ethics for Government Service, section 5. 

tial witnesses.145 The criteria that the staff established for potential witnesses sought a witness who was: from Representative 

Graves’ congressional district; familiar with the renewable fuels industry; and not employed by a company in which Representative 

Graves was invested.146 Mr. Hurst, who Mr. Sass originally suggested, met each of the requirements. Although Mr. Hurst held investments in two renewable energy cooperatives in which Mr. 

Graves was invested, he was not an officer or employee of either 

company. In addition, Representative Graves gave limited input as 

to who the minority staff should select to testify before the Small 

Business Committee. The final decision as to which individual was 

invited was left up to, and actually made by, the minority staff.147

Thus, the Standards Committee concluded that because Mr. Hurst 

met all of the reasonable and objective criteria to testify at the 

hearing, Representative Graves’ involvement with selection of Mr. 

Hurst was not improper. 

Because the Standards Committee concluded that Representative 

Graves’ involvement with the selection of the witness was not impermissible, the Standards Committee did not need to reach the 

issue of whether Representative Graves received any benefit in connection with Mr. Hurst’s testimony. However, the Standards Committee notes that neither OCE nor the Committee’s independent investigation identified any evidence that Representative Graves received any benefit in connection with Mr. Hurst’s testimony.148

Thus, even if Representative Graves’ involvement with the selection of the witness had been improper, it would not have violated 

House Rule 23, clause 3.149

2. Dispensing Personal Favors (Section 5 of the Code of Ethics for 

Government Service) 

Section 5 of the Code of Ethics, provides: 

Any person in Government Service should: * * * 

V. Never discriminate unfairly by the dispensing of special favors or privileges to anyone, whether for remuneration or not; and never accept for [one]self or [one’s] family, 

favors or benefits under circumstances which might be 

construed by reasonable persons as influencing the performance of [one’s] governmental duties.150

To establish a violation under section 5 of the Code of Ethics in 

connection with inviting a witness to testify before a committee 

hearing requires a showing that a Member improperly used his or 


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151 Id. 152 Id. 153 COS 00065; COS 00067; COS 00069; COS 00071; COS 00073; COS 00082; COS 00084; 

Memorandum of Interview of Paul Sass by OCE staff, June 16, 2009, ¶¶ 4, 11; Interview of Paul 

Sass by Standards Committee staff, September 16, 2009; Interview of Brooks Hurst by Standards Committee staff, September 18, 2009; Memorandum of Interview of Rep. Graves by OCE 

staff, June 16, 2009, ¶ 13; Memorandum of Interview of Brooks Hurst by OCE staff, July 13, 

2009, ¶ 9. 154Memorandum of Interview of Rep. Graves by OCE staff, June 15, 2009, ¶¶ 3, 4; Memorandum of Interview of Paul Sass by OCE staff, June 16, 2009, ¶ 57. 155 Interview of Paul Sass by Standards Committee staff, September 16, 2009; Memorandum 

of Interview of Thomas Brown by OCE staff, June 16, 2009, ¶ 12; Memorandum of Interview 

of Paul Sass by OCE staff, June 16, 2009, ¶ 16. However, the Standards Committee notes that, 

even if Representative Graves had greater involvement in the selection of Mr. Hurst to testify 

at the hearing, this would not have been improper. 

her official position by making that invitation.151 It is not necessary for a Member to receive a benefit from a witness’s testimony 

to violate section 5 of the Code of Ethics.152 After reviewing the 

evidence collected by OCE and conducting its own independent investigation, the Standards Committee determined that Representative Graves did not improperly use his official position by inviting 

Mr. Hurst to testify before the Small Business Committee. 

As noted above, Mr. Hurst met all of the reasonable and objective 

requirements the staff established for a witness for the March 4, 

2009, Small Business Committee hearing.153 As was customary for 

the minority on the Small Business Committee, Representative 

Graves had limited involvement with the witness selection process,154 and the ultimate decision to invite Mr. Hurst was made by 

the minority staff, not Representative Graves.155 Thus, because Mr. 

Hurst met all of the reasonable and objective requirements the 

staff established for a witness for the March 4, 2009, Small Business Committee hearing, Representative Graves’ involvement in 

the witness selection process did not discriminate unfairly against 

other potential witnesses by dispensing a special favor to Mr. 

Hurst. 

Accordingly, the Standards Committee concluded that Representative Graves’ involvement in the witness selection process was not 

improper where Mr. Hurst, an individual who held investments in 

two companies in which Representative Graves’ wife also held investments, was selected based on Mr. Hurst’s qualifications, as 

measured by objective and reasonable witness selection criteria. As 

a result, Representative Graves did not violate Section 5 of the 

Code of Ethics. 

V. CONCLUSIONS AND RECOMMENDATIONS 

OCE reviewed Representative Graves’ conduct pursuant to House 

Rule 3, clause 1; House Rule 23, clause 2; and what OCE identified 

as ‘‘House precedent on conflicts of interest.’’ For this reason, the 

Standards Committee also reviewed Representative Graves’ conduct pursuant to these rules and standards of conduct. Based on 

the facts presented in OCE’s Report and Findings, as well as the 

facts gathered by the Standards Committee’s independent investigation, the Standards Committee concluded that Representative 

Graves’ conduct did not implicate any of the rules or standards of 

conduct identified by OCE. Thus, the Standards Committee further 

determined that OCE analyzed Representative Graves’ conduct 

pursuant to the incorrect rules. 


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156OCE Review No. 09–7000, Findings of Fact and Citations of Law (OCE Findings), ¶ 9. OCE 

Findings can be found at Appendix E. 157OCE Findings, ¶ 10; House Resolution 895, 110th Cong., 2nd Sess. (H. Res. 895), section 

1(c)(1)(B) and (C) (110th Cong., March 11, 2008); Rules of the Office of Congressional Ethics, 

7(C) and (D) (hereinafter OCE Rules). Copies of H. Res. 895 and the OCE Rules can be found 

at Appendix C. 158See, e.g., OCE Findings, ¶¶ 10 and 11; H. Res. 895, section 1(c)(1)(C) and section 1(c)(2)(A); 

OCE Rule 8(C). 159OCE Rule 8(C) and H. Res. 895, section I, clause (c)(1)(C); see e.g., Memorandum of Interview of Rep. Graves by OCE staff, June 15, 2009; Memorandum of Interview of Brooks Hurst 

by OCE staff, July 13, 2009; Memorandum of Interview of Thomas Brown by OCE staff, June 

16, 2009; Memorandum of Interview of Paul Sass by OCE staff, June 16, 2009; and Memorandum of Interview of Jason Klindt by OCE staff, June 16, 2009. Pertinent portions of the 

OCE’s memoranda of interview can be found at Appendix D. 160Letter from David E. Skaggs and Porter J. Goss to Zoe Lofgren and Jo Bonner, August 

6, 2009. A copy of the letter can be found at Appendix E. 

Instead, the Standards Committee determined that Representative Graves’ conduct should more properly have been analyzed 

under House Rule 23, clause 3; and section 5 of the Code of Ethics 

for Government Service (Code of Ethics). After reviewing Representative Graves’ conduct pursuant to House Rule 23, clause 3, 

and section 5 of the Code of Ethics, the Standards Committee concluded that Representative Graves’ involvement with the witness 

selection process for the March 4, 2009, Small Business Committee 

hearing did not violate any applicable rule or standard of conduct. 

In the view of the Standards Committee’s findings and conclusions, no further action is recommended, and the Committee considers the matter closed. 

VI. OCE’s REVIEW 

While reviewing the materials forwarded to it by OCE, the 

Standards Committee was deeply disappointed to identify several 

procedural and substantive deficiencies in OCE’s review, some of 

which would appear to have been fatal to OCE’s ability to continue 

its review. Regretfully, the Standards Committee believes that it is 

necessary for the proper administration of the House ethics process 

and the due process rights of any current or future subject of an 

OCE investigation to identify these unfortunate deficiencies in this 

report. In so doing, the Standards Committee intends only to identify the issues it identified in the course of its review and does not, 

in any way, intend to ascribe to OCE any intent, motive or bad 

faith with respect to the deficiencies identified below. 

A. Summary of OCE’s Review 

On March 26, 2009, OCE initiated its preliminary review into allegations regarding the conduct of Representative Graves.156 During the preliminary review period, the OCE Board timely voted to 

initiate a second-phase review.157 Unfortunately, during the course 

of OCE’s second-phase review, OCE repeatedly failed to comply 

with deadlines mandated by OCE’s authorizing resolution and its 

own rules.158 OCE’s disregard for these deadlines resulted in OCE 

failing to terminate the matter as required by rule and conducting 

key phases of its investigatory work outside of the jurisdiction 

granted to OCE by its authorizing resolution.159

On August 6, 2009, OCE forwarded to the Standards Committee 

its Report and Findings recommending further review of allegations involving Representative Graves.160 OCE’s ‘‘report’’ consisted 


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161 COS 00126–COS 00149. 162Standards Committee Rule 17A(a). The Standards Committee Rules can be found at Appendix C. 163See OCE Findings, 9–13; See Memorandum of Interview of Rep. Graves by OCE staff, June 

15, 2009; Memorandum of Interview of Brooks Hurst by OCE staff, July 13, 2009; Memorandum 

of Interview of Thomas Brown by OCE staff, June 16, 2009; Memorandum of Interview of Paul 

Sass by OCE staff, June 16, 2009; and Memorandum of Interview of Jason Klindt by OCE staff, 

June 16, 2009; H. Res. Section 1, clause (c)(1) and (c)(2). 164 H. Res. 895, section 1, clause (c)(1)(A); see also Special Task Force on Ethics Enforcement, 

Report of the Democratic Members of the Special Task Force on Ethics Enforcement, 110th Cong., 

1st Sess., at 16 (2007) (hereinafter Capuano Report). The Special Task Force on Ethics Enforcement was the task force instructed to study creation of an independent ethics enforcement entity 

within the House. A copy of the Capuano Report can be found at Appendix C. 165OCE Rule 9(A); OCE Findings, ¶¶ 80–82. 166 H. Res. 895, section 1, clause (c)(2)(C)(i)(II)(dd). 167 Interview of Rep. Graves’ Counsel by Standards Committee staff, September 17, 2009. 

of a one-page statement of the nature of Representative Graves’ alleged violation. OCE’s ‘‘findings’’ consisted of a more detailed summary of OCE’s review. At the same time that OCE forwarded its 

Report and Findings to the Standards Committee, OCE also sent 

a copy of its one-page Report to Representative Graves. However, 

OCE did not provide Representative Graves with a copy of its Findings. 

After reviewing OCE’s Report and Findings, the Standards Committee provided Representative Graves with a copy of OCE’s Report 

and Findings and gave Representative Graves an opportunity to 

submit a response to OCE’s Report and Findings. Representative 

Graves submitted a response, in which he: presented additional 

facts that were not included in OCE’s Findings; raised procedural 

concerns with OCE’s review; took issue with certain of OCE’s factual and legal conclusions; and requested that the Standards Committee not make public OCE’s Report and Findings in the interests 

of justice, fundamental fairness, and due process.161

The Standards Committee reviewed the matter discussed in 

OCE’s Report and Findings without prejudice or presumptions as 

to the merits of the allegations.162 As such, the Standards Committee’s findings and conclusions with regard to Representative Graves 

were informed by, but made independent of, OCE’s Report and 

Findings. After reviewing OCE’s Report and Findings and conducting its own independent investigation, the Standards Committee was disappointed to find that OCE’s review was fundamentally flawed. 

First, as noted above, OCE repeatedly violated deadlines found 

in OCE’s authorizing resolution.163 Second, OCE’s findings unfortunately revealed the names and other identifying information of several cooperating witnesses in contravention of OCE’s authorizing 

resolution.164 Third, OCE forwarded the matter to the Standards 

Committee for further review without finding a ‘‘substantial reason 

to believe’’ that there was a violation of any relevant, substantive 

rule or other standard of conduct applicable to Representative 

Graves.165 Fourth, OCE’s Findings improperly made conclusions 

regarding the truth of statements made by cooperating witnesses, 

including Representative Graves.166 Fifth, OCE ignored relevant 

evidence provided by Representative Graves to OCE. Finally, the 

Standards Committee discovered materials within OCE’s Report 

and Findings that were potentially favorable or exculpatory to Representative Graves, but which OCE did not provide to Representative Graves.167


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168Standards Committee Rule 17A(c). 169Standards Committee Rule 17A and 25. 170 H. Res. 895, section 1, clause (c)(2)(C). 171OCE Rules 1, 4, 8, 9, and 11. 172See generally U.S. v. Watkins, 354 U.S. 178, 201 (1957) (holding that with respect to ‘‘investigating committees’’ Congress is ‘‘require[d] . . . to . . . spell out that group’s jurisdiction and 

purpose’’ and that those ‘‘instructions are embodied in the authorizing resolution’’). 173See generally U.S. v. Rumely, 345 U.S. 41, 44 (1953) (upholding reversal of conviction for 

refusal to answer questions of select committee of Congress because questions were outside of 

the scope of the select committee’s authorizing resolution, which was the ‘‘controlling charter 

of the committee’s powers’’ and thus ‘‘[i]ts right to exact testimony and to call for the production 

of documents must be found’’ in the resolution). 174 H. Res. 895, section 1, clause (c)(2)(C)(i)(II)(dd). 175OCE Rule 9(A) (emphasis in original). 176 H. Res. 895, section 1(c)(1)(B); OCE Rule 7(D). OCE must initiate a preliminary review 

within seven days of the request to commence the review. H. Res. 895, section 1(c)(1)(A); OCE 

Rule 7(C). 177 H. Res. 895, section 1(c)(1)(C). 

Because of the unfortunate flaws in OCE’s Report and Findings, 

the Standards Committee was confronted with a potential conflict 

between the requirement that the Standards Committee make 

OCE’s Report and Findings publicly available,168 and the due process and privacy protections afforded to Representative Graves and 

OCE’s cooperating witnesses by the Standards Committee Rules,169

OCE’s authorizing resolution,170 and OCE’s rules.171 The Standards Committee was concerned that publication of OCE’s Report 

and Findings would further compound OCE’s unfortunate failure to 

follow its authorizing resolution. However, the Standards Committee concluded that, on balance, the public interest was served by 

publication of OCE’s Report and Findings in this case, and thus the 

Standards Committee declined to withhold publication of OCE’s Report and Findings. 

B. OCE’s Authorizing Resolution and Rules 

OCE’s jurisdiction to review a matter is given only by virtue of 

OCE’s authorizing resolution.172 If OCE acts in contravention of its 

authorizing resolution, OCE loses jurisdiction over a matter.173

OCE’s authorizing resolution limits OCE’s reviewing authority to 

‘‘any alleged violation by a Member . . . of any law, rule, regulation, or other standard of conduct applicable to the conduct of such 

Member . . . in the performance of his duties or the discharge of 

his responsibilities[.]’’ 174 In accord with this resolution, OCE’s 

rules state that: 

The Board shall refer a matter to the Standards Committee for further review if it determines there is a substantial reason to believe the allegations based on all the 

information then known to the Board. However, in the 

event the Office is unable to reach that determination, but 

the Board does determine there is probable cause to believe the allegations, the Board may refer the matter to 

the Standards Committee for further review.175

OCE’s preliminary review must be completed within 30 days of 

receipt of a request to commence a preliminary review.176 If OCE’s 

Board does not vote to initiate a second-phase review by the end 

of the preliminary review period, the matter is terminated.177

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178 H. Res. 895, section 1(c)(1)(C); OCE Rule 8(C). Upon receiving OCE’s Report and Findings, 

the Standards Committee discovered that the Standards Committee and OCE had differing interpretations as to when OCE’s second-phase review commenced. Accordingly, the Standards 

Committee’s staff and OCE’s staff met with the House Parliamentarians to ascertain the correct 

interpretation. In the meeting the House Parliamentarian determined that if OCE’s Board votes 

to initiate a second-phase review, the second-phase review of that matter begins immediately 

following the end of OCE’s 30-day preliminary review period. 179OCE Rule 8(C) and H. Res. 895, section 1, clause (c)(1)(C). 180 Rule 8(C) and H. Res. 895, section 1, clause (c)(2)(A)(ii). 181 Id. 182 Id.; see generally Rumely, 345 U.S. at 44. 183 H. Res. 895, section 1(c)(2)(C)(i)(I). 184 H. Res. 895, section 1(c)(2)(C)(i)(II). 185See Capuano Report at 16. 

nary review period expires.178 OCE’s second-phase review terminates in 45 days,179 unless OCE votes to extend the second-phase 

review for an additional 14 days.180 The vote to extend must occur 

before the second-phase terminates.181 Once OCE’s second-phase 

review concludes, OCE’s legal authority to conduct further interviews or investigation is suspect.182

Upon completion of a second-phase review, OCE is ‘‘authorized 

and directed to’’ transmit a written report to the Standards Committee. This written report must be: 

composed solely of— 

(aa) a recommendation that the committee should dismiss the matter that was the subject of such review; 

(bb) a statement that the matter requires further review; 

or 

(cc) a statement that the matter is unresolved because 

of a tie vote; and 

the number of members voting in the affirmative and in the 

negative and a statement of the nature of the review and the 

individual who is subject of the review[.] 183

Along with its report, OCE is also ‘‘authorized and directed to’’ 

transmit its findings, if any, to the Standards Committee. OCE’s 

findings must be: 

composed solely of— 

(aa) any findings of fact; 

(bb) a description of any relevant information that it was 

unable to obtain or witnesses who it was unable to interview, and the reasons therefor; 

(cc) a recommendation for the issuance of subpoenas 

where appropriate, if any; and 

(dd) a citation of any relevant law, rule, regulation, or 

standard of conduct; 

but not the names of any cooperative witnesses or any conclusions regarding the validity of the allegations upon which it is 

based or the guilt or innocence of the individual who is the 

subject of the review[.] 184

The restriction on including the names of cooperative witnesses 

in OCE’s Findings is further explained in the Capuano Report, 

which states: 

Cooperative witnesses, who will not be named by the 

board within the Findings in order to preserve confidentiality, should be listed within the supporting documents 

for the Standards Committee’s information. These materials shall not be published unless the Standards Committee deems it necessary and appropriate.185


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186 H. Res. 895, section 1(c)(2)(C)(i)(III). 187OCE Rule 4(F). 188The Standards Committee previously asked OCE for supporting documentation. OCE staff 

informed the Standards Committee that OCE does not possess any ‘‘supporting documents.’’ 

Subsequently, OCE has also stated that they do not possess any supporting documents that are 

in their view, ‘‘germane.’’ 189OCE Findings, ¶ 9. 190OCE Findings, ¶ 9. The Committee notes this date is inconsistent with the Letter from 

David E. Skaggs and Porter J. Goss to Zoe Lofgren and Jo Bonner dated March 30, 2009, which 

indicated OCE had already initiated a preliminary review. 191OCE Findings, ¶ 10. These dates are taken directly from the ‘‘Procedural History’’ section 

of OCE’s Findings. 192Letter from David E. Skaggs and Porter J. Goss to Zoe Lofgren and Jo Bonner, April 27, 

2009. Neither OCE’s rules nor its policies permit OCE to delay the start of OCE’s second-phase 

review period beyond the end of the preliminary review period. See United States ex rel. Accardi 

v. Shaughnessy, 347 U.S. 260, 268 (1954) (holding that having stated the manner in which it 

is to exercise its discretion, an agency cannot refuse to follow its own rules); Wilson v. Commissioner of Social Sec., 378 F.3d 541, 545 (6th Cir. 2004) (holding that agencies are bound to follow 

their own regulations and that an agency’s failure to follow its own regulations, even when those 

regulations are more generous than necessary, tends to cause unjust discrimination and deny 

adequate notice); Sameena Inc. v. United States Air Force, 147 F.3d 1148, 1153 (9th Cir. 1998) 

(‘‘[t]he Supreme Court has long recognized that a federal agency is obliged to abide by the regulations it promulgates. An agency’s failure to follow its own regulations ‘tends to cause unjust 

discrimination and deny adequate notice’ and consequently may result in a violation of an individual’s constitutional right to due process. Where a prescribed procedure is intended to protect 

the interests of a party before the agency, ‘even though generous beyond the requirements that 

bind such agency, that procedure must be scrupulously observed.’ ’’) (internal citations and 

quotations omitted)). 193OCE Findings, ¶ 10. 194See Memorandum of Interview of Rep. Graves by OCE staff, June 15, 2009. 195See Memorandum of Interview of Thomas Brown by OCE staff, June 16, 2009; Memorandum of Interview of Paul Sass by OCE staff, June 16, 2009; and Memorandum of Interview 

of Jason Klindt by OCE staff, June 16, 2009; and Memorandum of Interview of Brooks Hurst 

by OCE staff, July 13, 2009. 

Along with its Report and Findings, OCE is also ‘‘authorized and 

directed to’’ transmit ‘‘any supporting documentation’’ to the Standards Committee.186 OCE is also required to ‘‘promptly provide to a 

subject any exculpatory information received.’’ 187 Unfortunately, to 

date, the Committee has not been provided with any supporting 

documentation related to this matter.188

C. Procedural History of OCE’s Review 

On March 26, 2009, two members of the OCE Board made a request to commence a preliminary review into allegations regarding 

the conduct of Representative Graves.189 OCE initiated its preliminary review in this matter on April 2, 2009.190 Pursuant to OCE’s 

authorizing resolution, OCE’s preliminary review concluded on 

April 25, 2009. On April 24, 2009, at least three members of the 

OCE Board voted to initiate a second-phase review in this matter.191

Pursuant to OCE’s authorizing resolution and OCE’s policies as 

stated to the Committee, OCE’s second-phase review should have 

begun on April 26, 2009, and the second-phase review should have 

concluded on June 9, 2009. On April 27, 2009, OCE sent a letter 

to the Standards Committee noting that it had voted to initiate a 

second-phase review in the matter concerning Representative 

Graves. Unfortunately, OCE’s letter stated that the second-phase 

review would not ‘‘commence’’ until May 2, 2009.192 On June 12, 

2009 three days after the second-phase review period ended, the 

OCE Board voted to extend the second-phase review for two additional weeks.193 Unfortunately, OCE interviewed a witness on June 

15, 2009,194 six days after the second-phase review period ended. 

OCE also interviewed three more witnesses on June 16, 2009,195


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196OCE Findings, ¶ 11. 197See Memorandum of Interview of Brooks Hurst by OCE staff, July 13, 2009. OCE’s unfortunate disregard for the deadlines mandated by its authorizing resolution raises the question 

of whether OCE was required, under the OCE Rule requiring OCE to disclose exculpatory materials to subject members (OCE Rule 4(F)), to disclose to Representative Graves that OCE missed 

strict deadlines and conducted portions of its investigation outside of the time permitted. 198 OCE Report. The Standards Committee notes that the Capuano Report stated that ‘‘Members of the Task Force believe that the timeline requirements instituted by the new process are 

critical: matters will spend at most three months under consideration by the board of the OCE 

before being referred to the Standards Committee for resolution.’’ Capuano Report at 14. 199Letter from David E. Skaggs and Porter J. Goss to Zoe Lofgren and Jo Bonner, August 

6, 2009. 200The Standards Committee notes that OCE’s witness interviews are neither transcribed nor 

videotaped. Instead, the only record of OCE’s witness interviews is found in memoranda of interviews reflecting OCE’s staff’s impressions of the interview. 201 As noted previously, the Standards Committee asked OCE for its supporting documentation, but OCE staff informed the Standards Committee that OCE does not possess any ‘‘supporting documents’’ and later that OCE does not possess any ‘‘supporting documents’’ that are 

‘‘germane.’’ 202 Interview of Rep. Graves’ Counsel by Standards Committee staff, September 17, 2009. 

seven days after the second-phase review period should have 

ended. 

On June 30, 2009, eighteen days after OCE voted to extend the 

second-phase review period for fourteen days, OCE completed its 

second-phase review.196 However, OCE interviewed a witness on 

July 13, 2009.197 This interview occurred thirteen days after its 

second-phase review ended according to OCE, and thirty-four days 

after the second-phase review period should have ended by rule. As 

such, it was untimely, and thus conducted outside of OCE’s legal 

authority, even by OCE’s own incorrect calculation of the applicable 

dates. On July 24, 2009, 120 days after two members of the OCE 

Board made a request to commence a preliminary review, OCE’s 

Board adopted a Report and Findings and ordered the Report and 

Findings to be transmitted to the Standards Committee.198

D. OCE’s Report and Findings 

On August 6, 2009, OCE forwarded to the Standards Committee 

a Report and Findings recommending further review of allegations 

involving Representative Graves.199 OCE’s Report and Findings relating to Representative Graves consisted of approximately 169 

pages. Only one page of the 169 pages is the ‘‘report.’’ Pages 5 

through 22 consist of OCE’s narrative summary of the ‘‘findings,’’ 

while the remaining 145 pages consist of documents cited in the 

narrative summary, including emails collected by OCE during its 

review, memoranda of interviews of cooperating witnesses (that 

have never been shown to or adopted by the witnesses interviewed),200 newspaper articles, and other miscellaneous materials. 

Unfortunately, OCE did not forward any ‘‘supporting documents’’ to 

the Standards Committee.201 OCE only provided Representative 

Graves with the one-page report, but did not provide him with the 

Findings or any other documents.202

1. OCE’s Report 

OCE’s one-page report—the only document forwarded to Representative Graves—identified the subject of OCE’s review as Representative Graves and the ‘‘nature of the alleged violation’’ as: 

Representative Sam Graves, Ranking Member of the 

Committee on Small Business, invited Witness A to testify 

at a Committee hearing on ‘‘The State of Renewable Fuels 


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203OCE Report. 204 Id. 205The Standards Committee notes that House Rule 23 contains eighteen distinct provisions 

by which a Member shall abide. 206OCE Report. 207OCE Findings, ¶ 17 (italics in original) (quoting House Rule 23, clause 2; House Rule 3, 

clause 1; House Ethics Manual, at 237). 208Findings, ¶ 2. 

Industry in the Current Economy.’’ The hearing was held 

on March 4, 2009. Witness A and Representative Graves’ 

wife, Lesley Graves, both hold financial interests in the 

same renewable fuels plants in Missouri. Representative 

Graves’ conduct may have violated House Rule 23 and 

House precedent regarding conflict of interest.203

OCE’s Report did not provide any additional statement regarding 

the substantive allegations underlying OCE’s review,204 such as 

which provision of House Rule 23 was allegedly implicated by Representative Graves’ conduct.205 OCE’s Report recommended ‘‘that 

the Committee on Standards of Official Conduct further review the 

above described allegations concerning Representative Graves.’’ 206

2. OCE’s Findings 

OCE’s Findings, which were not forwarded to Representative 

Graves, stated that the ‘‘Code of Official Conduct’’ relevant to Representative Graves’’ conduct included: 

Under House Rule 23, clause 2, Members ‘‘shall adhere 

to the spirit and the letter of the Rules of the House . . .’’ 

Under House Rule 3, clause 1, ‘‘Every Member . . . shall 

vote on each question put, unless he has a direct personal 

or pecuniary interest in the event of such question.’’ 

The House Ethics Manual advises ‘‘sponsoring legislation, advocating or participating in an action by a House 

Committee, or contacting an executive branch agency . . . 

entails a degree of advocacy above and beyond that involved in voting, and thus a Member’s decision on whether 

to take any such action on a matter that may affect his or 

her personal financial interests requires added circumspection.’’ 

The House Ethics Manual further advises that Members 

should guard against even the appearance of any impropriety or conflict of interest because such actions may adversely affect public perceptions and confidence.207

OCE’s Findings conclude that: 

there is substantial reason to believe that an appearance 

of conflict of interest was created when Representative 

Graves invited . . . a friend of the Representative’s who 

was invested in the same ethanol and biodiesel cooperatives as his wife, to testify before the Committee on Small 

Business.208

OCE’s Findings further concluded that ‘‘the guidance in the 

House Ethics Manual . . . would compel Representative Graves to 

disclose the financial interests he shared with [Mr. Hurst] at the 


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209OCE Findings, ¶ 81. 210OCE Findings, ¶ 82. 211 Interview of Paul Sass by Standards Committee staff, September 16, 2009; Interview of 

Brooks Hurst by Standards Committee staff, September 18, 2009; Interview of Michael Day by 

Standards Committee staff, September 25, 2009. 212 House Rule XI, clause 3(b)(8)(A); Standards Committee Rule 17A(c)(1). Pertinent portions 

of the House Rules can be found at Appendix C. 213 House Rule XI, clause 3(b)(8)(A); Standards Committee Rule 17A(c)(1). If the Standards 

Committee votes to withhold the report and findings for an additional 45 days and does not 

empanel an investigative subcommittee within the additional 45-day time period, the Standards 

Committee must then make OCE’s report and findings public. House Rule XI, clause 3(b)(8)(A); 

Standards Committee Rule 17A(c)(1). 214 House Rule XI, clause 3(b)(8)(A). Any public release of OCE’s findings must be made by 

the Standards Committee. OCE has no authority to publicly release its report and findings, nor 

does OCE have any authority to publicly comment on its report and findings or the matters contained therein at any time. 215Statement of the Chair and Ranking Republican Member of the Committee on Standards 

of Official Conduct Regarding Representative Sam Graves, September 16, 2009. 216 Id. 

time of the Committee hearing or refrain from extending [Mr. 

Hurst] an invitation to appear.’’ 209

However, OCE’s Findings also state that: 

any disqualifying interest that Representative Graves had 

in this matter would likely have affected Representative 

Graves only as a member of a class; therefore, there is not 

substantial reason to believe that Representative Graves’ 

invitation to [Mr. Hurst] violated the spirit of House Rule 

3.210

E. The Standards Committee’s Investigation 

1. Standards Committee’s Activities 

In addition to reviewing OCE’s Report and Findings, the Standards Committee conducted its own independent investigation. During the course of its investigation, the Standards Committee sought 

and received pertinent documents from relevant witnesses on a voluntary basis. The Standards Committee also conducted three voluntary interviews of relevant witnesses.211

If OCE properly refers a report and findings recommending further review to the Standards Committee, within 45 days the Standards Committee may either vote to empanel an investigative subcommittee or vote to withhold the Report and Findings for an additional 45 days.212 If the Standards Committee does not take either 

of those actions within 45 days, the Standards Committee must 

make OCE’s properly referred report and findings public.213 Any 

release of OCE’s report and findings may be accompanied by a report by the Standards Committee regarding the matter discussed 

in OCE’s report and findings.214

On September 15, 2009, the Standards Committee unanimously 

voted to withhold OCE’s Report and Findings for an additional 45 

days.215 In its press statement, released the same day, the Standards Committee explained that it had two reasons for voting to extend the matter.216 The Standards Committee’s first reason was 

that: 

the Office of Congressional Ethics did not find a ‘‘substantial reason to believe’’ that there was a substantive violation of any provision of the Code of Official Conduct or any 

law, rule, regulation, or other standard of conduct applicable to Representative Graves’ conduct in the performance 


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217 Id. 218 Id 219 Id. 220 Id. 221Letter from Blake Chisam, Chief Counsel and Staff Director, to Rep. Graves, September 

16, 2009. 222 COS 00126–COS 00169. At the request of the Standards Committee, Representative 

Graves adopted his counsel’s submission by oath or affirmation. See Affirmation of Rep. Graves 

(October 6, 2009). 223 COS 00130. 224Standards Committee Rule 17A(c). 225 H. Res. 895, section 1, clause (c)(2)(C). 226OCE Rules 1, 4, 8, 9, and 11. 227Standards Committee Rule 17A and 25. 

of his duties or the discharge of his responsibilities. Nevertheless, it referred the matter to the Committee for further 

review.217

The Standards Committee’s second reason was that it had ‘‘identified materials in the Office of Congressional Ethics’ report and 

findings that may contain exculpatory evidence, which OCE never 

provided to Representative Graves.’’ 218 The Standards Committee 

unanimously voted to extend the matter ‘‘to provide Representative 

Graves with potentially favorable or exculpatory materials, which 

the Committee understands, in the interests of justice, should have 

been provided to Representative Graves pursuant to Office of Congressional Ethics Rule 4(F).’’ 219 The Standards Committee further 

noted that ‘‘Committee Rule 25 requires us to disclose these materials to Representative Graves.’’ 220

On September 16, 2009, the Standards Committee forwarded 

OCE’s Report and Findings to Representative Graves and offered 

Representative Graves the opportunity to respond to OCE’s Report 

and Findings within 15 days.221 Before the expiration of the 15-day 

response period, Representative Graves sought an extension of one 

business day, which the Standards Committee granted. Representative Graves’ counsel submitted a response to OCE’s Report and 

Findings on October 5, 2009.222

2. Representative Graves’ Submission 

The Standards Committee was disappointed to find that Representative Graves’ submission presented facts that were not included in OCE’s Findings, raised procedural concerns with OCE’s 

review, and took issue with certain of OCE’s factual and legal conclusions. Representative Graves’ submission also requested that the 

Standards Committee not make public OCE’s Report and Findings 

in the interests of justice, fundamental fairness, and due process.223

The Standards Committee gave careful consideration to Representative Graves’ request. The Standards Committee was concerned that many of the regrettable flaws in OCE’s Report and 

Findings created an unfortunate conflict between the publication 

requirement in the Standards Committee’s Rules 224 and the due 

process and privacy protections afforded to Representative Graves 

and OCE’s cooperating witnesses by OCE’s authorizing resolution,225 OCE’s Rules,226 and the Standards Committee Rules.227

Given these regrettable flaws, the Standards Committee was concerned that publication of OCE’s Report and Findings would further compound OCE’s apparent violations of its authorizing resolution. However, despite the strong arguments against release of 


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228 COS 00133. Representative Graves provided the memorandum, which was prepared in the 

context of the investigation, to the Standards Committee. The Standards Committee notes that 

OCE did not discuss this memorandum in its Findings. The Standards Committee also notes 

that OCE never provided the memorandum, nor any ‘‘supporting documents’’ to the Standards 

Committee. The Standards Committee is puzzled by the fact that OCE did not incorporate this 

information into its Findings for public disclosure. The Standards Committee is also troubled 

by the transparency concerns inherent in OCE potentially withholding relevant information 

from the Standards Committee. 229 COS 00134. 230 COS 00137. 231 COS 00127–COS 00129. 232 COS 00139–COS 00141. 233 COS 00141–COS 00144. 234 COS 00145; COS 00146. 

OCE’s Report and Findings, the Standards Committee declined to 

withhold publication of OCE’s Report and Findings. Instead, the 

Standards Committee concluded that its concerns with the conflict 

created by releasing a fundamentally flawed Report and Findings 

were outweighed by the interests to the House, and the public, in 

ensuring accountability and transparency with regard to OCE and 

OCE’s practices. The Standards Committee notes that its publication of this Report and Findings should not be viewed as determinative of whether this matter was legally referred to the Standards Committee such that it triggered the Standards Committee’s 

duty under House Rule 11, clause 3(b)(8)(A) to publicly disclose 

OCE’s Report and Findings. 

a. New facts presented by Representative Graves: 

i. Before OCE’s second-phase review period expired, Representative Graves gave to OCE a memorandum describing the 

rules pertaining to disclosure by witnesses testifying before the 

Small Business Committee and explaining that Mr. Hurst complied with all such rules.228

ii. The Small Business Committee has never inquired into 

potential witnesses’ financial investments or financial dealings 

that the witness may have in common with a member of the 

committee or a member’s spouse.229

iii. Mr. Hurst told OCE that he never discussed specific investments with Representative Graves and that he was not 

aware of what investments Representative Graves or his wife 

had.230

b. Procedural arguments made by Representative Graves: 

i. OCE only disclosed to Representative Graves that it was 

reviewing his conduct with respect to House Rule 23 generally. 

It did not cite to any specific provision of House Rule 23, nor 

to House Rule 3. Thus, OCE failed to accurately advise Representative Graves of the rules or standards of conduct that he 

was alleged to have violated.231

ii. OCE violated OCE Rules 4(F) and 5 by failing to provide 

exculpatory information to Representative Graves.232

iii. OCE conducted its investigation outside of its jurisdictional time limitations.233

iv. OCE’s review was outside of its jurisdiction because Representative Graves’ alleged conduct did not violate any ‘‘law, 

rule, regulation, or other standard of conduct . . . applicable to 

[him] in the performance of his . . . duties or the discharge of 

his . . . responsibilities.’’ 234


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235 COS 00146–COS 00147. 236 COS 00148. 237 Id. 238 COS 00132. 239 COS 00135. 240 COS 00135. 241 COS 00136; COS 00137. 242 COS 00138; COS 00139 243Standards Committee Rule 17A(a). The Standards Committee Rules can be found at Appendix C. 

v. OCE’s Report and Findings violated Standards Committee 

Rule 15(a)(4) because it contained ‘‘innuendo, speculative assertions, and conclusory statements.’’ 235

vi. OCE failed to disclose to Representative Graves that the 

information he provided to OCE might be publicly disclosed 

‘‘whether it was germane to the investigation or not.’’ 236

vii. OCE’s Report and Findings improperly reveal the names 

of cooperative witnesses and personal information from individuals referenced in the Report and Findings, including identities, email addresses, and phone numbers.237

c. Factual and legal conclusions with which Representative 

Graves took issue: 

i. Representative Graves reasoned that because the Small 

Business Committee has no financial oversight authority, Representative Graves could have no financial interest in Mr. 

Hurst’s testimony before the Small Business Committee.238

ii. Representative Graves argued that OCE’s theory regarding disclosure of financial interests ‘‘would create an absurdity 

because it would require all Members of the [Small Business 

Committee] to cross-check their investments and their spouse’s 

investments with each potential witnesses’ investments every 

time a witness is invited by the [committee] to testify.’’ 239

iii. Representative Graves asserted that his then-Deputy 

Chief of Staff, his Chief of Staff, and Representative Graves all 

agree that Representative Graves did not choose Mr. Hurst to 

be a witness and was rarely involved in the process of selecting 

witnesses.240

iv. Representative Graves stated that he and Mr. Hurst dispute OCE’s inference that Representative Graves was aware of 

Mr. Hurst’s invesments.241

v. Representative Graves argued that Mr. Hurst’s background and history of congressional testimony refute OCE’s inference that Mr. Hurst was not qualified to testify at the hearing.242

F. Findings and Conclusions Regarding Deficiencies in OCE’s 

Review 

The Standards Committee reviews any findings transmitted by 

OCE without prejudice or presumptions as to the merits of the allegations.243 As such, the Standards Committee’s findings and conclusions with regard to Representative Graves were informed by, 

but made independent of, OCE’s Report and Findings. However, 

after reviewing OCE’s Report and Findings regarding the conduct 

of Representative Graves and conducting its own independent investigation, the Standards Committee was deeply disappointed to 

discover that OCE’s review was fundamentally flawed because it 


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244See generally, Watkins, 354 U.S. at 201. 245See Capuano Report at 11, 14. 246 H. Res. 895, (c)(1)(C). This practice is consistent with other legal frameworks, in which investigative bodies are bound to strict deadlines to protect the fundamental due process rights 

of the subject of the investigation. 247OCE Review No. 09–7000, Findings of Fact and Citations of Law (OCE Findings), ¶ 9. 248 H. Res. 895, section 1(c)(1)(B); OCE Rule 7(D). 249OCE Findings, ¶ 10. 250 H. Res. 895, section 1(c)(1)(C); OCE Rule 8(C). As noted previously, this interpretation of 

when OCE’s second-phase review commences was provided to both the Standards Committee’s 

staff and OCE’s staff by the House Parliamentarian’s Office, who stated that, if OCE’s Board 

votes to initiate a second-phase review, that second-phase review begins immediately following 

the end of OCE’s 30-day preliminary review period. Thus, the first day of OCE’s second-phase 

review was April 26, 2009. The Standards Committee notes that OCE stated in a letter that 

its second-phase review would not ‘‘commence’’ until May 2, 2009. Letter from David E. Skaggs 

and Porter J. Goss to Zoe Lofgren and Jo Bonner, April 27, 2009. OCE unfortunately did not 

provide any explanation for how it could delay commencing the second-phase review for five 

days. OCE has explained to the Standards Committee that its policy is to commence secondphase reviews on the day after the preliminary phase review ends. 251OCE Rule 8(C) and H. Res. 895, section 1, clause (c)(2)(A)(i). 252OCE Rule 8(C) and H. Res. 895, section 1, clause (c)(2)(A)(ii). 253OCE Findings, ¶ 10. 254 H. Res. 895, section 1, clause (c)(2)(A)(ii). 255OCE Rule 8(C) and H. Res. 895, section 1, clause (c)(2)(A)(i). 256OCE Findings, ¶ 11. 

routinely failed to adhere to the requirements of OCE’s authorizing 

resolution, some of which were fatal to OCE’s ability to continue 

its review. 

First, OCE failed to meet certain deadlines mandated by OCE’s 

authorizing resolution and OCE’s rules. OCE’s jurisdiction to review a matter stems solely from OCE’s authorizing resolution.244

Failure by OCE to abide by the strict timeframes established by its 

authorizing resolution effectively strips OCE of its jurisdiction over 

a matter.245 For example, in order for OCE to commence a secondphase review, three members of the Board must vote to commence 

a second-phase review before the end of the preliminary review. ‘‘If 

no such vote to commence a second-phase review has succeeded by 

the end of the applicable time period, the matter is terminated.’’ 246

OCE’s preliminary review began at the request of two members 

of OCE’s Board on March 26, 2009,247 and was completed within 

30 days on April 25, 2009.248 On April 24, 2009, at least three 

members of the OCE Board voted to initiate a second-phase review 

in this matter.249 By rule, OCE’s second-phase review commenced 

when the preliminary review period expired.250 OCE’s secondphase review ends in 45 days,251 which in this case was June 9, 

2009, and OCE could only have extended that period once by 14 

days.252 Unfortunately, OCE voted to extend its review of the matter on June 12, 2009.253 This vote occurred three days after the 

second-phase review terminated, and OCE’s authorizing resolution 

requires that a vote to extend must occur before the termination 

of the second-phase review.254 Thus, by law, OCE’s second-phase 

review ended on June 9, 2009, because OCE did not timely vote to 

extend the review.255

In its Findings, OCE claimed that the second-phase review terminated on June 30, 2009.256 Unfortunately, this was an incorrect 

calculation of the applicable time period regardless of which date 

OCE used. If the correct date of June 9, 2009, was used, OCE’s 14- 

day extension would have ended on June 23, 2009. Even calculating from June 12, 2009, the date on which OCE voted to extend, 

the 14 days would have ended on June 26, 2009. 


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257The dates of these interviews are documented in OCE’s memoranda of interview. See 

Memorandum of Interview of Rep. Graves by OCE staff, June 15, 2009; Memorandum of Interview of Brooks Hurst by OCE staff, July 13, 2009; Memorandum of Interview of Thomas Brown 

by OCE staff, June 16, 2009; Memorandum of Interview of Paul Sass by OCE staff, June 16, 

2009; and Memorandum of Interview of Jason Klindt by OCE staff, June 16, 2009. 258The date of this interview is documented in OCE’s memorandum of interview, and was 

independently confirmed by the Standards Committee. Memorandum of Interview of Brooks 

Hurst by OCE staff, July 13, 2009. 259See OCE Rule 8(C) and H. Res. 895, section 1, clause (c)(2)(A)(i); OCE Findings, ¶ 11; 

Memorandum of Interview of Brooks Hurst by OCE staff, July 13, 2009; see generally Rumely, 

345 U.S. 41; see also Capuano Report stated that ‘‘Members of the Task Force believe that the 

timeline requirements instituted by the new process are critical: matters will spend at most 

three months under consideration by the board of the OCE before being referred to the Standards Committee for resolution.’’ Capuano Report at 14. 260 H. Res. 895, section 1, clause (c)(1)(A). The Standards Committee notes that OCE gave the 

Standards Committee a revised version of its Findings on October 28, 2009, at 5:00 p.m. In this 

revised version, OCE redacted the last four digits of business direct-dial telephone numbers, the 

user-names of non-House email addresses, and all digits of private telephone numbers. The 

redactions, while helpful, do not resolve one of the fundamental problems with OCE’s Findings— 

that it names cooperating witnesses in direct violation of its authorizing resolution and its rules. 261See Capuano Report at 16. 262See H. Res. 895, section 1, clause (c)(2)(C)(i)(II)(dd) and (c)(2)(C)(i)(III). 263 Not only did OCE deem unredacted documents, which identify cooperating witnesses, to 

be part of its Findings, OCE also incorporated and pasted into various sections of the narratives 

summary of its Findings images of emails and other documents provided by cooperating witnesses. Unfortunately, these images contain the identities of witnesses that voluntarily provided 

documents or testimony to OCE. The Standards Committee was particularly concerned that 

OCE’s disclosure of the names of cooperating witnesses does not preserve the confidentiality of 

those witnesses. 

Because the Board did not vote on or before June 9, 2009, OCE’s 

review involving Representative Graves legally terminated on June 

9, 2009. 

Since the matter terminated by rule, OCE staff should not have 

conducted further interviews or investigation. However, OCE conducted all of its interviews after June 9, 2009.257

Further, even assuming arguendo that the second-phase review 

concluded on June 30, 2009, as OCE claims, OCE continued to 

gather evidence in violation of its authorizing resolution. OCE staff 

interviewed a main and key witness in this matter on July 13, 

2009,258 13 days after OCE claimed the second-phase review concluded, and 34 days after the matter terminated by rule. Unfortunately, OCE appears to have lacked legal authority to conduct this 

interview.259

Second, OCE’s findings erroneously revealed the names and 

other identifying information of several cooperating witnesses in 

contravention of OCE’s authorizing resolution.260 As the Capuano 

Report states, ‘‘[c]ooperative witnesses, who will not be named by 

the board within the Findings in order to preserve confidentiality, 

should be listed within the supporting documents for the Standards 

Committee’s information. These materials shall not be published 

unless the Standards Committee deems it necessary and appropriate.’’ 261 Recognizing important confidentiality concerns, OCE’s 

authorizing resolution contemplated that OCE would issue limited 

public ‘‘findings’’ and that the bulk of information pertaining to a 

subject under investigation would be contained in non-public ‘‘supporting documentation’’ unless its disclosure was directly relevant 

and necessary for inclusion in the ‘‘findings.’’ 262 Unfortunately, 

throughout OCE’s ‘‘findings,’’ the names and other identifying information—such as emails, addresses, telephone numbers, and titles—of cooperating witnesses are disclosed openly without any attempt to redact the names or other identifying information.263 BeVerDate Nov 24 2008 06:31 Nov 04, 2009 Jkt 053070 PO 00000 Frm 00047 Fmt 6659 Sfmt 6602 E:\HR\OC\HR320.XXX HR320

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264Given the interplay between the various publication requirements of OCE’s report and 

findings, and the clear directive to protect the privacy of cooperating witnesses, the Standards 

Committee is particularly concerned with the inclusion of identifying information—such as 

email addresses, direct-dial extensions, and personal cellular telephones—in OCE’s Report and 

Findings. However, given these publication requirements, the Standards Committee is also more 

generally concerned with the presence of significant quantities of extraneous and irrelevant information included as part of OCE’s Report and Findings in this case. 265 H. Res. 895, section 1, clause (c)(2)(C)(i)(II)(dd). 266OCE Rule 1(3). 267OCE Rule 9(A) (emphasis in original). 268OCE Findings, ¶¶ 80–82. 269 In light of this, the Standards Committee was surprised to note the resources expended 

to conduct this investigation. For example, OCE sent two attorneys to Kansas City, who stayed 

overnight, to interview witnesses. See, e.g., Memorandum of Interview of Rep. Graves by OCE 

staff, June 15, 2009. The Standards Committee also conducted its own independent investigation. The Standards Committee notes that Representative Graves hired counsel to represent him 

during both OCE’s review and the Standards Committee’s investigation. 270The Standards Committee is particularly concerned with improper referrals of this nature 

because of the publication requirements of referrals to the Standards Committee that reccause OCE made these materials part of its Findings, they are potentially subject to mandatory public disclosure.264

Third, OCE referred the matter to the Standards Committee for 

further review without finding a ‘‘substantial reason to believe’’ 

that there was a substantive violation of any provision of the Code 

of Official Conduct or any law, rule, regulation, or other standard 

of conduct applicable to Representative Graves’ conduct in the performance of his duties or the discharge of his responsibilities. 

OCE’s authorizing resolution limits OCE’s review authority to ‘‘any 

alleged violation by a Member . . . of any law, rule, regulation, or 

other standard of conduct applicable to the conduct of such Member 

. . . in the performance of his duties or the discharge of his 

responsibilities[.]’’ 265 In accord with this resolution, OCE’s rules 

state that OCE’s jurisdiction is limited to reviewing whether a 

Member has violated a ‘‘law, rule or regulation, or other standard 

of conduct in effect at the time the conduct occurred . . .’’ 266 OCE’s 

rules further state that: 

The Board shall refer a matter to the Standards Committee for further review if it determines there is a substantial reason to believe the allegations based on all the 

information then known to the Board. However, in the 

event the Office is unable to reach that determination, but 

the Board does determine there is probable cause to believe the allegations, the Board may refer the matter to 

the Standards Committee for further review.267

OCE found a substantial reason to believe that Representative 

Graves’ conduct was inconsistent with the advice in the Standards 

Committee’s House Ethics Manual that Members should avoid the 

‘‘appearance’’ of a conflict of interest, but did not find that Representative Graves violated House Rule 3 (pertaining to voting) or 

House Rule 23, clause 2 (i.e., failure to abide by the spirit of the 

rules).268 There is no relevant rule or standard of conduct that absolutely prohibits the ‘‘appearance’’ of a conflict of interest or that 

compels disclosure of every potential conflict.269 It is with great regret that the Standards Committee determines that it can only conclude that OCE violated both its authorizing resolution and its own 

rules when it forwarded this matter to the Standards Committee 

for further consideration without finding a ‘‘substantial reason to 

believe’’ that there was a substantive violation of any relevant rule 

or standard of conduct.270


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ommend further review. If OCE properly refers a report and findings recommending further review to the Standards Committee, within 45 days the Standards Committee may either vote to 

empanel an investigative subcommittee or vote to withhold the report and findings for an additional 45 days. House Rule XI, clause 3(b)(8)(A); Standards Committee Rule 17A(c)(1). If the 

Standards Committee does not take either of those actions within 45 days, the Standards Committee must make OCE’s properly referred report and findings public. House Rule XI, clause 

3(b)(8)(A); Standards Committee Rule 17A(c)(1). If the Standards Committee votes to withhold 

the report and fmdings for an additional 45 days and does not empanel an investigative subcommittee within the additional 45-day time period, the Standards Committee must then make 

OCE’s properly referred report and findings public. House Rule XI, clause 3(b)(8)(A); Standards 

Committee Rule 17A(c)(1). In contrast, if OCE properly refers a report and findings recommending dismissal, and the Standards Committee then dismisses that referral, OCE’s report 

and findings need not be published. House Rule XI, clause 3(b)(8)(B)(i); Standards Committee 

Rule 17A(e). 271 H. Res. 895, section 1, clause (c)(2)(C)(i)(II)(dd). 272OCE Findings, ¶ 76. OCE’s findings also improperly make conclusions regarding the validity of other allegations that are directly contrary to statements made by cooperating witnesses. 

See e.g., OCE Findings ¶ 75 (concluding that ‘‘Representative Graves had knowledge of [Mr. 

Hurst]’s investment in Golden Triangle and had reason to believe that [Mr. Hurst] was also invested in Biofuels’’) and OCE Findings, Memorandum of Interview of Rep. Graves by OCE staff, 

June 15, 2009, ¶ 39 (noting that Representative Graves stated that ‘‘Investments are not something that he talks about with Brooks Hurst. He could not say what Brooks Hurst was invested 

in; he goes in and out of investments so he wouldn’t know what he was invested in.’’). 273 Id. 274 H. Res. 895, section 1, clause (c)(2)(C)(i)(II)(aa). 275See Memorandum of Interview of Rep. Graves by OCE staff, June 15, 2009. 276The Standards Committee notes that OCE’s witness interviews are neither transcribed nor 

video-taped. Instead, the only record of OCE’s witness interviews is found in memoranda of 

interviews reflecting OCE’s staff’s impressions of the interview. 277See Morgan v. US., 298 U.S. 468, 481 (1936) (‘‘For the weight ascribed by the law to the 

findings . . . rests upon the assumption that the officer who makes the findings has addressed 

himself to the evidence, and upon that evidence has conscientiously reached the conclusions 

which he deems it to justify. That duty cannot be performed by one who has not considered evidence or argument. It is not an impersonal obligation. It is a duty akin to that of a judge. The 

one who decides must hear.’’); U.S. v. Raddatz, 447 U.S. 667, 697 (1980) (Justice Marshall, dissenting) (‘‘In this respect, the requirement that a finder of facts must hear the testimony offered 

by those whose liberty is at stake derives from deep-seated notions of fairness and human dignity.’’); United States v. Oregon State Medical Society, 343 U.S. 326, 339 (1952) (‘‘ ‘Face to face 

with living witnesses, the original trier of the facts holds a position of advantage from which 

appellate judges are excluded. In doubtful cases, the exercise of his power of observation often 

proves the most accurate method of ascertaining the truth.’ ’’); U.S. v. Diapulse Corporation of 

America, 457 F.2d 25, 30 (2nd Cir. 1972) (‘‘It is [the trial court’s] duty to appraise the testimony 

and demeanor of the witnesses.’’); In re Pearson Bros. Co., 787 F.2d 1157, 1162 (7th Cir. 1986) 

(‘‘The question of credibility of witnesses is peculiarly for the trier of fact and an appellate court 

will not redetermine the credibility of witnesses where the trial court had the opportunity to 

observe their demeanor and form a conclusion.’’). 

Fourth, OCE’s Findings improperly make conclusions regarding 

the truth of statements made by cooperating witnesses, including 

Representative Graves. OCE’s authorizing resolution states that 

OCE’s findings shall not include ‘‘any conclusions regarding the validity of the allegations upon which it is based’’ or ‘‘guilt or innocence of the individual who is the subject of the review.’’ 271 Regrettably, in direct violation of this provision, OCE’s Findings conclude 

that Representative Graves demonstrated a ‘‘lack of candor’’ in his 

responses to OCE.272 OCE then compounds this error by extrapolating that alleged ‘‘lack of candor’’ into a tacit admission of guilt 

on the part of Representative Graves.273 Pursuant to OCE’s authorizing resolution, OCE’s Board has the authority to make findings, 

not OCE’s staff.274 However, no member of OCE’s Board was 

present at the interview of Representative Graves275 and accordingly no Board member was in a position to evaluate his credibility.276 Thus, even if this credibility determination were considered a ‘‘finding of fact’’ rather than a comment on culpability, there 

is no authority for such a determination to be delegated to or made 

by OCE’s staff.277

Fifth, while the Committee does not intend to suggest that OCE 

acted maliciously or in bad faith, it is a fact that OCE ignored and 

failed to disclose relevant information Representative Graves proVerDate Nov 24 2008 06:31 Nov 04, 2009 Jkt 053070 PO 00000 Frm 00049 Fmt 6659 Sfmt 6602 E:\HR\OC\HR320.XXX HR320

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278 H. Res. 895, section 1(c)(2)(C)(i)(III). 279 COS 00133. 280 COS 00151–COS 00156. 281 Id. 282See COS 00113; Memorandum of Interview of Brooks Hurst by OCE staff, July 13, 2009, 

¶ 23. 283OCE Findings, ¶ 3; see also OCE Findings, ¶ 75. 284See COS 00114; COS 00115. 285OCE Findings, ¶ 3; see also OCE Findings ¶ 75. 

vided to it. Along with its report and findings, OCE is ‘‘authorized 

and directed to’’ transmit ‘‘any supporting documentation’’ to the 

Standards Committee.278 During the course of OCE’s review, Representative Graves provided a memorandum to OCE.279 The memorandum was from Barry Pineles, Chief Counsel to the Republican 

staff of the Small Business Committee,280 and was directly relevant 

to several central issues in this matter. For example, the memorandum provided OCE with information about the jurisdiction of 

the Small Business Committee, the typical procedures for announcing hearing topics for the Small Business Committee, the typical 

procedures for identifying witnesses for Small Business Committee 

hearings, and the witness disclosure requirements for witnesses at 

Small Business Committee hearings.281 The Standards Committee 

is generally concerned that OCE’s Report and Findings do not mention this memorandum or address the contents of the memorandum. However, the Standards Committee is particularly disappointed that OCE did not forward the memorandum to the 

Standards Committee. As previously noted, OCE did not provide 

the Standards Committee with any ‘‘supporting documentation’’ in 

this matter. Unfortunately, such selective presentation of evidence 

to the Standards Committee raises significant concerns with the 

transparency of OCE’s process. 

Finally, after reviewing OCE’s Report and Findings, the Standards Committee discovered materials within OCE’s Report and 

Findings that were potentially favorable or exculpatory to Representative Graves. For example: 

a. Mr. Hurst told OCE in both a letter and during his interview with OCE that he does not have any business relationship with Representative Graves or Mrs. Graves.282 This statement is inconsistent with OCE’s allegation that an appearance 

of conflict of interest was created because ‘‘Representative 

Graves could expect [Mr. Hurst] to testify at the hearing in a 

manner consistent with Witness A’s and his own financial interest.’’ 283

b. Documents OCE collected from Mr. Hurst show that Mr. 

Hurst’s interest in Biofuels, LLC, is less than 1⁄3 of 1% and his 

interest in Golden Triangle Energy Cooperative, Inc. is just 

0.50%.284 The relatively small amount of these holdings is inconsistent with OCE’s allegation that Mr. Hurst’s and Representative Graves’ ‘‘shared financial interest’’ was such that 

‘‘Representative Graves could expect [Mr. Hurst] to testify at 

the hearing in a manner consistent with [Mr. Hurst]’s and his 

own financial interest.’’ 285

c. Mr. Hurst stated in an interview to OCE that he was the 

President of the Missouri Soybean Association and had testified at Congressional hearings on prior occasions. Mr. Hurst 

further stated that the first time he testified at a Congressional hearing, he was invited to testify by then-Representative 


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286See Memorandum of Interview of Brooks Hurst by OCE staff, July 13, 2009, ¶ 9. 287See OCE Findings, ¶¶ 3, 40, 41, 75. 288 Interview of Rep. Graves’ Counsel by Standards Committee staff, September 17, 2009. 289OCE Rule 4(F). 290Standards Committee Rule 25. 291Letter from Blake Chisam, Chief Counsel and Staff Director, to Rep. Graves, September 

16, 2009. 

Jim Talent.286 This statement is inconsistent with OCE’s implication that Mr. Hurst was not selected because of his qualification but only because of his ‘‘shared financial interest’’ with 

Representative Graves.287

The Standards Committee was disappointed when Representative Graves’ counsel informed the Standards Committee that Representative Graves was not provided a copy of OCE’s Findings nor 

any other materials, including the potentially favorable or exculpatory materials identified by the Standards Committee.288 The 

Standards Committee’s view was that, in the interests of justice, 

these potentially favorable or exculpatory materials should have 

been provided to Representative Graves,289 and that Standards 

Committee Rule 25 290 required the Standards Committee to disclose these materials to Representative Graves. For this reason the 

Standards Committee provided Representative Graves with a copy 

of OCE’s Report and Findings and directed Representative Graves 

to the existence of potentially favorable information in OCE’s Findings.291

VII. STATEMENT UNDER RULE 13, CLAUSE 3(c) OF THE 

RULES OF THE HOUSE OF REPRESENTATIVES 

The Standards 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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216 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 250 here 53070.179
217 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 251 here 53070.180
218 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 252 here 53070.181
219 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 253 here 53070.182
220 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 254 here 53070.183
221 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 255 here 53070.184
222 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 256 here 53070.185
223 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 257 here 53070.186
224 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 258 here 53070.187
225 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 259 here 53070.188
226 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 260 here 53070.189
227 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 261 here 53070.190
228 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 262 here 53070.191
229 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 263 here 53070.192
230 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 264 here 53070.193
231 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 265 here 53070.194
232 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 266 here 53070.195
233 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 267 here 53070.196
234 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 268 here 53070.197
235 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 269 here 53070.198
236 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 270 here 53070.199
237 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 271 here 53070.200
238 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 272 here 53070.201
239 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 273 here 53070.202
240 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 274 here 53070.203
241 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 275 here 53070.204
242 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 276 here 53070.205
243 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 277 here 53070.206
244 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 278 here 53070.207
245 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 279 here 53070.208
246 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 280 here 53070.209
247 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 281 here 53070.210
248 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 282 here 53070.211
249 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 283 here 53070.212
250 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 284 here 53070.213
251 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 285 here 53070.214
252 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 286 here 53070.215
253 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 287 here 53070.216
254 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 288 here 53070.217
255 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 289 here 53070.218
256 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 290 here 53070.219
257 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 291 here 53070.220
258 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 292 here 53070.221
259 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 293 here 53070.222
260 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 294 here 53070.223
261 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 295 here 53070.224
262 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 296 here 53070.225
263 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 297 here 53070.226
264 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 298 here 53070.227
265 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 299 here 53070.228
266 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 300 here 53070.229
267 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 301 here 53070.230
268 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 302 here 53070.231
269 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 303 here 53070.232
270 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 304 here 53070.233
271 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 305 here 53070.234
272 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 306 here 53070.235
273 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 307 here 53070.236
274 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 308 here 53070.237
275 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 309 here 53070.238
276 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 310 here 53070.239
277 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 311 here 53070.240
278 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 312 here 53070.241
279 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 313 here 53070.242
280 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 314 here 53070.243
281 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 315 here 53070.244
282 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 316 here 53070.245
283 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 317 here 53070.246
284 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 318 here 53070.247
285 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 319 here 53070.248
286 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 320 here 53070.249
287 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 321 here 53070.250
288 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 322 here 53070.251
289 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 323 here 53070.252
290 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 324 here 53070.253
291 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 325 here 53070.254
292 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 326 here 53070.255
293 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 327 here 53070.256
294 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 328 here 53070.257
295 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 329 here 53070.258
296 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 330 here 53070.259
297 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 331 here 53070.260
298 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 332 here 53070.261
299 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 333 here 53070.262
300 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 334 here 53070.263
301 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 335 here 53070.264
302 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 336 here 53070.265
303 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 337 here 53070.266
304 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 338 here 53070.267
305 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 339 here 53070.268
306 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 340 here 53070.269
307 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 341 here 53070.270
308 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 342 here 53070.271
309 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 343 here 53070.272
310 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 344 here 53070.273
311 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 345 here 53070.274
312 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 346 here 53070.275
313 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 347 here 53070.276
314 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 348 here 53070.277
315 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 349 here 53070.278
316 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 350 here 53070.279
317 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 351 here 53070.280
318 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 352 here 53070.281
319 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 353 here 53070.282
320 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 354 here 53070.283
321 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 355 here 53070.284
322 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 356 here 53070.285
323 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 357 here 53070.286
324 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 358 here 53070.287
325 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 359 here 53070.288
326 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 360 here 53070.289
327 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 361 here 53070.290
328 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 362 here 53070.291
329 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 363 here 53070.292
330 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 364 here 53070.293
331 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 365 here 53070.294
332 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 366 here 53070.295
333 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 367 here 53070.296
334 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 368 here 53070.297
335 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 369 here 53070.298
336 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 370 here 53070.299
337 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 371 here 53070.300
338 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 372 here 53070.301
339 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 373 here 53070.302
340 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 374 here 53070.303
341 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 375 here 53070.304
342 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 376 here 53070.305
343 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 377 here 53070.306
344 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 378 here 53070.307
345 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 379 here 53070.308
346 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 380 here 53070.309
347 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 381 here 53070.310
348 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 382 here 53070.311
349 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 383 here 53070.312
350 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 384 here 53070.313
351 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 385 here 53070.314
352 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 386 here 53070.315
353 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 387 here 53070.316
354 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 388 here 53070.317
355 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 389 here 53070.318
356 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 390 here 53070.319
357 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 391 here 53070.320
358 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 392 here 53070.321
359 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 393 here 53070.322
360 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 394 here 53070.323
361 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 395 here 53070.324
362 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 396 here 53070.325
363 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 397 here 53070.326
364 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 398 here 53070.327
365 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 399 here 53070.328
366 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 400 here 53070.329
367 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 401 here 53070.330
368 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 402 here 53070.331
369 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 403 here 53070.332
370 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 404 here 53070.333
371 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 405 here 53070.334
372 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 406 here 53070.335
373 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 407 here 53070.336
374 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 408 here 53070.337
375 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 409 here 53070.338
376 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 410 here 53070.339
377 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 411 here 53070.340
378 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 412 here 53070.341
379 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 413 here 53070.342
380 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 414 here 53070.343
381 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 415 here 53070.344
382 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 416 here 53070.345
383 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 417 here 53070.346
384 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 418 here 53070.347
385 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 419 here 53070.348
386 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 420 here 53070.349
387 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 421 here 53070.350
388 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 422 here 53070.351
389 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 423 here 53070.352
390 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 424 here 53070.353
391 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 425 here 53070.354
392 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 426 here 53070.355
393 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 427 here 53070.356
394 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 428 here 53070.357
395 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 429 here 53070.358
396 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 430 here 53070.359
397 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 431 here 53070.360
398 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 432 here 53070.361
399 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 433 here 53070.362
400 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 434 here 53070.363
401 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 435 here 53070.364
402 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 436 here 53070.365
403 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 437 here 53070.366
404 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 438 here 53070.367
405 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 439 here 53070.368
406 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 440 here 53070.369
407 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 441 here 53070.370
408 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 442 here 53070.371
409 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 443 here 53070.372
410 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 444 here 53070.373
411 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 445 here 53070.374
412 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 446 here 53070.375
413 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 447 here 53070.376
414 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 448 here 53070.377
415 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 449 here 53070.378
416 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 450 here 53070.379
417 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 451 here 53070.380
418 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 452 here 53070.381
419 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 453 here 53070.382
420 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 454 here 53070.383
421 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 455 here 53070.384
422 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 456 here 53070.385
423 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 457 here 53070.386
424 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 458 here 53070.387
425 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 459 here 53070.388
426 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 460 here 53070.389
427 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 461 here 53070.390
428 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 462 here 53070.391
429 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 463 here 53070.392
430 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 464 here 53070.393
431 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 465 here 53070.394
432 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 466 here 53070.395
433 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 467 here 53070.396
434 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 468 here 53070.397
435 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 469 here 53070.398
436 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 470 here 53070.399
437 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 471 here 53070.400
438 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 472 here 53070.401
439 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 473 here 53070.402
440 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 474 here 53070.403
441 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 475 here 53070.404
442 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 476 here 53070.405
443 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 477 here 53070.406
444 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 478 here 53070.407
445 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 479 here 53070.408
446 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 480 here 53070.409
447 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 481 here 53070.410
448 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 482 here 53070.411
449 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 483 here 53070.412
450 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 484 here 53070.413
451 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 485 here 53070.414
452 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 486 here 53070.415
453 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 487 here 53070.416
454 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 488 here 53070.417
455 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 489 here 53070.418
456 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 490 here 53070.419
457 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 491 here 53070.420
458 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 492 here 53070.421
459 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 493 here 53070.422
460 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 494 here 53070.423
461 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 495 here 53070.424
462 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 496 here 53070.425
463 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 497 here 53070.426
464 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 498 here 53070.427
465 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 499 here 53070.428
466 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 500 here 53070.429
467 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 501 here 53070.430
468 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 502 here 53070.431
469 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 503 here 53070.432
470 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 504 here 53070.433
471 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 505 here 53070.434
472 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 506 here 53070.435
473 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 507 here 53070.436
474 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 508 here 53070.437
475 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 509 here 53070.438
476 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 510 here 53070.439
477 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 511 here 53070.440
478 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 512 here 53070.441
479 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 513 here 53070.442
480 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 514 here 53070.443
481 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 515 here 53070.444
482 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 516 here 53070.445
483 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 517 here 53070.446
484 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 518 here 53070.447
485 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 519 here 53070.448
486 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 520 here 53070.449
487 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 521 here 53070.450
488 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 522 here 53070.451
489 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 523 here 53070.452
490 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 524 here 53070.453
491 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 525 here 53070.454
492 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 526 here 53070.455
493 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 527 here 53070.456
494 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 528 here 53070.457
495 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 529 here 53070.458
496 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 530 here 53070.459
497 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 531 here 53070.460
498 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 532 here 53070.461
499 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 533 here 53070.462
500 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 534 here 53070.463
501 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 535 here 53070.464
502 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 536 here 53070.465
503 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 537 here 53070.466
504 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 538 here 53070.467
505 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 539 here 53070.468
506 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 540 here 53070.469
507 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 541 here 53070.470
508 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 542 here 53070.471
509 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 543 here 53070.472
510 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 544 here 53070.473
511 


wwoods2 on DSK1DXX6B1PROD with REPORTSInsert offset folio 545 here 53070.474