" ! HOUSE OF REPRESENTATIVES 113TH CONGRESS

1st Session 

REPORT

113–266 

House Calendar No. 74 

IN THE MATTERS OF ALLEGATIONS 

RELATING TO TRAVEL TO TAIWAN BY 

REPRESENTATIVES WILLIAM OWENS AND 

PETER ROSKAM IN 2011 

R E P O R T 

OF THE

COMMITTEE ON ETHICS 

NOVEMBER 15, 2013.—Referred to the House Calendar and ordered to be 

printed 


pwalker on DSK7TPTVN1PROD with REPORTSE:\Seals\Congress.#13
IN THE MATTERS OF ALLEGATIONS RELATING TO TRAVEL TO TAIWAN BY REPRESENTATIVES 

WILLIAM OWENS AND PETER ROSKAM IN 2011 


pwalker on DSK7TPTVN1PROD with REPORTS
U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON : 

1 

85–584 

" ! HOUSE OF REPRESENTATIVES 113TH CONGRESS

1st Session 

REPORT

2013

113–266 

House Calendar No. 74 

IN THE MATTERS OF ALLEGATIONS 

RELATING TO TRAVEL TO TAIWAN BY 

REPRESENTATIVES WILLIAM OWENS AND 

PETER ROSKAM IN 2011 

R E P O R T 

OF THE

COMMITTEE ON ETHICS 

NOVEMBER 15, 2013.—Referred to the House Calendar and ordered to be 

printed 


pwalker on DSK7TPTVN1PROD with REPORTSE:\Seals\Congress.#13
(II) 

COMMITTEE ON ETHICS 

K. MICHAEL CONAWAY, Texas, 

Chairman 

CHARLES W. DENT, Pennsylvania 

PATRICK MEEHAN, Pennsylvania 

TREY GOWDY, South Carolina 

SUSAN W. BROOKS, Indiana 

LINDA T. SA ́ NCHEZ, California, 

Ranking Member 

PEDRO R. PIERLUISI, Puerto Rico 

MICHAEL E. CAPUANO, Massachusetts 

YVETTE D. CLARKE, New York 

TED DEUTSCH, Florida 

REPORT STAFF

THOMAS A. RUST, Interim Chief Counsel/Staff Director 

JACKIE M. BARBER, Counsel to the Chairman 

DANIEL J. TAYLOR, Counsel to the Ranking Member 

CLIFFORD C. STODDARD, JR., Senior Counsel 

BRITTANY M. BOHREN, Investigative Clerk 


pwalker on DSK7TPTVN1PROD with REPORTS
(III)

LETTER OF SUBMITTAL 

HOUSE OF REPRESENTATIVES, 

COMMITTEE ON ETHICS, 

Washington, DC, November 15, 2013. 

Hon. KAREN L. HAAS, 

Clerk, U.S. House of Representatives, 

Washington, DC. 

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

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

the attached report, ‘‘In the Matters of Allegations Relating to 

Travel to Taiwan by Representatives William Owens and Peter 

Roskam In 2011.’’ 

Sincerely, 

K. MICHAEL CONAWAY, 

Chairman. 

LINDA T. SA ́ NCHEZ, 

Ranking Member. 


pwalker on DSK7TPTVN1PROD with REPORTS

pwalker on DSK7TPTVN1PROD with REPORTS
(V) 

C O N T E N T S 

Page 

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

II. HOUSE RULES, LAWS, REGULATIONS, OR OTHER STANDARDS OF 

CONDUCT ..................................................................................................... 3 

III. FACTUAL BACKGROUND ............................................................................. 6 

IV. ANALYSIS ........................................................................................................ 16 

V. CONCLUSION .................................................................................................. 19 

VI. STATEMENT UNDER RULE XIII, CLAUSE 3(c) OF THE RULES OF 

THE HOUSE OF REPRESENTATIVES .................................................... 20 

APPENDIX A: REPORT AND FINDINGS OF THE OFFICE OF CONGRESSIONAL ETHICS RELATED TO REPRESENTATIVE WILLIAM OWENS 

(Review No. 12-8236) ........................................................................................... 21 

APPENDIX B: REPORT AND FINDINGS OF THE OFFICE OF CONGRESSIONAL ETHICS RELATING TO REPRESENTATIVE ROSKAM (Review 

No. 13-9784) .......................................................................................................... 175 

APPENDIX C: REPRESENTATIVE OWEN’S RESPONSE TO THE REPORT 

AND FINDINGS OF THE OFFICE OF CONGRESSIONAL ETHICS (Review No. 12-8236) ................................................................................................. 311 

APPENDIX D: REPRESENTATIVE ROSKAM’S RESPONSE TO THE REPORT AND FINDINGS OF THE OFFICE OF CONGRESSIONAL ETHICS 

(Review No: 13-9784) ........................................................................................... 327 


pwalker on DSK7TPTVN1PROD with REPORTS

pwalker on DSK7TPTVN1PROD with REPORTS
113TH CONGRESS REPORT " ! HOUSE OF REPRESENTATIVES 1st Session 113–266 

IN THE MATTERS OF ALLEGATIONS RELATING TO TRAVEL TO TAIWAN BY REPRESENTATIVES WILLIAM OWENS 

AND PETER ROSKAM IN 2011 

NOVEMBER 15, 2013—Referred to the House Calendar and ordered to be printed 

Mr. CONAWAY, from the Committee on Ethics, 

submitted the following 

R E P O R T 

I. INTRODUCTION 

In 2011, the Taipei Economic and Cultural Representative Office 

(TECRO), the representative of the Government of Taiwan in the 

United States, extended invitations to Representatives Bill Owens 

and Peter Roskam to travel to Taiwan as part of approved programs under the Mutual Educational and Cultural Exchange Act 

(MECEA). After TECRO extended the initial invitations, it was decided that the trips should be conducted under the House’s privately-sponsored travel rules and not MECEA. Shortly thereafter, 

the Chinese Culture University (CCU), a private university, agreed 

to sponsor separate trips for both Members and their wives. In this 

way, each Member’s trip was changed from a MECEA program to 

travel subject to the House’s officially-connected, privately-sponsored travel rules. Despite the change in the nature of the trips, 

TECRO—now apparently assisting CCU in TECRO’s capacity as 

the representative of the Government of Taiwan—remained involved in the planning and conduct of the trip. 

It is not improper for a private entity in a foreign country to rely 

on their government’s representative in Washington to assist them 

in communicating with the House of Representatives and this Committee, particularly where significant time differences and language barriers may exist. Therefore, the simple request for the 

Committee to work with TECRO did not, at that time, raise any 

particular red flags. 

Following the change in the nature of the trip, both Members 

sought and received approval from the Committee on Ethics (Committee) for themselves and their wives to participate in these privately-sponsored trips to Taiwan sponsored by CCU. However, it 

was not clear to the Committee at that time that the trips had iniVerDate Mar 15 2010 03:52 Nov 21, 2013 Jkt 008554 PO 00000 Frm 00009 Fmt 6659 Sfmt 6602 E:\HR\OC\HR266.XXX HR266

pwalker on DSK7TPTVN1PROD with REPORTS
2 

tially been planned and organized under the MECEA programs. It 

was only after the conclusion of the trip that the Committee became aware of this fact. 

The change from a MECEA program to a privately-sponsored trip 

was potentially problematic. The late change in the nature of the 

trips, without a significant change in the itinerary or involvement 

of the original sponsor, suggested that CCU may not have been a 

proper sponsor as defined under the privately-sponsored travel 

rules. Under the rules, sponsors must be involved in the planning 

and organizing of a trip. So called ‘‘money-only’’ sponsors are not 

permitted. 

Additionally, in the case of Representative Owens, Park Strategies, LLC was involved at various stages of the trip. At the time, 

Park Strategies was a registered foreign agent of TECRO. Lobbyists and foreign agents may assist with organizing MECEA trips. 

However, under the House’s privately-sponsored travel rules, lobbyists and foreign agents may only have de minimis involvement in 

the planning, organization, request, or arrangement of a one-day 

privately-sponsored travel and may have no involvement in multiday trips. After the trip was changed to privately-sponsored travel, 

Park Strategies reduced its involvement in the trip, but not sufficiently to comply with the privately-sponsored travel rules. In any 

event, the trip that they helped to plan, organize, request, and arrange as a MECEA trip was in fact the same trip that CCU was 

brought on to sponsor, with only minor variations. Shortly after 

these allegations became public, and before the Committee or the 

Office of Congressional Ethics initiated its review of the matter, 

Representative Owens personally paid back the costs of the trip. 

Beginning in the last Congress, the Committee undertook reviews of these two trips. The Office of Congressional Ethics (OCE) 

also reviewed the trips. On August 30, 2012, the OCE referred a 

report and findings to the Committee regarding Representative 

Owens’ trip. In its referral, the OCE recommended further review 

of the allegation that Representative Owens accepted travel expenses from an impermissible source. On February 6, 2013, the 

Committee published the OCE’s report and findings regarding Representative Owens as required by House Rule and continued its review of the allegations. On June 13, 2013, the OCE referred a report and findings to the Committee regarding Representative 

Roskam’s trip. In its referral, the OCE recommended further review of the allegation that Representative Roskam accepted travel 

expenses from an impermissible source. On September 11, 2013, 

the Committee published the OCE’s report and findings regarding 

Representative Roskam as required by House Rule and continued 

its review of the allegations. 

The Committee has completed its review of the allegations and 

unanimously concluded the following: 

1. The presently-available evidence is inconclusive as to whether 

CCU was a proper sponsor for the trips. Both Representatives 

Owens and Roskam, as well as Park Strategies, fully cooperated 

with the Committee’s investigation. Unfortunately, neither TECRO 

nor CCU agreed to cooperate with the Committee. Both entities 

possess information that is material to the Committee’s investigation. However, both entities are also outside of the Committee’s 

power to compel testimony. 


pwalker on DSK7TPTVN1PROD with REPORTS
3 

1 House Rule XXV, clause 5(d)(2); see also, House Ethics Manual (2008) at 89. N.B., the guidance in the House Ethics Manual applied to the trips under review in this report. However, that 

guidance was superseded when the Committee adopted new travel regulations at the end of the 

112th Congress. 

2. Representative Owens or his staff repeatedly sought guidance 

from the Committee regarding the trip to Taiwan. The presentlyavailable evidence shows that Park Strategies was involved in a 

more than de minimis manner in the planning, organizing, requesting, and arranging of his trip, and that they remained involved in 

the trip, even after it changed from a MECEA program to privately-sponsored travel. Representative Owens should have known 

that the trip was not a proper privately-sponsored trip because of 

the lobbying firm’s continued involvement, which the Committee 

was unaware of. For this reason, the payments by CCU for Representative Owens’ travel expenses were improper. When a Member or employee receives an impermissible gift, one appropriate 

remedy is repaying the market value of the gift. As noted previously, Representative Owens has already refunded the costs of 

his trip. 

3. As always, the Committee can only approve privately sponsored travel when the sponsors cooperate with the Committee’s 

oversight responsibilities. If a sponsor or its agent refuses to cooperate, the Committee will have no choice but to deny approval 

of a trip. However, the Committee has no jurisdiction over the 

MECEA programs and, therefore, any determinations regarding 

MECEA travel is a matter for the State Department to decide. 

Members are simply urged to exercise extreme caution when the 

nature or sponsor of a trip changes or is uncertain in any way. Indeed, the Committee notes that there are several different types of 

permissible official and officially-connected travel, each governed by 

a different set of rules and requirements. The differences between 

these types of travel can be confusing, and which set of rules apply 

to any particular trip may not be clear, particularly when outside 

groups are involved. Members and staff are encouraged to not necessarily rely on sponsors’ claims regarding compliance with the ethics rules, but instead to contact the Committee with all questions 

about such travel. 

The Committee’s review was incomplete because the information 

necessary to conduct a complete review was outside of the Committee’s reach. Therefore, because Representative Owens has voluntarily remedied the impermissible gift and there is insufficient evidence to show that Representative Roskam’s travel was improper, 

and after careful consideration, the Committee has unanimously 

voted to close the matter referred by the OCE; and agreed to end 

its review of this matter with the publication of this Report. 

II. HOUSE RULES, LAWS, REGULATIONS, OR OTHER 

STANDARDS OF CONDUCT 

A. HOUSE RULE XXV, CLAUSE 5

House Rule XXV, clause 5 (the Gift Rule), permits Members and 

staff to accept unsolicited travel expenses paid for by a private 

source under certain circumstances and only after pre-approval by 

the Committee.1 In 2007, the House Rules were amended to require House Members and employees to seek prior written apVerDate Mar 15 2010 03:52 Nov 21, 2013 Jkt 008554 PO 00000 Frm 00011 Fmt 6659 Sfmt 6602 E:\HR\OC\HR266.XXX HR266

pwalker on DSK7TPTVN1PROD with REPORTS
4 

2 House Rule XXV, clause 5(b)(1)(A) and (C). 

3 House Rule XXV, clause 5(c)(2); see also, House Ethics Manual (2008) at 89. 4 House Rule XXV, clause 5(b)(1)(C)(ii). See also, House Ethics Manual (2008) at 89. 5See Ethics Manual at 97. 6 House Ethics Manual (2008) at 73. 

proval of the Committee before accepting travel paid for by a private source, and the Committee adopted regulations to implement 

this new requirement. Pursuant to those rules and regulations, the 

Committee has conducted a thorough review of each proposed privately-sponsored trip. Committee staff recommends changes where 

necessary to bring trips into compliance with relevant laws, rules, 

or regulations and, on occasion, informs House Members and employees that a proposed trip is not permissible. 

A private sponsor is required to complete a Private Sponsor 

Travel Certification Form (Sponsor Form) and must certify that the 

information on the form is true, complete, and correct to the best 

of their knowledge. The Committee relies on the representations 

made on the travel forms as certified by the trip sponsor. The Committee recognizes both the significant benefit the public receives 

when their Representatives and their Representatives’ staff receive 

hands-on education and experience, as well as the mandate that 

outside groups be appropriately limited in what gifts and support 

they are allowed to provide to Members of Congress and congressional staff. 

The House Rules provide that if the traveler receives advance authorization from the Committee, the necessary travel costs ‘‘shall 

be considered a reimbursement to the House and not a gift prohibited by’’ the Gift Rule.2 One of the restrictions to the acceptance of 

such travel is that federally-registered lobbyists or registered foreign agents are banned from being involved in the planning, organizing, requesting, or arranging of most trips.3 Additionally, travel 

paid for by private sponsors who retain or employ lobbyists or foreign agents is limited to one day of officially-connected activity.4

A further factor the Committee considers when reviewing requests from Members and staff to accept privately sponsored travel 

is the source of funding for the trip. The House Ethics Manual 

states that 

Expenses may only be accepted from an entity or entities that have a significant role in organizing and conducting a trip, and that also have a clear and defined organizational interest in the purpose of the trip or location 

being visited. Expenses may not be accepted from a source 

that has merely donated monetary or in-kind support to 

the trip but does not have a significant role in organizing 

and conducting the trip.5

When a Member or employee receives a gift that is unacceptable 

under the Gift Rule, and for which a gift waiver is not available, 

the recipient generally must either return the gift or pay the market value of the gift.6 With regard to travel, when the Committee 

approves Members and staff to take privately-sponsored travel that 

is later determined to be impermissible, a variety of remedies may 

be appropriate. When neither the Committee nor the traveler had 

any reason to know of the factors that made the trip impermissible, 

and the violation was only of House rules, then reimbursement 


pwalker on DSK7TPTVN1PROD with REPORTS
5 

7See Report of the Committee on Ethics, In the Matter of Allegations Relating to Staff Travel 

Provided by the Turkish Coalition of America in August 2008, available at www.ethics.house.gov. 8See Report of the Committee on Ethics, In the Matter of the Investigation into Officially Connected Travel of House Members to Attend the Carib News Foundation Multinational Business 

Conferences in 2007 and 2008, available at www.ethics.house.gov (Carib News). 9 5 U.S.C. § 7342. 

10 22 U.S.C. §§ 2451 et seq. 11 House Rule XXV, clause 5(a)(3)(N). 12 House Ethics Manual at 109. 13 22 U.S.C. § 2452(a)(2)(i). 14 22 U.S.C. § 2458a(1). 15 House Ethics Manual at 110–111. 

may not be necessary.7 However when either the violation is of a 

statute or constitutional provision beyond the jurisdiction of the 

Committee, or when the Member or staff had reason to know of the 

impermissible factors and did not bring them to the attention of 

the Committee, then reimbursement or disgorgement of the cost of 

the trip or the specific impermissible reimbursements may be necessary to remedy the violation.8

B. GIFTS FROM FOREIGN GOVERNMENTS

Article 1, Section 9, Clause 8 of the United States Constitution, 

commonly referred to as the Emoluments Clause, prohibits federal 

government officials, including House Members and employees, 

from accepting ‘‘any present . . . of any kind whatever, from any 

. . . foreign State,’’ without the consent of Congress. Congress has 

consented through the vehicles of the Foreign Gifts and Decorations Act (FGDA) 9 and Mutual Educational and Cultural Exchange 

Act (MECEA).10 A Member, officer, or employee may accept travel 

expenses from a unit of foreign government only under one of these 

two statutory grants of authority. Any gift permitted by these statutes is also permitted by the House gift rule.11

With respect to travel, the FGDA allows House Members and 

employees to accept travel paid for by a foreign government only 

if the travel takes place entirely outside the United States. Such 

travel must also be consistent with the interests of the United 

States and must be permitted under FGDA regulations issued by 

the Ethics Committee.12

MECEA, on the other hand, authorizes the Secretary of State to 

approve cultural exchange programs that finance ‘‘visits and interchanges between the United States and other countries of leaders, 

experts in fields of specialized knowledge or skill, and other influential or distinguished persons . . . .’’ 13 However, the statute expressly states that: 

[T]he Congress does not consent to the acceptance by 

any Federal employee of any portion of any such grant or 

other form of assistance which provides assistance with respect to any expenses incurred by or for any member of 

the family or household of such Federal employee.14

Travel subject to an approved MECEA program is not subject to 

Committee pre-approval. However, all expenses must be paid by 

the foreign government host of the MECEA trip and none may be 

paid by any private source.15

It is the responsibility of a House Member or employee who accepts an invitation to travel to a foreign country to confirm that the 

expenses for travel to and from the United States are not paid by 


pwalker on DSK7TPTVN1PROD with REPORTS
6 

16 Id. at 111. 17See Appendix A, OCE Findings, Review No: 12-8236, Exhibit 2, page 1. 18 Id. 19 Id. 20 Id. 21 Id. 22 Id. 23 Id. 24 Id. 

a foreign government unless the trip is consistent with an approved 

MECEA program. To that end, the House Ethics Manual advises 

House Members and employees traveling on MECEA programs to 

ask for a copy of the letter from the State Department approving 

the program.16

III. FACTUAL BACKGROUND 

A. TRAVEL BY REPRESENTATIVE OWENS

1. Invitation to travel to Taiwan from TECRO 

During August 2011, Sean King, Vice President of Park Strategies, LLC, a lobbying firm, contacted Jon Boughtin, Senior Legislative Assistant to Representative Owens, to discuss the possibility 

of Representative Owens traveling to Taiwan. Park Strategies represented TECRO as a registered foreign agent. TECRO had an interest in Members of Congress visiting Taiwan. Representative 

Owens’ office began considering the travel proposal but did not 

commit at the time. Mr. King continued to contact Mr. Boughtin 

about the travel invitation into the fall. 

According to the OCE Report and Findings, Representative 

Owens told the OCE that the first time his traveling to Taiwan 

was mentioned was in July 2011 during ‘‘an introductory meeting 

with representatives from the Taiwan government.’’17 Representative Owens told the OCE that he had no further discussions about 

traveling to Taiwan until the fall of 2011 when he had a conversation with another Member about the possibility of traveling to Taiwan together.18 He recalled his having conversations with Park 

Strategies about traveling to Taiwan.19 Representative Owens told 

the OCE that it was explained that the trip was related to the 

‘‘Marcy Project’’ near his congressional district.20 Representative 

Owens explained to the OCE that the Marcy Project was, at the 

time, attempting to recruit the Taiwan Semiconductor Manufacturing Company (TSMC) to open a facility in Madison County, New 

York, near Representative Owens’ congressional district.21

Representative Owens also told the OCE that he believed he had 

a telephone conversation with former Senator Alphonse D’Amato, 

the Founder and Managing Director of Park Strategies, LLC, on 

October 6, 2011, during which Senator D’Amato inquired if he had 

any interest in going to Taiwan to meet with TSMC.22 Representative Owens told the OCE that after reviewing his calendar about 

the telephone call he believed Senator D’Amato’s firm represented 

Madison County in New York.23 Representative Owens was interested in the travel because Madison County would benefit from 

TSMC opening a facility there and would create jobs for Representative Owens’ constituents.24

According to Mr. Boughtin, Representative Owens became very 

interested in the prospect of TSMC opening such a facility and this 


pwalker on DSK7TPTVN1PROD with REPORTS
7 

25 Based on public disclosures, this trip appears to have been conducted pursuant to MECEA. 26Owens Production 04-000002. There is no record that the request for the advisory opinion 

was ever received by the Committee. 27 Id. 28 Id. 

resulted in his accepting the invitation from Park Strategies on behalf of TECRO to travel to Taiwan. 

At some point Mr. Boughtin contacted the Committee to ascertain if such a trip was permissible and was advised by Committee 

staff of the different ways in which a Member or employee may be 

permitted to travel. It was during this communication that Mr. 

Boughtin first learned of the MECEA program. On October 20, 

2011, Mr. King sent Mr. Boughtin an email describing a trip recently completed by another Congressman as an example of a trip 

that could be taken by Representative Owens.25 On October 26, 

2011, Mr. Boughtin emailed Mr. King and asked him if the trip 

would be covered under the MECEA program. Mr. King replied 

‘‘yes.’’ Mr. Boughtin told the Committee that because of the TSMC 

issue, Representative Owens decided to accept the invitation and 

was planning on traveling to Taiwan later in the year. Mr. 

Boughtin told the Committee that the TSMC issue was the driving 

force in Representative Owens deciding to travel to Taiwan. 

2. Invitation to travel to Taiwan from CCU 

Mr. King told the Committee that sometime between November 

15 and 21, 2011, the idea of Mrs. Owens traveling with Representative Owens was brought up. Mr. King told the Committee that he 

knew the travel would have to be handled through a different process if Mrs. Owens traveled as well. At some point Mr. Boughtin inquired of the Committee if a personal friend of Representative 

Owens could pay for Mrs. Owens to travel along with her husband. 

He recalled that either Representative Owens or his Chief of Staff, 

Bradley Katz, asked him to research the question. Since Representative Owens was traveling under MECEA, Mr. Boughtin was instructed to discuss Mrs. Owens’ travel with the State Department. 

An email from Mr. Boughtin to Representative Owens dated November 14, 2011, noted that he had been working with a Committee attorney on the trip and contained a draft request for an advisory opinion 26 from the Committee regarding whether Representative Owens may accept an unsolicited offer from a personal friend 

to cover the cost of Mrs. Owens’ travel while Representative Owens 

is on a MECEA trip. 

On November 29, 2011, CCU sent an invitation to Representative Owens and his wife to travel to Taiwan from December 27 to 

31, 2011, as guests of CCU. There was no evidence presented to the 

Committee that CCU had contacted Representative Owens or any 

member of his staff before this invitation was sent. 

Representative Owens told the OCE that he understood the role 

of TECRO was ‘‘working to establish the agenda’’ for the trip and 

he assumed the government of Taiwan was paying for the trip.27

He realized that the payment arrangements for the trip had 

changed once he received the invitation letter from CCU.28 He did 

not have any communications with CCU regarding the trip but did 

recall participating in a lunch during the trip in which four CCU 

officials attended and that one of the CCU deans attended a dinner 


pwalker on DSK7TPTVN1PROD with REPORTS
8 

29 Id. 30While Representative Owens did request from the sponsor that they add this meeting to 

the itinerary, there is no indication that the meeting, which occurred in Taipei on a day that 

he was already there, added any cost to the trip. Therefore, there is no apparent solicitation 

issue with this request. 31Owens Production at 03–000061. 32Owens Production at 02–001128. 

the following night hosted by the Taiwan Foreign Minister.29 Representative Owens was escorted throughout his visit by an official 

of the Taiwan Ministry of Foreign Affairs (MOFA). 

In a written submission to the Committee, Park Strategies told 

the Committee that, once the decision was made to change the trip 

to privately sponsored travel, they were no longer involved in the 

travel planning, even though they maintained contact with Mr. 

Boughtin to see how the planning was going. Contrarily, in an 

interview with the Committee, Mr. King said that he reported to 

Benson Wang from TECRO that he met with Representative 

Owens on December 5, 2011, specifically to discuss the trip. Mr. 

Boughtin remembered Mr. King’s visit on December 5, 2011, and 

stated it was a limited discussion about the trip and the TSMC 

meeting but that Representative Owens just stopped by to say 

hello. 

3. Itinerary and TSMC 

Mr. Boughtin told the Committee that he met frequently with 

Frank Lee and Mr. Wang to plan the itinerary for the trip. He indicated that early on in the process Representative Owens made it 

clear that he wanted to visit with TSMC officials while he was in 

Taiwan.30 TECRO officials, through MOFA, were attempting to arrange the meeting between TSMC and Representative Owens, but 

explained that due to the holidays it may not be possible. According 

to Mr. Boughtin, Representative Owens made it very clear that the 

TSMC meeting was the most important part of the trip and that 

either Representative Owens or Bradley Katz instructed Mr. 

Boughtin to contact Mr. King and Park Strategies to assist in arranging the meeting. Mr. Boughtin stated that it was known by 

Representative Owens that Park Strategies had a relationship with 

TSMC. A review of emails between Mr. Boughtin and Mr. King and 

Mr. Boughtin and Representative Owens indicated that the TSMC 

meeting was still in question on December 26, 2011, the day before 

Representative Owens was to travel to Taiwan. On December 20, 

2011, Mr. Boughtin forwarded an email from TECRO official LiChih Cheng indicating that her colleague in Taipei was unable to 

set up the meeting with TSMC. Mr. King responded that he would 

‘‘see what our Taipei staff can work out, stay tuned.’’ 31

Mr. Boughtin told the Committee that the meeting with TSMC 

was very important, as indicated in Representative Owens’ email 

to Mr. Boughtin on December 25, 2011, in which he asks why the 

meeting with TSMC (‘‘the chip comp’’) is not on the schedule. After 

Mr. Boughtin responds that Mr. King is waiting to hear back from 

TSMC, Representative Owens responds, ‘‘TSMC is really important.’’ 32 When asked if Representative Owens would have cancelled 

the trip if the TSMC meeting could not be arranged Mr. Boughtin 

replied that he would not have cancelled it the day before the trip. 

When asked if Representative Owens would have cancelled the trip 

if it was known a couple of weeks before the trip that the meeting 


pwalker on DSK7TPTVN1PROD with REPORTS
9 

33 At any one time, it is not unusual for the Committee to be reviewing separate, unrelated 

requests for travel to the same country offered by different sponsors. The Committee’s staff of 

advice and education attorneys reviewed over 2,000 requests for privately sponsored travel in 

2011, and handled over 20,000 phone calls and emails seeking informal guidance for a wide variety of situations, including the many ways Members and staff can accept travel. 

with TSMC could not be arranged, he responded that it was possible. Mr. Boughtin emphasized that the meeting with TSMC was 

the reason for Representative Owens taking the trip. 

4. Committee review 

On December 7, 2011, Representative Owens’ office submitted 

the travel forms necessary for the Committee to review his travel 

to Taiwan. On the final version of the Privately Sponsored Travel: 

Traveler Form (Traveler Form) dated December 16, 2011, Representative Owens’ explanation for why the travel was related to 

his official duties was that he was ‘‘interested in engaging a company that has expressed interest in hiring employees in my district. This Taiwanese company stands to benefit my constituents by 

relocating to a site near my district and I would like to engage 

them to help promote this opportunity.’’ On the initial version of 

the Traveler Form dated December 6, 2011, Representative Owens’ 

explanation as to why the travel is related to his official duties was 

‘‘Opportunity to explore economic development opportunities for upstate New York, as well as defense and security related issues.’’ 

The package also included a Sponsor Form which indicates the 

sponsor for the Taiwan trip from December 27, 2011, through January 1, 2012, was CCU. CCU’s organizational interest in sponsoring the trip, entered in question 13 of the Sponsor Form, was 

‘‘The Chinese Culture University aims to promote international, 

cultural exchanges in order for it to thrive in a world increasingly 

engineered by an irresistible thrust towards globalization.’’ 

Neither of these forms asks if lobbyists or foreign agents were 

ever involved in the trip, or if lobbyists or registered foreign agents 

employed and retained by another party were involved in the trip. 

Therefore, there were no false representations in the forms that 

concealed the involvement of Park Strategies. Given the additional 

information the Committee now has, it is questionable whether 

CCU fits within the definition of a permissible sponsor under the 

Committee’s travel regulations, but there are no clear or unambiguous false statements on these forms. 

Representative Owens or his staff repeatedly sought guidance 

from the Committee regarding the trip to Taiwan. However, Committee Counsel assigned to the trip who had spoken with Representative Owens’ staff about the MECEA trip and whether a personal friend could pay for Mrs. Owens’ travel, did not realize when 

he happened to be assigned the privately sponsored trip approximately one month later, that this was in essence the same trip 

with little or no attenuation.33 All the representations the Committee received from CCU and on the sponsor forms, including that 

CCU did not retain or employ a registered lobbyist or foreign 

agent, indicated this was a permissible privately sponsored trip. 

The Committee was not aware at the time of the role Park Strategies played in the proposed MECEA trip or of the lobbying firm’s 

continued involvement after it became a privately sponsored trip, 


pwalker on DSK7TPTVN1PROD with REPORTS
10 

34See Appendix A, Exhibits 17, 18. 

nor did it have any reason in December 2011 to question whether 

CCU was a ‘‘money only’’ sponsor. 

5. Representative Owens’ travel to Taiwan 

Representative Owens went on the trip to Taiwan, which followed the itinerary submitted to the Committee for pre-travel approval. The events listed on the trip itinerary provided to the Committee by Representative Owens for the pre-travel review are not 

dissimilar to events on other itineraries for privately sponsored 

travel to Taiwan that have been approved by the Committee. However, it was determined only during this investigation that TECRO, 

with the assistance of Park Strategies, developed the initial 

itinerary for the trip and that itinerary, except for the visit to 

CCU, remained essentially the same when submitted to the Committee. 

6. Questions regarding funding of the trip 

The OCE reported interviewing one or more witnesses who 

claimed that the Taiwan Ministry of Foreign Affairs actually paid 

for the airfare and hotel of Representative Owens.34 Notwithstanding this testimony, on numerous prior, similar trips to Taiwan sponsored by private entities, the Committee has inquired and 

been assured that the private sponsor was paying all expenses out 

of its general funds, with no grants or reimbursements. These assurances came from the private sponsors for each trip and, with regard to one trip, also from TECRO’s representative, Gordon Yang. 

It also appears that at least some of the information provided to 

the OCE regarding this question was recanted. 

As discussed more fully below, the Committee was unable to receive clarifying information from either TECRO or CCU with regards to the trips taken by Representatives Roskam and Owens. At 

best, the current evidence regarding whether the Taiwanese government may have funded part or all of these trips is contradictory 

and therefore inconclusive. While disturbing with regard to the actions of TECRO and the private sponsors, such inconclusive evidence is insufficient to hold either Member accountable for reimbursement on that basis alone. 

B. TRAVEL BY REPRESENTATIVE ROSKAM

1. Invitation to travel to Taiwan from TECRO 

Mike Dankler, Legislative Assistant to Representative Roskam, 

told the OCE that he has discussed Representative Roskam traveling to Taiwan with officials from TECRO since 2009. On May 13, 

2011, Mr. Yang sent a blanket email of which Mr. Dankler was a 

recipient, inviting various Members of Congress to travel to Taiwan 

during June or July, 2011. The invitation, shown below, did not invite any particular Members, but made it clear that the invitation 

was for Members and staff and would be organized under the 

MECEA program. 


pwalker on DSK7TPTVN1PROD with REPORTS
11 

35 As that Member is no longer a Member of the House of Representatives, the Committee 

did not review his travel to Taiwan for potential violations, and makes no findings or conclusions regarding that trip. 

2. Invitation to travel to Taiwan from CCU 

Shortly after the TECRO extended the invitation to Representative Roskam, the idea of Mrs. Roskam traveling with Representative Roskam was brought up. On May 16, 2011, Mr. Yang sent an 

email to Mr. Dankler stating, ‘‘We welcome Congressman and Mrs. 

Roskam to visit Taiwan. In that case, we need to go through 

priovate [sic] sponsor and the House ethics committee for clearance, which require your confirmation to join the trip at least ONE 

month ahead of its departure . . .’’ 

After receiving Mr. Yang’s email, Mr. Dankler sent another email 

asking if the trip was the same as the one Representative Roskam 

had been invited to attend earlier by another Member. Mr. Yang, 

in a response email, confirmed it was the same trip that TECRO 

worked together with other Members to organize. Mr. Yang told 

Mr. Dankler that only one Member and that Member’s spouse attended the previous trip during the April recess.35


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 18 here 85584.001
12 

36THPRl000314. 37THPRl000317. 38THPRl000319. While Representative Roskam did request from the sponsor that they add 

this meeting to the itinerary, there is no indication that the meeting, which occurred in a town 

that other members had travelled to as part of similar trips, added any cost to the trip. Therefore, there is no apparent solicitation issue with this request. 39THPRl000323. 

A review 36 of Committee records disclosed travel to Taiwan 

taken by that Member in 2011, which was sponsored by Fu Jen 

Catholic University. Mr. Dankler sent an email to Representative 

Roskam regarding Mr. Yang’s response. 

Following this email,37 on May 27, 2011 Mr. Dankler emailed 

Mr. Yang: ‘‘Congressman Roskam’s daughter will be teaching 

English in Taiwan for about 6 months beginning in June and asked 

if they could adjust the itinerary to include a trip to visit his 

daughter in Tsaoton, Nantou County, Taiwan.’’ 38 Mr. Yang responded: ‘‘Mike—That will be no problem at all. We can make any 

arrangement to accommodate the Congressman’s interests.’’ 39

Representative Roskam told the OCE he recalled indicating that 

he wanted to visit his daughter who was teaching in Taiwan at the 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 19 here 85584.002 Insert offset folio 19 here 85584.003
13 

40 Id. at 3. 41THPRl000373. 42See Appendix B, OCE Findings, review No. 13–9784, Exhibit 3 at 2. 

time and that his wife accompanied him on the trip but did not recall when that was decided.40 Representative Roskam, through his 

staff, also indicated that he wanted his daughter to accompany him 

and his wife in Taipei. While Mr. Yang offered to pay for the expenses of Representative Roskam’s daughter, Mr. Dankler, much to 

his and Representative Roskam’s credit, replied that he had 

checked on that issue with the Ethics Committee and that Representative Roskam was required to and would personally pay for 

any added expense resulting from his daughter’s presence. 

Mr. Dankler continued to communicate and meet with Mr. Yang 

in June 2011. On June 7, 2011, Representative Roskam asked Mr. 

Dankler to move the dates of the Taiwan trip to July 17–23, 2011. 

Mr. Dankler passed this request on to Mr. Yang and the trip dates 

were changed. In Mr. Dankler’s email to Mr. Yang, Mr. Dankler 

wrote, ‘‘Great news! I just got the green light to move forward with 

the trip. Whenever you have the ethics paperwork, just let me 

know.’’ 41

Mr. Dankler subsequently asked Mr. Yang for an itinerary for 

the trip. After he received it, Mr. Dankler sent Representative Roskam the following email. Representative Roskam’s daughter’s name 

is Gracey. 

After this email, there continued to be communication between 

Mr. Dankler and Mr. Yang about the trip, and Mr. Yang pressed 

Mr. Dankler to find a couple of other Members who would be interested in going on the trip. 

CCU provided a letter dated June 15, 2011, inviting Representative Roskam and his wife to travel to Taiwan in July and then sent 

a subsequent letter dated September 2, 2011, inviting Representative Roskam and his wife to travel to Taiwan on October 15, 2011. 

Representative Roskam told the OCE that he did not recall having 

any discussions with anyone about the source of funding for his 

trip to Taiwan, and believed that there were two sponsors for the 

trip, the Government of Taiwan and the Chinese Culture University.42


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 21 here 85584.004
14 

Even after CCU officially became the sponsor on June 15, 2011, 

all communications regarding the trip were between TECRO and 

Mr. Dankler. Other than the two general letters of invitation, there 

were no other communications between Representative Roskam’s 

office and CCU regarding the travel. Both Mr. Dankler and Representative Roskam told the OCE that they had no contact with 

anyone from CCU other than the time Representative Roskam 

spent with CCU officials during the actual trip. 

In early July 2011 the trip was postponed due to changes in the 

congressional schedule. Mr. Dankler sent Mr. Yang an email on 

July 8, 2011, notifying him of the change and the need to postpone 

the trip. Initially the trip was rescheduled for September 2011 but 

again was postponed at the request of Representative Roskam until 

October 15 through 22, 2011. A new letter from CCU dated September 2, 2011, was submitted to the Committee along with the required travel forms. During this time Mr. Dankler continued to 

communicate with Mr. Yang about the trip while there does not appear to be any communication between Representative Roskam’s 

office and CCU. In fact, on August 5, 2011, Mr. Yang sent the following email indicating that TECRO, and not CCU, was still the 

primary entity involved in scheduling the trip. No one at CCU is 

included on this or any other email discussing the trip. 

3. Committee review 

Prior to participating in the trip Representative Roskam sought 

and received the Committee’s approval of the trip. Following the 

Committee’s privately-sponsored travel regulations, Representative 

Roskam submitted to the Committee both the Traveler Form and 

the Sponsor Form. The Sponsor Form, which allegedly was prepared by CCU, was provided to Representative Roskam’s office by 

officials at TECRO. CCU’s organizational interest in sponsoring the 

trip, entered in question 13 of the Sponsor Form, was ‘‘The Chinese 

Culture University pays much attention to international culture exchanges so that it could thrive in a world increasingly engineered 

by an irresistible thrust towards globalization.’’ In question 8 of the 

Traveler Form, Representative Roskam explained why his participation in the trip is related to his official duties: ‘‘Taiwan is an important trade partner of the U.S. As a member of the Ways and 

Means Committee, this trip will further my understanding of the 

trade relationship and the security issues that affect it.’’ Given the 

additional information the Committee now has, it is questionable 

whether CCU fits within the definition of a permissible sponsor 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 22 here 85584.005
15 

43 It is not improper for a private entity in a foreign country to rely on their governent’s representative in Washington to assist them to communicate with the House of Representatives 

and this Committee, particularly where significant time difference and language barriers may 

exist. Therefore the simple request for the Committee to work with TECRO did not, at that 

time, raise any particular red flags. 44 If Representative Roskam had simply been left on his own to spend time with his family 

for two days, Committee staff would have simply advised that such activity was personal and 

not officially connected. Members may include such personal activity, but must pay lodging, 

meals, and all other expenses on their own, and if the period of personal travel exceeds official 

travel, then the traveler must pay half of the roundtrip airfare themselves. However, after inquiring further, it appears that Representative Roskam did always intend to engage in the officially connected activity, but to have his wife and daughter accompany him, as discussed above. 

under the Committee’s travel regulations, but there are no clear or 

unambiguous false statements on these forms. 

The Sponsor Form indicates CCU was the sponsor of the trip. 

However, Gordon Yang was identified to the Committee by Mr. 

Dankler as his point of contact for the trip.43 Committee staff scrutinized the itinerary to make sure that the cultural experiences had 

a sufficient and permissible officially connected purpose and asked 

TECRO’s representative several questions regarding that part of 

the trip. The purpose for travelling to Tsaoton Township was described as seeing a small rural county like the heartland of the 

Midwest and that it has a relationship with his constituents in the 

U.S. including that teachers were connected with constituents and 

that Representative Roskam had a particular interest in education. 

TECRO did mention that Representative Roskam’s daughter was 

also a teacher. Committee Counsel did not understand TECRO’s 

representative to be stating that Representative Roskam’s daughter 

was teaching in Taiwan. 

The purposes of visiting the Sun Moon Lake National Scenic 

Area and its surroundings were described to Committee staff as 

seeing water conservation work being done there and relations 

with minority groups, respectively. These are legitimate reasons for 

private sponsors to include these types of visits on officially connected itineraries if the sponsor so chooses. Indeed, awareness of 

such issues across the world is an important part of any Member’s 

fact finding to assist them in considering similar or connected 

issues in their own district and our nation at large. Not only are 

these legitimate purposes, but another trip sponsored with 

TECRO’s assistance by a different Taiwanese private university in 

April of 2011, and several earlier trips, had the same visits to Sun 

Moon Lake National Scenic area on their itinerary, with no known 

connection to the children of that Member. In fact almost every trip 

sponsored (nominally at least) by CCU and another private university in Taiwan since 2007 has included a high speed rail journey 

to an area outside of Taipei, including several to Sun Moon Lake. 

Still, the rationale of having ‘‘leisure’’ or ‘‘quality time’’ with one’s 

family in ‘‘a very nice resort area’’ as discussed in the background 

on the trip is not a permissible officially connected purpose for privately sponsored travel and if Committee staff had been aware of 

that connection and intent, additional questions would have been 

asked, at least.44 The Committee, however, was not aware of that 

possible piece of the rationale until it reviewed the email described 

above in the materials provided to the Committee by Representative Roskam as part of this investigation. In the end, Representative Roskam did certify on his post-travel paperwork that he did 

attend all of the legitimate and regular educational and fact-finding locations on the itinerary, as had Members before him. The 


pwalker on DSK7TPTVN1PROD with REPORTS
16 

45 Id. at 4. 46 Id. at 4. 47 Id. at Exhibit 20. 48See Ethics Manual at 97. 

mere fact that his wife and daughter were with him does not diminish the value of the fact finding activity or make the activities 

impermissible. 

4. Representative Roskam’s travel to Taiwan 

Representative Roskam went on the trip to Taiwan, which followed the itinerary submitted to the Committee for pre-travel approval. As with Representative Owens, the itinerary provided to 

the Committee by Representative Roskam also included events 

similar to other privately sponsored travel to Taiwan. Again, the 

Committee determined only during this investigation that the 

itinerary appears to have been prepared by TECRO. Representative Roskam told the OCE that he only recalled meeting with CCU 

officials for about three hours on one day of the trip, when he met 

with the President of CCU and toured the campus and a museum 

on the campus.45 Representative Roskam indicated Frank Lee, 

from TECRO, escorted him and his wife for part of the trip. He 

added there were ‘‘many people’’ who escorted his party during the 

trip but did not know if any of them were from CCU.46

C. TECRO’S AND CCU’S REFUSAL TO COOPERATE

Both CCU and TECRO declined to participate in the OCE’s and 

the Committee’s investigations of these matters. On June 30, 2012, 

CCU sent an email to the OCE in which CCU claimed that it asked 

for TECRO’s assistance in arranging the trips.47 TECRO declined 

to participate with the Committee’s investigation citing their agreement with the American Institute in Taiwan. The Committee requested CCU’s cooperation with its investigation. CCU Director of 

Public Relations, Hsing-Hsia Yuan responded via email. In his response to the Committee, CCU declined to cooperate with the Committee’s investigation noting as part of the reason that they were 

aware that TECRO would not cooperate with the Committee. 

IV. ANALYSIS 

1. Money-only sponsor 

The Committee provides guidance to members and staff related 

to the acceptance of travel from private sources in the House Ethics 

Manual. One of the factors the Committee considers when reviewing requests from Members and staff to accept privately sponsored 

travel is the source of funding for the trip. The Ethics Manual 

states that 

Expenses may only be accepted from an entity or entities that have a significant role in organizing and conducting a trip, and that also have a clear and defined organizational interest in the purpose of the trip or location 

being visited. Expenses may not be accepted from a source 

that has merely donated monetary or in-kind support to 

the trip but does not have a significant role in organizing 

and conducting the trip.48


pwalker on DSK7TPTVN1PROD with REPORTS
17 

It is clear based on the evidence reviewed by the Committee that 

both of these trips began as an invitation to participate in travel 

under the MECEA program from TECRO, the representative of the 

Government of Taiwan in the United States. At the time of the 

trips, the Government of Taiwan had an agreement with the State 

Department to provide such travel under the MECEA program. 

The Government of Taiwan still has such an agreement. Both Representative Roskam and Representative Owens were invited by 

TECRO officials, and the invitations made it clear that it was the 

Government of Taiwan, and not any private party, that was making the invitations. While the Committee was aware that TECRO 

was involved in each trip, the Committee had been given the impression by TECRO and CCU or other Taiwanese sponsors, on numerous occasions, that such assistance was the kind of perfectly 

appropriate assistance that a nation’s embassy, or a state’s representative may provide to their citizens who are not physically located in this country and who may have significant communications hurdles. 

However, after Committee reviewing these two trips, it appears 

to the Committee that TECRO and the Ministry of Foreign Affairs 

remained completely involved in the planning and organization of 

these trips. CCU’s only involvement with the actual itinerary appears to have been meeting with the Members during a few hours 

of the trips. CCU claims to have been the source of funding for the 

trip, but due to their refusal to cooperate with the Committee’s investigation it is unclear if the funding actually came from CCU. 

Even if CCU paid for the trips for both Representative Roskam and 

Representative Owens and their wives, due to their lack of involvement in the planning, organization or even conduct of the trip, 

CCU’s involvement appears to be little more than providing the 

funding for the trips. 

Based on the evidence before the Committee, and the fact that 

both TECRO and CCU refused to cooperate with the Committee’s 

investigation, the Committee cannot determine whether CCU’s involvement in both trips was significant enough for CCU to be considered a legitimate sponsor. 

At the same time, this is the kind of information the Committee 

seeks directly from sponsors to carry out its role assigned by House 

Rules to review and approve requests to accept privately sponsored 

travel. Indeed, there are several different types of permissible official and officially-connected travel, each governed by a different set 

of rules and requirements. The differences between these types of 

travel can be confusing, and which set of rules apply to any particular trip may not be clear, particularly when outside groups are 

involved. While the Committee would hope that Members and staff 

be alert enough to raise any red flags or abnormalities to the Committee, and thus avoid the need for investigations such as these 

after the fact, without a careful reading of the Committee’s manual 

and travel regulations, the Members and staff are not normally 

alerted to this issue. For this reason it is not fair to say that the 

Members in this circumstance had reason to know that CCU might 

not be a permissible sponsor, particularly given the Committee’s 

own difficulty with reaching a conclusion on the question with the 

available facts and evidence. 


pwalker on DSK7TPTVN1PROD with REPORTS
18 

49See House Ethics Manual (2008), at 89, 401. 50 Id. at 90. 51 As with other elements of these trips, the Committee had no knowledge of or reason to suspect Park Strategies’ involvement at the time the trip was approved. 

2. Lobbyist involvement in travel 

During the 110th Congress, the travel provisions of the House 

gift rule were substantially revised to impose new restrictions and 

requirements on officially-connected travel paid for by a private 

source. Included in these changes is House Rule XXV, clause 

5(c)(3), which states: 

A Member, Delegate, Resident Commissioner, officer, or 

employee of the House may not accept a reimbursement 

(including payment in kind) for transportation, lodging, or 

related expenses for a trip (other than a trip permitted 

under paragraph (b)(1)(C) of this clause) if such trip is in 

any part planned, organized, requested, or arranged by a 

registered lobbyist or agent of a foreign principal. 

While entities that retain or employ a lobbyist or a foreign agent 

may sponsor one-day trips, the involvement of lobbyists or foreign 

agents must be de minimis, which was defined by the Committee 

at the time of these trips as ‘‘only negligible or otherwise inconsequential in terms of time and expense of the overall planning and 

purpose of the trip.’’ 49 Lobbyist involvement in planning, organizing, requesting or arranging multiple-day trips is also prohibited.50 In addition, the Rule does not limit the prohibition on planning, organizing, requesting or arranging only to lobbyists or foreign agents retained by the primary sponsor of the trip. However 

MECEA trips, which are regulated and overseen by the State Department and not the Committee or the House, do permit the involvement of lobbyists and foreign agents. 

The evidence in Mr. Owens’ trip demonstrates that registered 

lobbyists and foreign agents from Park Strategies were intimately 

involved in planning, organizing, requesting, and arranging the 

trip. This involvement was most prominent when the trip was still 

supposed to be conducted pursuant to MECEA. As noted above, at 

the time this trip was a MECEA trip, such involvement was permitted by the Department of State. However, as discussed elsewhere in this report, the evidence suggests that there was no real 

attenuation of the organization of the trip when it was altered from 

a MECEA trip, to a privately sponsored trip. Therefore the work 

that Park Strategies did to plan, organize, request and arrange the 

trip as a MECEA trip carried over to the privately-sponsored trip, 

making the private sponsorship impermissible.51 Furthermore, despite the testimony of a Park Strategies employee that, in substance, they knew they could not be involved in the planning and 

organizing of a privately-sponsored trip and therefore stepped back 

from that role, the evidence indicates that they were still engaged 

in setting specific meetings on the itinerary, and they were still 

billing TECRO for their involvement with this trip. For all of these 

reasons, Mr. Owens’ trip was impermissible pursuant to House 

Rules. 


pwalker on DSK7TPTVN1PROD with REPORTS
19 

52See Report of the Committee on Ethics, In the Matter of Allegations Relating to Staff Travel 

Provided by the Turkish Coalition of America in August 2008, available at 

www.ethics.house.gov. 53See Report of the Committee on Ethics, In the Matter of the Investigation into Officially Connected Travel of House Members to Attend the Carib News Foundation Multinational Business 

Conferences in 2007 and 2008, available at www.ethics.house.gov. 

V. CONCLUSION 

When the Committee approves and Members and staff attend 

privately-sponsored travel that is later determined to be impermissible, a variety of remedies may be appropriate. When neither the 

Committee nor the traveler had any reason to know of the factors 

that made the trip impermissible, and the violation was only of 

House rules, then reimbursement may not be necessary.52 However 

when either the violation is of a statute or constitutional provision 

beyond the jurisdiction of the Committee, or when the Member or 

staff had reason to know of the impermissible factors and did not 

bring them to the attention of the Committee, then reimbursement 

or disgorgement of the cost of the trip may be necessary to remedy 

the violation.53

Representative Owens or his staff repeatedly sought guidance 

from the Committee regarding the trip to Taiwan. The presentlyavailable evidence shows that Park Strategies was involved in a 

more than de minimis manner in the planning, organizing, requesting, and arranging of his trip, and that they remained involved in 

the trip, even after it changed from a MECEA program to privately-sponsored travel. Representative Owens should have known 

that the trip was not a proper privately-sponsored trip because of 

the lobbying firm’s continued involvement, which the Committee 

was unaware of. For this reason, the payments by CCU for Representative Owens’ travel expenses were improper. When a Member or employee receives an impermissible gift, one appropriate 

remedy is repaying the market value of the gift. As noted previously, Representative Owens has already refunded the costs of 

his trip. 

Because Representative Owens has voluntarily remedied the impermissible gift and there is insufficient evidence to show that Representative Roskam’s travel was improper, the Committee will consider this matter closed. 

Finally, both TECRO and CCU were notified that for the Committee to fulfill its responsibilities to review offers of privatelysponsored travel, the Committee must have the cooperation of the 

sponsors. Both TECRO and CCU declined to provide such cooperation. As always, the Committee can only approve privately sponsored travel when the sponsors cooperate with the Committee’s 

oversight responsibilities. If a sponsor or its agent refuses to cooperate, the Committee will have no choice but to deny approval 

of a trip. However, the Committee has no jurisdiction over the 

MECEA programs and, therefore, any determinations regarding 

MECEA travel is a matter for the State Department to decide. 

Members are simply urged to exercise extreme caution when the 

nature or sponsor of a trip changes or is uncertain in any way and 

to contact the Committee with all questions about such travel. 

The Chair is directed, upon providing the notices required pursuant to House Rule XI, clause 3(b)(8)(A), and Committee Rule 

17A(a)(2), to file this report with the House, together with copies 


pwalker on DSK7TPTVN1PROD with REPORTS
20 

54 House Rule XI, clauses 3(a)(2) and 3(b). 

of the OCE’s Reports and Findings in this matter.54 The filing of 

this report, along with its publication on the Committee’s Web site, 

shall serve as publication of the OCE’s Reports and Findings in 

these matters, pursuant to House Rule XI, clause 3(b)(8)(A), and 

Committee Rule 17A(b)(3) and 17A(c)(2). 

VI. STATEMENT UNDER RULE XIII, CLAUSE 3(c) OF THE 

RULES OF THE HOUSE OF REPRESENTATIVES 

The Committee made no special oversight findings in this report. 

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

measure in this report. 


pwalker on DSK7TPTVN1PROD with REPORTS
(21) 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 29 here 85584.006
22 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 30 here 85584.007
23 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 31 here 85584.008
24 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 32 here 85584.009
25 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 33 here 85584.010
26 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 34 here 85584.011
27 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 35 here 85584.012
28 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 36 here 85584.013
29 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 37 here 85584.014
30 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 38 here 85584.015
31 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 39 here 85584.016
32 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 40 here 85584.017
33 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 41 here 85584.018
34 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 42 here 85584.019
35 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 43 here 85584.020
36 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 44 here 85584.021
37 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 45 here 85584.022
38 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 46 here 85584.023
39 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 47 here 85584.024
40 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 48 here 85584.025
41 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 49 here 85584.026
42 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 50 here 85584.027
43 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 51 here 85584.028
44 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 52 here 85584.029
45 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 53 here 85584.030
46 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 54 here 85584.031
47 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 55 here 85584.032
48 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 56 here 85584.033
49 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 57 here 85584.034
50 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 58 here 85584.035
51 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 59 here 85584.036
52 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 60 here 85584.037
53 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 61 here 85584.038
54 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 62 here 85584.039
55 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 63 here 85584.040
56 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 64 here 85584.041
57 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 65 here 85584.042
58 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 66 here 85584.043
59 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 67 here 85584.044
60 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 68 here 85584.045
61 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 69 here 85584.046
62 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 70 here 85584.047
63 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 71 here 85584.048
64 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 72 here 85584.049
65 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 73 here 85584.050
66 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 74 here 85584.051
67 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 75 here 85584.052
68 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 76 here 85584.053
69 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 77 here 85584.054
70 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 78 here 85584.055
71 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 79 here 85584.056
72 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 80 here 85584.057
73 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 81 here 85584.058
74 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 82 here 85584.059
75 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 83 here 85584.060
76 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 84 here 85584.061
77 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 85 here 85584.062
78 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 86 here 85584.063
79 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 87 here 85584.064
80 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 88 here 85584.065
81 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 89 here 85584.066
82 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 90 here 85584.067
83 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 91 here 85584.068
84 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 92 here 85584.069
85 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 93 here 85584.070
86 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 94 here 85584.071
87 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 95 here 85584.072
88 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 96 here 85584.073
89 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 97 here 85584.074
90 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 98 here 85584.075
91 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 99 here 85584.076
92 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 100 here 85584.077
93 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 101 here 85584.078
94 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 102 here 85584.079
95 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 103 here 85584.080
96 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 104 here 85584.081
97 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 105 here 85584.082
98 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 106 here 85584.083
99 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 107 here 85584.084
100 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 108 here 85584.085
101 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 109 here 85584.086
102 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 110 here 85584.087
103 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 111 here 85584.088
104 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 112 here 85584.089
105 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 113 here 85584.090
106 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 114 here 85584.091
107 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 115 here 85584.092
108 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 116 here 85584.093
109 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 117 here 85584.094
110 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 118 here 85584.095
111 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 119 here 85584.096
112 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 120 here 85584.097
113 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 121 here 85584.098
114 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 122 here 85584.099
115 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 123 here 85584.100
116 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 124 here 85584.101
117 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 125 here 85584.102
118 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 126 here 85584.103
119 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 127 here 85584.104
120 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 128 here 85584.105
121 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 129 here 85584.106
122 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 130 here 85584.107
123 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 131 here 85584.108
124 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 132 here 85584.109
125 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 133 here 85584.110
126 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 134 here 85584.111
127 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 135 here 85584.112
128 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 136 here 85584.113
129 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 137 here 85584.114
130 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 138 here 85584.115
131 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 139 here 85584.116
132 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 140 here 85584.117
133 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 141 here 85584.118
134 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 142 here 85584.119
135 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 143 here 85584.120
136 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 144 here 85584.121
137 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 145 here 85584.122
138 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 146 here 85584.123
139 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 147 here 85584.124
140 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 148 here 85584.125
141 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 149 here 85584.126
142 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 150 here 85584.127
143 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 151 here 85584.128
144 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 152 here 85584.129
145 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 153 here 85584.130
146 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 154 here 85584.131
147 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 155 here 85584.132
148 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 156 here 85584.133
149 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 157 here 85584.134
150 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 158 here 85584.135
151 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 159 here 85584.136
152 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 160 here 85584.137
153 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 161 here 85584.138
154 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 162 here 85584.139
155 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 163 here 85584.140
156 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 164 here 85584.141
157 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 165 here 85584.142
158 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 166 here 85584.143
159 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 167 here 85584.144
160 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 168 here 85584.145
161 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 169 here 85584.146
162 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 170 here 85584.147
163 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 171 here 85584.148
164 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 172 here 85584.149
165 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 173 here 85584.150
166 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 174 here 85584.151
167 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 175 here 85584.152
168 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 176 here 85584.153
169 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 177 here 85584.154
170 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 178 here 85584.155
171 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 179 here 85584.156
172 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 180 here 85584.157
173 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 181 here 85584.158

pwalker on DSK7TPTVN1PROD with REPORTS
(175) 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 182 here 85584.159
176 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 183 here 85584.160
177 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 184 here 85584.161
178 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 185 here 85584.162
179 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 186 here 85584.163
180 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 187 here 85584.164
181 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 188 here 85584.165
182 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 189 here 85584.166
183 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 190 here 85584.167
184 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 191 here 85584.168
185 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 192 here 85584.169
186 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 193 here 85584.170
187 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 194 here 85584.171
188 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 195 here 85584.172
189 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 196 here 85584.173
190 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 197 here 85584.174
191 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 198 here 85584.175
192 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 199 here 85584.176
193 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 200 here 85584.177
194 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 201 here 85584.178
195 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 202 here 85584.179
196 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 203 here 85584.180
197 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 204 here 85584.181
198 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 205 here 85584.182
199 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 206 here 85584.183
200 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 207 here 85584.184
201 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 208 here 85584.185
202 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 209 here 85584.186
203 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 210 here 85584.187
204 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 211 here 85584.188
205 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 212 here 85584.189
206 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 213 here 85584.190
207 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 214 here 85584.191
208 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 215 here 85584.192
209 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 216 here 85584.193
210 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 217 here 85584.194
211 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 218 here 85584.195
212 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 219 here 85584.196
213 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 220 here 85584.197
214 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 221 here 85584.198
215 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 222 here 85584.199
216 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 223 here 85584.200
217 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 224 here 85584.201
218 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 225 here 85584.202
219 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 226 here 85584.203
220 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 227 here 85584.204
221 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 228 here 85584.205
222 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 229 here 85584.206
223 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 230 here 85584.207
224 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 231 here 85584.208
225 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 232 here 85584.209
226 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 233 here 85584.210
227 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 234 here 85584.211
228 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 235 here 85584.212
229 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 236 here 85584.213
230 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 237 here 85584.214
231 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 238 here 85584.215
232 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 239 here 85584.216
233 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 240 here 85584.217
234 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 241 here 85584.218
235 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 242 here 85584.219
236 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 243 here 85584.220
237 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 244 here 85584.221
238 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 245 here 85584.222
239 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 246 here 85584.223
240 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 247 here 85584.224
241 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 248 here 85584.225
242 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 249 here 85584.226
243 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 250 here 85584.227
244 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 251 here 85584.228
245 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 252 here 85584.229
246 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 253 here 85584.230
247 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 254 here 85584.231
248 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 255 here 85584.232
249 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 256 here 85584.233
250 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 257 here 85584.234
251 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 258 here 85584.235
252 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 259 here 85584.236
253 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 260 here 85584.237
254 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 261 here 85584.238
255 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 262 here 85584.239
256 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 263 here 85584.240
257 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 264 here 85584.241
258 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 265 here 85584.242
259 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 266 here 85584.243
260 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 267 here 85584.244
261 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 268 here 85584.245
262 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 269 here 85584.246
263 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 270 here 85584.247
264 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 271 here 85584.248
265 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 272 here 85584.249
266 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 273 here 85584.250
267 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 274 here 85584.251
268 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 275 here 85584.252
269 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 276 here 85584.253
270 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 277 here 85584.254
271 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 278 here 85584.255
272 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 279 here 85584.256
273 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 280 here 85584.257
274 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 281 here 85584.258
275 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 282 here 85584.259
276 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 283 here 85584.260
277 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 284 here 85584.261
278 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 285 here 85584.262
279 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 286 here 85584.263
280 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 287 here 85584.264
281 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 288 here 85584.265
282 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 289 here 85584.266
283 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 290 here 85584.267
284 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 291 here 85584.268
285 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 292 here 85584.269
286 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 293 here 85584.270
287 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 294 here 85584.271
288 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 295 here 85584.272
289 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 296 here 85584.273
290 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 297 here 85584.274
291 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 298 here 85584.275
292 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 299 here 85584.276
293 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 300 here 85584.277
294 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 301 here 85584.278
295 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 302 here 85584.279
296 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 303 here 85584.280
297 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 304 here 85584.281
298 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 305 here 85584.282
299 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 306 here 85584.283
300 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 307 here 85584.284
301 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 308 here 85584.285
302 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 309 here 85584.286
303 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 310 here 85584.287
304 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 311 here 85584.288
305 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 312 here 85584.289
306 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 313 here 85584.290
307 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 314 here 85584.291
308 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 315 here 85584.292
309 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 316 here 85584.293
310 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 317 here 85584.294
(311) 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 318 here 85584.295
312 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 319 here 85584.296
313 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 320 here 85584.297
314 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 321 here 85584.298
315 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 322 here 85584.299
316 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 323 here 85584.300
317 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 324 here 85584.301
318 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 325 here 85584.302
319 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 326 here 85584.303
320 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 327 here 85584.304
321 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 328 here 85584.305
322 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 329 here 85584.306
323 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 330 here 85584.307
324 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 331 here 85584.308
325 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 332 here 85584.309

pwalker on DSK7TPTVN1PROD with REPORTS
(327) 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 333 here 85584.310
328 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 334 here 85584.311
329 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 335 here 85584.312
330 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 336 here 85584.313
331 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 337 here 85584.314
332 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 338 here 85584.315
333 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 339 here 85584.316
334 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 340 here 85584.317
335 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 341 here 85584.318
336 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 342 here 85584.319
337 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 343 here 85584.320
338 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 344 here 85584.321
339 


pwalker on DSK7TPTVN1PROD with REPORTSInsert offset folio 345 here 85584.322