Subject: Report on Willis matter
Date: Mon, 13 Aug 2001 23:59:23 -0400
From: "James W. Lark, III" <jwl3s@virginia.edu>
Organization: Dept. of Systems Engineering, University of Virginia
To: Steve Givot <givot@softwarena.com>, Thomas Knapp <tlknapp@free-market.net>,
     Michael Gilson De Lemos <mg4u@oasis.net>, Joe Dehn <jwd3@dehnbase.org>,
     Steve Dasbach <SteveDasbach@hq.lp.org>, Carl Milsted <cmilsted@earthlink.net>,
     Elias Israel <eli@promanage-inc.com>, Jim Turney <JimTurney@lpva.com>,
     Scott Lieberman <scott73@best.com>, Jim Dexter <jimdex@inconnect.com>,
     Ken Bisson <kbisson@usa.net>, Mark Nelson <lpiachair@home.com>,
     Lorenzo Gaztanaga <DiazVivar@aol.com>, Deryl Martin <dnc@multipro.com>,
     Jim Lark <jwl3s@virginia.edu>, Daniel Wisnosky <stigmata@skylink.net>,
     Lois Kaneshiki <lois@nb.net>, Daniel Karlan <DanKarlan@compuserve.com>,
     Mary Ruwart <Mary@ruwart.com>, Mike Dixon <mdixonlp@earthlink.net>,
     Richard Schwarz <hogweed@pop.mail.rcn.net>, Ed Hoch <edsway@sprynet.com>,
     Greg Holmes <mag97@home.com>, Mark Rutherford <RUTHERFORDLAW@prodigy.net>,
     Tim Hagan <t.hagan@usa.net>, Ben Scherrey <Ben.Scherrey@ga.lp.org>,
     Mark Cenci <mcenci@mindspring.com>
CC: "Lark, Jim" <jwl3s@virginia.edu>, "Hall, William" <HALLWW@wnj.com>

Dear colleagues:

    I hope all is well with you.  I have prepared a report concerning
the Willis matter for your consideration.  Some of the report will be
sent in separate e-mails.  I had hoped to have more time to include more
background information for you. However, given my faculty commitments,
the need to finish the SPT material, and some other constraints, I
decided to send it now so that you can evaluate the material and
determine what additional information you would like to have.

    Some comments about the inquiry and the report:

1)  The inquiry is not complete and probably won't be complete by the
start of the LNC meeting on Aug. 25.  Unfortunately, several people from
whom I wish to obtain information have so far declined to participate;
also, there are several other people (especially people who worked on
the 1996 Browne campaign) for whom I do not have contact information.  I
am also waiting for some information concerning a couple of items from
the 1996 Browne campaign files.  I hope to obtain this information very
soon.

2)  I shall send you updates should additional information become
available between now and the start of the LNC meeting on Aug. 25.  If
you have questions or requests for more information, please let me
know.  Also, during the next week I intend to send an e-mail in which
issues of scope and procedure for the inquiry are discussed.

3)  In the first section of the report, I have provided suggestions
concerning background and reference material for understanding the
Willis matter, as well as a copy of an e-mail from Harry Browne to
former LP chair Mary Gingell.  Given the amount of material and the
online availability of that material, I decided to provide the URLs for
most of the material rather than sending you extremely large text files
or extremely long e-mails.  However, if you have access to e-mail but
find it difficult or expensive to avail yourself of the online material,
please contact me and I'll send material to you in e-mail form.

    Please note that I do not claim that the list of items provided in
this section contains all of the useful references; it is possible that
I am unaware of material that might be very helpful to the committee.
Thus, I welcome suggestions for additional references.  Also, I make no
claim that the material available in the sources listed is correct in
every detail or provides a complete and uncaricatured view of the Willis
matter.  Indeed, some of the material strikes me as biased in various
ways; in certain cases (such as the Liberty magazine timeline), some
minor details are incorrect.  (John Famularo has indicated that the LP
News article contains false hearsay information concerning him; I do not
know whether he is correct.)

    Within the last seven years, the LNC has taken action against two
prominent activists:  Tamara Clark and Gene Cisewski.  To provide some
background concerning the situation involving Ms. Clark, I have listed
two online references.  I do not have similar online references for the
situation involving Mr. Cisewski; however, I have asked LP general
counsel Bill Hall to provide some material about that situation.  Please

note that since I had no involvement with the Clark situation when it
occurred, I cannot claim that the material represents the story
accurately and completely.

4)  You have already been sent material concerning legal issues from LP
general counsel Bill Hall.  As you know, that material is privileged and
confidential; any discussion of these issues should proceed under the
protection of the attorney-client privilege.  Thus, Mr. Hall should be
included in any correspondence or conversation about the particulars of
our legal situation.  Please do not hesitate to contact Mr. Hall or me
if you have any questions about this matter.

    As you consider and discuss this material in advance of the upcoming
meeting, I ask as a favor that you treat this material with an extra
degree of caution.  Since the information gathering process continues, I

believe it would be better to wait until the LNC meeting before
distributing certain parts of this material widely.  In particular, I am
still trying to contact people to request information from them, and I
have had some difficulty with bad addresses (e-mail and regular mail).
It would be very unfortunate for someone who has so far failed to
respond as a result of e-mail problems and/or out-of-date mailing
addresses to come under suspicion.

    At its heart, the Willis matter deals with issues of trust and
responsibility.  The determination of whether an action is legal or
ethical can depend upon information that is easily misinterpreted or
misrepresented.  I have already seen several horrible examples of how
small, subtle and completely innocent errors in interpretation or
presentation of information I provided to the LNC can create problems
that require a great deal of time to repair.  Injudicious behavior on
our part could harm the reputations of innocent people; thus, let us
exercise our responsibilities with great care.

    Thanks for your work for liberty.  I look forward to seeing you in
Las Vegas.

    Take care,
    Jim

    James W. Lark, III
    Advisor, The Liberty Coalition
    University of Virginia

    Chairman, Libertarian Party
-----

(I)  Background and reference material

Statement of Perry Willis, May 11, 2001 (available online at
http://harrybrowne.org/policy)

Timeline of events prepared by Joe Dehn (available online at
www.dehnbase.org/lpus/library/misc/timeline.html)

Timeline from Liberty magazine, September, 2001  (available online at
http://www.libertysoft.com/liberty/timeline.html)

Minutes of the May 23, 2001 Executive Committee meeting (available
online at http://archive.lp.org/lnc/ec/20010523.html)

Minutes of the May 30, 2001 Executive Committee meeting (available
online at http://archive.lp.org/lnc/ec/20010530.html)

Willis contract (not dated) (available online at
http://users.erols.com/famularo/PlatPara.htm)

Letter of employment agreement from Steve Dasbach to Perry Willis (dated

Oct. 3, 1997)  (available online at
http://users.erols.com/famularo/PlatPcov.htm)

LNC policy manuals (and some especially relevant sections):

LNC policy manual (as amended Sept. 5, 1993)  (available online at
http://archive.lp.org/lnc/pm/19930905.html): Article I, section 2;
article IV, sections 1-5

LNC policy manual (as amended Aug. 21, 1994) (available online at
http://archive.lp.org/lnc/pm/19940821.html):  Article I, section 2;
article IV, sections 1-2

LNC policy manual (as amended July 7, 1996) (available online at
http://archive.lp.org/lnc/pm/19960707.html): Article I, section 2;
article IV, section 1-2

LNC policy manual (as amended March 8, 1998) (available online at
http://archive.lp.org/lnc/pm/19980308.html): Article I, section 3;
article IV, sections 1-3

LNC policy manual (as amended July 3, 2000) (available online at
http://archive.lp.org/lnc/pm/20000703.html):  Article I, section 3;
article IV, sections 1-3

Article about Willis matter in LP News, July, 2001 (available online at
http://www.lp.org/lpnews/0107/willis.html)

Relevant sections from the minutes of particular LNC meetings during Mr.

Willis' service as national director:

August, 1995 (available online at
http://archive.lp.org/lnc/lnc950826.min.html):  Item 9, part C

December, 1995 (available online at
http://archive.lp.org/lnc/lnc951209.min.1.html):  Item 13, part 13.1

November, 1996 (available online at
http://archive.lp.org/lnc/lnc961116.min.html):  Resolution moved by
Bennett Rutledge (no numbering of items)

April, 1997 (available online at
http://archive.lp.org/lnc/lnc970405.min.html): Policy Manual: Policy
Manual, 5

A listing of LNC members who have served during the period 1981- present

(available online at
http://www.dehnbase.org/lpus/library/lnc-mem-hist.html)

Information about LNC actions concerning Tamara Clark:

Minutes of LNC meeting April, 1995 (available online at
http://archive.lp.org/lnc/lnc950429.min.html): Item 15 (Campaign
Support)

Article about Clark censure in LP News, June, 1995 (available online at
http://www.lp.org/lpn/9506-Clark.html)

Text of e-mail message from Harry Browne to former LP chair Mary
Gingell:

From: "Harry Browne" <HarryBrowne@AmericanLibertyFoundation.org>
To: "Mary Gingell" <mtg@dehnbase.org>
Subject: Re: Perry's memo
Date: Tue, 15 May 2001 00:29:47 -0500

Dear Mary:

Sorry for the delay in getting back to you.

I'll be issuing a statement in the next couple of days. I imagine it
will find it's way to you.

In the meantime, you should know that I was aware of Perry's actions and

agreed to them.

Please give my best to Joe.

With best wishes,

Harry

----- Original Message -----
From: "Mary Gingell" <mtg@dehnbase.org>
To: <harrybrowne@harrybrowne.org>
Sent: Saturday, May 12, 2001 1:25 AM
Subject: Perry's memo

Hi, Harry.

It occurs to me that now that Perry's memo is being broadcast around the

country, the following question is sure to come up - is the fact that
this memo can be found on the harrybrowne.org
website an indication that you concur with Perry's opinion that
violating the LPC conflict of
interest rules in 1996 in order to help the Browne for President
campaign is justifiable?  And even if you don't believe that allowing
him to post this memo on your website is an implicit endorsement of it,
what, in fact, is your position on the issue?

So I guess I am asking it . . . as someone who defended him, and Winter,

and Sharon, and you during that time and assured people that they were
not, in fact, in violation of the policy.  I would
appreciate knowing how you felt about it then, and how you feel about it

now.

Mary

==

(II)  People contacted about the Willis matter:

    Most of the people listed were contacted by e-mail.  Many of those
for whom we had substantial difficulty in finding a properly functioning

e-mail address were recently sent letters; these people are indicated by

the symbol (L).  Those who have responded are indicated with the symbol
(R).  Because of various difficulties in contacting people, some people
on the list have only recently been contacted; also, in some cases it is

not clear that the message or letter has been received.  Thus, one
should not assume that failure to respond means an unwillingness to
cooperate. Before the Las Vegas meeting I shall attempt to contact all
of those who have not yet responded.

    Please note that there are several people not listed for whom I am
attempting to obtain contact information.  This includes several of the
people who worked for the 1996 Browne campaign in a support capacity
(such as Theresa Bronson, Robert Martin, and Lisa Paley) as well as some

of Mr. Browne's opponents for the nomination.

1996 Browne Campaign:

Sharon Ayres
Harry Browne (Mr. Browne provided an oral statement)
Michael Cloud (Mr. Cloud provided an oral statement)
Jack Dean
Kiana Delamare (L)
Stuart Reges  (Mr. Reges did not respond to my inquiry messages, but has

issued a statement about the Willis matter)
Perry Willis (Mr. Willis responded to my inquiry of April 25 with his
statement of May 11)

Jo Jorgensen (VP candidate) (R)

2000 Browne Campaign:

Jim Babka
Geoff Braun  (Mr. Braun indicated that he had received the inquiry
message)
Harry Browne (Mr. Browne provided an oral statement)
Michael Cloud  (Mr. Cloud provided an oral statement)
Jennifer Willis (L)
Perry Willis (Mr. Willis provided his statement on May 11)
Steve Willis (L)
Stephanie Yanik

Art Olivier (VP candidate)  (L)

LNC Members:  1993-1996:

Steve Dasbach (R)
Karen Allard
John Famularo (R)
Hugh Butler  (R)
Sharon Ayres
Tamara Clark  (L)
Ron Crickenberger (R)
Don Ernsberger (Mr. Ernsberger provided an oral statement)
Gary Johnson (R)
James Dan  (R)
Bill Evers  (R)
Thea McLean (R)
Joe Hauptmann (L)
Gary Ilardi
Dan Karlan (R)
Joe Brennan (L)
Bob Franke (R)
Joe Barnett (L)
Tom Paswater (L)
Gus Hercules (L)
Lynn House (L)
Terry Savage (R)
Steve Linnabary (L)
Scott Benson (L)
Jesse Markowitz (R)
Pamela Haberkorn (L)
Jeanne Bojarski (R)
Joe Lusardi  (L)

LNC Members:  1996-1998:

Steve Dasbach  (R)
Karen Allard
Gary Johnson (R)
Hugh Butler  (R)
Sharon Ayres
John Buttrick
Ron Crickenberger (R)
Steve Givot (R)
Barb Goushaw (R)
Bill Hall (R)
Steve Winter (L)
Joe Dehn (R)
Paul Smith (L)
Gene Cisewski
Chris Gardiniere
Ken Bisson (R)
Candy Copas (L)
Tim Moir (L)
Mark Tuniewicz (R)
Bob Franke (Mr. Franke provided an oral statement)
Geoff Neale (R)
Scott Lieberman (R)
Terry Savage (R)
Bennett Rutledge (L)
Don Gallick (L)
Gary Ilardi
John Famularo (R)
Dan Karlan (R)
Joe Brennan (L)
Mike Ginsburg (L)
Lynn Atherton (R)

LNC Members:  1998-2000:

David Bergland (Mr. Bergland indicated that he had received the inquiry
message)
Hugh Butler  (R)
Steve Givot  (R)
Mark Tuniewicz  (R)
John Buttrick
Mike Dixon (R)
Bill Hall (R)
Jim Lark (R)
Mary Ruwart (R)
BetteRose Smith (R)
Joe Dehn (R)
Terry Savage (R)
Ken Bisson (R)
Chris Spruyt
Amy Rule (L)
Jim Turney (R)
Muni Savyon
Eli Israel (R)
Bob Franke (Mr. Franke provided an oral statement)
Geoff Neale (R)
Ed Hoch (R)
Scott Lieberman (R)
Dan Fylstra (R)
Barb Goushaw (R)
Gary Ilardi
Richard Schwarz (R)
Ken Lindell
Jackie Bradbury (L)
Deryl Martin (R)

LNC Members: 2000-2002:

Jim Lark  (R)
Dan Fylstra  (R)
Steve Givot  (R)
Mark Tuniewicz  (R)
Deryl Martin  (R)
Ken Bisson  (R)
Lorenzo Gaztanaga
Eli Israel (R)
Lois Kaneshiki (R)
Jim Turney  (R)
Mike Dixon (R)
Ed Hoch (R)
Joe Dehn (R)
Scott Lieberman (R)
Sara Chambers
Mark Rutherford  (R)
Michael Gilson De Lemos (R)
Richard Schwarz (R)
Ken Lindell
Dan Karlan (R)
Mark Nelson (R)
Tom Knapp  (R)
Jim Dexter (R)
Tim Hagan (R)
Dan Wisnosky (R)
Barb Goushaw (R)
Greg Holmes
Ben Scherrey (R)
Carl Milsted (R)
Mark Cenci  (R)
Mary Ruwart (R)

Employees (current and former):

Stephanie Abdon (R)
Marc Brandl  (R)
John Buckley (R)
Mike Chase (L)
Gene Cisewski
Ananda Creager (R)
Ron Crickenberger (R)
Steve Dasbach (R)
Nick Dunbar  (R)
Cynthia Fellows (L)
Dan Gallagher (R)
George Getz (R)
Scott Kohlhaas
Marc Montoni (R)
Peter Orvetti (R)
Dollie Parker
Dianne Pilcher (R)
Tiffany Rodney (L)
Dan Smith (Mr. Smith provided an oral statement)
Lisa Stronawski
Jonathan Trager (R)
Kris Williams
Perry Willis (Mr. Willis provided his statement on May 11)
Bill Winter (R)

1998 Bylaws Committee members:

David Aitken  (R)
Karen Allard
Bruce Baechler  (deceased; God rest his soul)
David Bergland (R)
Ken Bisson  (R)
Hugh Butler (R)
Greg Dirasian
Geoff Neale (R)
William Redpath (Mr. Redpath provided a oral statement)
Mark Tuniewicz (R)

Responses from those contacted:

    I have separated the responses into different categories due to the
number of responses and the length of those responses.  Each category
will be e-mailed separately.  The categories consist of responses from
current LNC members, responses from former LNC members and members of
the 1998 Bylaws Committee, responses from current and former staff
members, and responses from people associated with the Browne for
President campaigns.  (Some of the people I am currently trying to
contact do not fit into these categories.) I have received oral
statements in response to my inquiries from the following people: Harry
Browne, Michael Cloud, Don Ernsberger, Bob Franke, Bill Redpath, and Dan

Smith.

(III)  Information obtained from 1996 Browne campaign records and
Libertarian Party vendor records

    With the approval of the Executive Committee, I asked Bill Redpath,
internal auditor for the Libertarian Party, to examine the campaign
finance records of the 1996 Browne for President campaign that were
stored at LP headquarters.  Mr. Redpath, who is currently running for
Governor in Virginia, graciously agreed to do so.  In addition to
obtaining the Browne campaign files, Mr. Redpath borrowed several
Libertarian Party vendor files from 1995-1996.

    I assisted Mr. Redpath on two occasions in examining the material in

the files.  We were able to find information relevant to some questions
that had been raised concerning the Browne campaign:

LP list rental by the Browne campaign:

    The 1996 Browne for President campaign was evidently able to rent
the Libertarian Party mailing list on several occasions in 1996 at times

when the campaign had not paid for previous mailings. According to the
material we viewed, the campaign rented lists from the LP from May, 1995

until June, 1996 according to the following schedule:

Invoice from LP to Browne campaign for $3000.90 on May 3, 1995.
According to invoice, campaign rented current member list for $1549.00
(12,392 names at $125/1000 names), lapsed member list for $1451.90
(14,519 names at
$100/1000 names). Invoice paid on May 12, 1995.

Invoice from LP to Browne campaign for $1755.25 on May 19, 1995.
According to invoice, campaign rented the current member list for
$1755.25 (14,010 names at $125/1000 names).  (NOTE:  It appears the
campaign may have been overcharged, as 14010 x $.125 = $1751.25.)
Invoice paid on May 25, 1995.

Invoice from LP to Browne campaign for $3418.45 on July 24, 1995.
According to invoice, campaign rented current member list for $1761.75
(14,094 names at
$125/1000 names), lapsed member list for $1656.70 (16,567 names at
$100/1000 names).  Invoice paid on July 27, 1995.

Invoice from LP to Browne campaign for $3192.60 on Sept. 5, 1995.
According to invoice, campaign rented current member list for $1763.00
(14,104 names at
$125/1000 names), lapsed member list for $1429.60 (14,296 names at
$100/1000 names).

Invoice from LP to Browne campaign for $1401.10 on Sept. 12, 1995.
According to invoice, campaign rented various sublists at $100/1000
names.

Invoice from LP to Browne campaign for $659.00 on Sept. 13, 1995.
According to invoice, campaign rented various sublists at $100/1000
names.

The invoices of Sept. 5, Sept. 12, and Sept. 13 were paid on Sept. 27,
1995 (total: $5252.70).

Invoice from LP to Browne campaign for $116.20 on Oct. 10, 1995.
According to invoice, campaign rented various sublists at $100/1000
names.

Invoice from LP to Browne campaign for $3493.53 on Oct. 19, 1995.
According to invoice, campaign rented current member list for $1760.63
(14,085 names at
$125/1000 names), lapsed member list for $1732.90 (17,329 names at
$100/1000 names).

Invoice from LP to Browne campaign for $191.50 on Oct. 19, 1995.
According to invoice, campaign rented the 1983 and 1987 delegate lists
at $100/1000 names.

The invoices of Oct. 10, Oct. 19, and Oct. 19 were paid on Nov. 2, 1995
(total: $3801.23).

The charge for the delegate list rentals was recalculated at $25/1000
names, and a refund of $143.62 was given to the campaign on Nov. 13,
1995.  This refund is listed on the LP FEC report for December, 1995,
but doesn't seem to be listed in the Browne FEC report.

Invoice from LP to Browne campaign for $3567.90 on Dec. 4, 1995.
According to invoice, campaign rented current member list for $1766.50
(14,132 names at
$125/1000 names), lapsed member list for $1785.90 (17,859 names at
$100/1000 names), and paid a charge of $15.50 to FEDEX something on
behalf of Michael Cloud.  Invoice paid on Jan. 23, 1996.

Invoice from LP to Browne campaign for $3543.00 on Jan. 17, 1996.
According to invoice, campaign rented the current member list for
$833.25 (14,132 names at $62.50/1000 names), the current member list for

$833.25 (14,132 names at $62.50/1000 names), the current member list for

$833.25 (14,132 names at $62.50/1000 names), and the current member list

for $833.25 (14,132 names at $62.50/1000 names), and paid a charge of
$10.00 to FEDEX something on behalf of Michael Cloud.

Invoice from LP to Browne campaign for $1865.75 on Feb. 6, 1996.
According to invoice, campaign rented current member list for
$1865.75 (14,926 names at $125/1000 names).

Invoice from LP to Browne campaign for $1937.38 on March 25, 1996.
According to invoice, campaign rented current member list for
$1902.63 (15,221 names at $125/1000 names), and paid charges of $21.75
and $13.00 to FEDEX something to Steve Lyons (Champion Printing in
Cincinnati, OH).  (Total:  $1937.38)

Invoice from LP to Browne campaign for $1908.00 on April 25, 1996.
According to invoice, campaign rented current member list for
$1908.00 (15,264 names at $125/1000 names).

Invoice from LP to Browne campaign for $1930.88 on June 21, 1996.
According to invoice, campaign rented current member list for
$1930.88 (15,447 names at $125/1000 names).

The invoices from January, February, March, April, and June were paid
(total: $11185.01) on July 3, 1996.

    At this time, one cannot conclude from this information that the
Browne campaign received special treatment, because as far as we can
ascertain there are no clear examples of other enterprises or campaigns
that received different treatment.  However, it appears that the
national office under Mr. Willis' direction exercised a considerable
degree of forbearance concerning the Browne campaign's list rental
payment performance in the first six months of 1996.

    It should be noted that the size of the Browne campaign's
outstanding debt to the LP was indicated in the FEC reports filed by the

LP.  For example, in the April monthly report (for period March 1, 1996
- March 31, 1996), the Browne campaign is listed on Schedule D as owing
$6806.13.  (This is in error; the entry for "amount incurred this
period" is listed as $1397.38, when it should be $1937.38, and so the
proper total should be $7346.13.)  The Browne campaign's outstanding
obligation continued to show in the FEC filings until the debt was paid
in July, 1996.  Thus, one may ask whether Mr. Willis or others exhibited

appropriate business judgment.  One may also ask whether greater
oversight should have been exercised by the LNC.

LP payments for undisclosed work by Mr. Willis?:

    In consideration of Mr. Willis' undisclosed action of preparing
fundraising letters for the Browne campaign, a question was raised as to

whether Mr. Willis had directed party funds to the firm of Dean, Spear &

Associates ("DSA") with the intention of having DSA use those funds to
pay Mr. Willis or the preparation of the fundraising letters.  More
pointedly, if DSA paid $2000 to Mr. Willis that he requested in his Feb.

28, 1996 invoice to the firm, did DSA obtain the funds for that payment
from the Libertarian Party?  This question was raised since DSA was
engaged by the Libertarian Party in late 1994 to establish a "major
donor program" for the party.  While we cannot answer the question with
certainty, we discovered a document in the Browne campaign files which
suggests this did not happen.

    Specifically, we viewed an invoice dated March 15, 1996 from DSA to
the Browne campaign requesting payment of fees for professional
services.  The services consisted of the following:

Copywriting                    Graphics
December Fundraising Letter                    $575
January Fundraising Letter
575                                75
February Fundraising Letter
575                               350
First Prospecting Letter                              575

Totals
2300                                425

TOTAL DUE       $2725

This invoice (among others) was paid by the Browne campaign (Crestar
check #5512) on June 3,
1996.

    In comparing this invoice to Mr. Willis' invoice of Feb. 28, 1996 to

DSA, it appears that DSA added a $75 fee to the $500 fee charged for
each letter by Mr. Willis.  In addition, DSA added fees for providing
graphics to the January and February fundraising letters.  Since this
invoice was paid by the Browne campaign, it appears that if DSA paid
$2000 to Mr. Willis for his undisclosed work for the Browne campaign,
then the funds used to do so ultimately came from the Browne campaign
and not the party.

Knowledge of Mr. Willis' undisclosed writing activities by others:

    The invoice from Mr. Willis to DSA of Feb. 28, 1996 indicated that
Mr. Willis had written four letters on behalf of the Browne campaign.
Specifically, Mr. Willis sought payment of $500 for each of the
following items: a December letter, a January letter, a February letter,

and a first prospecting letter.

    A question has been raised as to whether Michael Cloud was aware of
Mr. Willis' undisclosed work for the campaign. Mr. Willis notes in his
memo of May 11 that Mr. Cloud was writing fundraising letters for the
Browne campaign prior to Mr. Willis' undisclosed actions. We are not
able to answer the question at this time, however, we have discovered an

interesting item that is worthy of further inquiry.

    Theresa ("Terry") Bronson provided consulting services for the
Browne campaign through the firm of Bronson Office Services of
Nashville, Tennessee.  Ms. Bronson sent several invoices to the Browne
campaign for both payment of services and reimbursement of expenses.

    In an invoice of January 14, 1996 (the date listed on the invoice is

14 January 95), Ms. Bronson requests payment of consulting services for
the Browne campaign for the period Dec. 26, 1995 - January 13, 1996.
One of the provided services listed is for "proofing fund-raising
letters."
The total amount requested in the invoice was $1507.50 (100.5 hours at
$15/hour).  The invoice was paid (Crestar check #5340) on Feb. 17,
1996.  In an invoice of March 4, 1996, Ms. Bronson requests payment of
consulting services for the Browne campaign for the period Feb. 11, 1996

- March 3, 1996.  Again, one of the provided services listed is for
"proofing fund-raising letters."  The total amount requested in the
invoice was $3041.25 (202.75 hours at $15/hour).  The invoice was paid
(Crestar check #5518) on June 3, 1996.

    In an invoice dated March 10, 1996, Ms. Bronson requests
reimbursement for telephone charges incurred from January 30, 1996 -
Feb. 28, 1996.  The total amount requested in the invoice was $238.25.
This invoice (among others) was paid (Crestar check #5406) on March 21,
1996.

    In reviewing the telephone charges mentioned above, it is
interesting to note three consecutive calls originating from the fax
number (615 352-8922) for Bronson Office Services on February 27, 1996
(the day before the date of the Willis invoice to DSA):

8:26 AM    Alexandria  VA    703 683-1825    3.0 Minutes    $.84
8:29 AM    Fullerton  CA       714 870-7459    2.0 Minutes    $.56
8:31 AM    Las Vegas  NV    702 873-4008    2.0 Minutes    $.56

The Alexandria number was evidently Perry Willis' home number (listed as

both voice and fax); the Fullerton number was the fax number for DSA;
the Las Vegas number was the fax number for Michael Cloud.  (A call
originating from Bronson Office Services fax number to Mr. Willis' home
number was made at 9:16 AM for two minutes (cost: $.30) on Feb. 25,
1996.)

Unreported reimbursement?:

    Mr. Willis requested reimbursement from the Browne campaign on June
13, 1996 for three items:  a $3.50 charge for the Triboro Bridge in (or
to) Manhattan, a $32.00 cab fare from LaGuardia Airport to St. Martin's
Press, and a $26.00 cab fare from St. Martin's Press to LaGuardia
Airport.  (Total charge:  $61.50)  The copies of the receipts submitted
indicated that these expenses were incurred on June 7, 1996.  The
invoice was paid by Crestar check #5539 on June 26, 1996.  If this
reimbursement is listed in the FEC filings of the Browne campaign, it
has so far escaped our notice.  Note:  St. Martin's Press published Why
Government Doesn't Work by Harry Browne.

    At this time we have no idea whether this information pertains to
any improper behavior on the part of anyone.  It is mentioned because
Mr. Willis was reimbursed by the Browne campaign for some activity prior

to the 1996 national convention, and because the expenditure is not
listed (as far as we could tell) in the Browne campaign FEC filings.

Payments by the Libertarian Party in 1995-1997 to Jack Dean:

    During the Executive Committee meeting of May 23, 2001, LP secretary

Steve Givot indicated that it would be appropriate to determine the
following:

A.  What payments were made by the Party to Jack Dean or any firm in
which he was involved in 1995, 1996, and 1997?  What were the dates,
amounts, and stated purpose of each such payment?
B.  What payments were made by Mr. Dean or any firm in which he was
involved to Mr. Willis during 1995, 1996, and 1997?    What were the
dates, amounts, and stated purpose of each such payment?
C.  What payments were made by Mr. Dean or any firm in which he was
involved to any L.P. employee other than Mr. Willis during 1995, 1996,
and 1997?    What were the dates, amounts, and stated purpose of each
such payment?

    In examining the LP vendor files and the LP's FEC filings for
1995-1997, we obtained the following information concerning the
questions in part A:

The following payments were issued to Dean, Spear & Associates by the
Libertarian Party:

Payment of $1550 on Jan. 4, 1995 as a consulting fee for the Major
Gifts program.  (This check is accompanied by a letter of agreement
signed by Jack Dean and Steve Dasbach for Dean, Spear & Associates to
develop a Major Gifts program, as presented in correspondence (dated
12/1/93) to the LNC.)

Payment of $1550 on Feb. 16, 1995 as the consulting fee for February for

the Major Gifts program.

Payment of $1550 on March 2, 1995 as the consulting fee for March for
the Major Gifts program.

Payment of $1550 on March 30, 1995 as the consulting fee for April for
the Major Gifts program.

Payment of $1550 on May 1, 1995 as the consulting fee for May for the
Major Gifts program.

Payment of $1550 on May 31, 1995 as the consulting fee for June for the
Major Gifts program.

Payment of $1550 on June 21, 1995 as the consulting fee for July for the

Major Gifts program.

Payment of $1550 on August 1, 1995 as the consulting fee for August for
the Major Gifts program.

The following payments were issued to J. Harris Dean Consulting from the

Libertarian Party:

Payment of $1420.40 on Nov. 26, 1996 for 10% commission for preparation
of e-mail fundraising letter:  Newspaper Ads for Browne for
President.  (The invoice to the LP was dated Nov. 20, 1996.)

The following payment was issued to J. Harris Dean by the Libertarian
Party:

Payment of $673.90 on April 19, 1995 for expenses for an executives
conference in Atlanta.  (This was invoiced by Dean, Spear & Associates
on April 12, 1995; apparently, the payment represented half of the
expenses; the other half were evidently paid by the Browne campaign.)

    As far as we could discern, there were no payments by the party to
Mr. Dean or a firm with which he was associated during 1997.

    For future reference, it may be useful to note that Mr. Dean was
evidently involved in some manner with the firm WK Advertising, based in

Fullerton, California.  The firm provided video services to the Browne
campaign. Two invoices (invoice #1378 and #1379), dated Jan. 26, 1996,
were sent from the company to the Browne campaign  The invoices contain
the following information: Contact: Jack Dean.