The PAC released its fourth quarter report in installments; to see the big picture you need to consider information from each of the 3 installments. Having multiple parts to combine, when none ends at a rational point makes the job of analysis much more difficult. This 4th quarter analysis is compiled using common sense and arithmetic. One pass is made as the reports become available, no effort is expended to go back in time and recalculate or summarize
information as updates or corrections are made. This should be considered an overview, as the sums do not match exactly the final year end Summary Reports – 2009 -2010 issued by Treasurer Crawford.
During the 3rd quarter, Treasurer Crawford received several deficiency letters related to previous reporting. The responses are not available on the FEC site. Wouldn’t you love to see those responses? The FEC deficiency letters detailed multiple issues from arithmetic errors to questions related to the various items that the PAC had paid for. These included an offset from Pie-Spy LLC, clarification of expenditures for fundraising consulting, expenses attributed to
postage, clerical consulting, office supplies, photography, video production and much more.
Cash flow
To model 4th Quarter monthly incoming cash, the daily receipts from each of the installment reports were calculated and monthly estimated receipts were then estimated.
(Please click on the images to enlarge)
Expenses
Here are the big ticket expenses (and credits) for 2010.
The Brain Trust
To start, it is very interesting to see who has come and gone over the 23 months that the PAC has been in existence. Political watchers and reporters have observed that the PAC is not employing the caliber of professionals that would advise a serious presidential contender nor is it attempting to raise money in a serious fashion. The analysis from this citizen observer confirms that opinion.
Nobody got a raise this quarter, unlike previous quarters. Lindsay Hayes was again paid for speech writing services in October (Ten PM Medial). As a reminder, Michael Gross reported in his Vanity Fair article that Hayes left his gig with Palin in April. Nothing to worry about though, as a new speech writer has surfaced: Chriss Winston of Pomfret, Maryland was paid $4000 on November 5th for speech writing. Ms. Winston appears to be an accomplished and respected speech writer, working for both the Reagan and first Bush administrations. She is also a real author. One wonders how hard it must have been for her to work for Palin. I bet we won’t see her again.
Joshua Livestro remains on the payroll and we can see that he probably has been around since July. Beardog did the legwork on Paideia and his work resulted in the discovery that Joshua Livestro was Paideia. Elaborate lengths were employed to conceal his identity. Does the lack of transparency on both sides suggest that there is embarrassment or shame in the consulting relationship? If not, perhaps there really should be. Beardog’s own site has disappeared in
recent days. A YouTube video of his investigation is available. Beardog also looks into the secrecy surrounding the addition of Joshua Livestro as one of Sarah Palin's advisor.
Ivy Frye has remained off the PAC payroll. Her guardianship of Bristol during the DWTS series was not paid for by the PAC. Marilyn Lane did however get reimbursed for $2623 for correspondence and postage on October 27th. Did we see her in the audience at a DWTS contest around that time or was it the other long-time family friend who also happens to be on the PAC payroll, Carol Ryan? Does anybody remember?
In one of the last PAC installments, RAM’s job description was again expanded. Her responsibilities grew to include “Quick Response”. RAM was very quick to respond in defense of Palin following the tragic mass shooting in Tucson, as reported by Alaska Dispatch. We have speculated on RAM’s silence in recent days and some may worry about her silence and her welfare. Would she have any unemployment benefits should she ever lose her job with SarahPAC? The answer to that is a big NO. It’s interesting that RAM has never been paid for any expenses. No postage, no travel, no nothing. I wonder if she has ever met with Palin in person.
The average consultant spend continues to run around $300,000 per quarter.
Internet Fund Raising
In 2009, SarahPAC spent $279046 on internet fundraising. For 2010, Upstream Communications has been the primary
SarahPAC internet fundraiser. This company took over from Edonations in December 2009.
The PAC has again invested in direct mail efforts to raise funds. The costs of direct mail campaigns likely include printing, postage, thank-you correspondence, and direct mail firm services. It is unclear if Passcode developed a new video to promote Palin, or if the 2 payments seen in the 4th quarter are remaining amounts due from the Mama Grizzly video.
Four entries documenting likely duplicate transactions appear on page 4 of 5, Schedule B Itemized Disbursements, 11/23 – 12/31. These are big amounts but it is just sloppy, very, very sloppy. There are only 11 or 12 entries per page and just 5 pages total. Timothy Crawford, McLean, VA was reimbursed for postage in the amount of $980 on 12/02/2010. The Arlington, VA postmaster was paid $980 for stamps on 12/17/2010. The Wasilla, AK postmaster was paid $456 for PO Box rental and postage on 11/22/2010. Marilyn Lane, Wasilla, AK was reimbursed for PO Box rental and postage in the amount of $456 on 11/24/2010. They sure look like dupes to me, or were they acutally paid twice?
Trinkets and Meat
The PAC did not invest in any trinkets, photos or holiday gifts during the last quarter. Wasn’t there a book tour? Notrinkets? No photographs? I am not going to talk about the meat again.
The PAC is still not itemizing expenses covered under the Visa bill; 24% of travel expenses are not itemized as required by FEC regulations. Three private charters were used during the fourth quarter. There are no travel expenses for December. Again, it looks like Palin runs a tab with airlines and hotels. Or she is getting someone else to pay?
PAC Business
There were credits for uncashed checks to the Michele Bachmann for Congress, MN, campaign (2500) and the Coffman for Congress, CO, campaign (5000). Did these candidates have scruples?
Several small reimbursements were made during the quarter to SarahPAC contributors.
***
A big thank you to mxm for doing this analysis with such good humour. You can uncross your eyes now, mxm. Give them a good rest.
.
Please note that all filed SarahPAC reports can be accessed HERE.
The report for the second quarter 2010 can be downloaded HERE and the report for the third quarter 2010 HERE.
The FEC has asked SarahPAC Treasurer Timothy Crawford to provide additional information related to the latest PAC filings.These FEC notices of deficiency and request for corrected information come as no surprise.
An August 11 FEC letter of deficiency requested further information focusing on a single issue, the incomplete information related to contributor identification.
A significant number of the contributors listed in Itemized Receipts, Schedule A, do not include the required amount of identity detail. The FEC demanded a response by September 15.It is unknown if Treasurer Crawford responded to this demand as it is not included in the FEC index of 2010 SarahPAC submissions.It should be noted though that the PAC filing of October 15 includes a significant number of contributors listed in the Schedule A without complete identifying detail.The means by which the Treasurer must correct the submission were very specific.
Commission Regulations require that a committee discloses the identification of all individuals who contribute in excess of $200 in a calendar year. (11 CFR § 104.3(a)(4)(i)) Identification for an individual is defined as the full name (first name, middle name or initial, if available, and last name; initials for first and last name are not acceptable), complete mailing address, occupation, and name of employer. (11 CFR § 100.12) Your report discloses contributions from individuals for which the identification is not complete.
This most recent FEC deficiency letter details multiple issues from arithmetic errors to questions related to the various items that the PAC has paid for.These include an offset from Pie-Spy LLC, clarification of expenditures for fundraising consulting, expenses attributed to postage, clerical consulting, office supplies, photography, video production and much more.
Treasurer Crawford must explain:If a portion or all of these expenditures were for public communications (as defined by 11 CFR §100.26) or voter drive activity (under 11 CFR §106.6(b)(2)(i)) containing express advocacy as defined under 11 CFR §100.22, this would constitute an in-kind contribution or an independent expenditure and should be properly disclosed on a Schedule B or E supporting Line 23 or 24 as appropriate. Public communications and voter drive activity that refer to a clearly identified Federal candidate, but that do not expressly advocate the election or defeat of that candidate should be reported on Schedule B for Line 21(b) of the Detailed Summary Page. Please clarify whether this activity contained express advocacy and amend your report to properly disclose this activity, if necessary.
A response to this deficiency letter is due by December 15.Unfortunately, the FEC has not yet requested an explanation of all questionable expenses.Perhaps they are just getting started.
CASH FLOW
It is difficult to estimate monthly cash flow using the same methods that were previously used to analyze incoming contributions.The direct mail campaigns, the increased bank fees and the reduced internet fundraising costs suggest that more money was received through the mail than through the internet efforts. The FEC reports reveal that $400,482 was received in the first quarter, $865,815 was received during the second quarter and $1,213,300 was received during the third quarter.
To model monthly incoming cash, the non-itemized receipts were calculated following the same incoming rate as the itemized receipts. During the second quarter, 529 line items appeared in the itemized receipts (Schedule A); 40% of the itemized total was received in April, 35% was received in May and 25% was received in June.The same rationale was used in modeling the third quarter receipts; 20% of the itemized cash was received in July, 32% was received in August and 48% was received in September.Please keep in mind that this model is built on monthly estimates of incoming receipts, however the totals match the FEC filing.
2009
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Total
IN
461188
104020
71431
31657
64570
476244
147390
109610
83804
22024
560281
2132219
OUT
97835
57434
50012
42165
56752
152224
103657
80392
92061
175668
345260
1253460
2010
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Total
IN
95040
178101
127341
346326
303035
216454
239863
389406
584032
2479598
OUT
138470
105286
184490
319339
295195
189252
224538
334718
363820
2155108
Cash Flow, February 2009 through September 2010
In reviewing the contributor demographics, several observations can be made.
There is only 1 individual from Alaska that can be found in the itemized listings; this AK resident makes small recurring monthly contributions.Just 1, not 2, not 3 ---- only 1, a homemaker from Anchorage is Palin’s only listed AK donor.
That should inform the thinking of her supporters if nothing else does.
During the second quarter only 25% of the donors whose names appeared on the itemized Schedule A listing were women.No wonder Palin launched her Mama Grizzly campaign on July 8th, she was looking for some mama bonding and love.Too bad it wasn’t more lucrative.
2010
Jul
Aug
Sept
Total
Listed Donors
289
365
639
1293
Women
67
67
121
255
% Women
23%
18%
19%
18%
It seems that there may have been several efforts to enhance contributions. Perhaps the fans conducted these efforts.In late July, a number of donations were made in the amount of $20.12 --- that’s kind of cute.Then on August 29, a number of donors made contributions in the amount of $28.99.Nothing similar happened in September.
It should be noted that Palin’s own marketing company, Pie-Spy LLC, reimbursed the PAC $3863 for airline tickets and for the purchase of a domain name. The PAC listed a $709.85 expense for a domain name acquisition in March 2010, but not in connection with "Pie Spy LLC" (download the SarahPAC report for the first quarter 2010 HERE).
Interesting that Palin is using her marketing company, Pie-Spy.However, it’s even more interesting that the PAC was reimbursed by Pie-Spy since no report ever showed a distribution to Pie-Spy!It seems that the FEC thought so as well as they included this in the November 10 deficiency letter:4. Schedule A supporting Lines 15 and 17 of your report discloses an offset to an operating expenditure(s) totaling $3,862.90 from "Pie-Sky LLC"; however, your report(s) does not appear to disclose a disbursement to this entity. Please provide clarifying information regarding this activity and amend your report(s) if necessary.
EXPENSES
Here are the big ticket expenses for 2010 – good old common sense was used in moving the data to worksheets, bundling like categories and doing simple arithmetic.
Category
Expenses YTD
Consultants
927295
Internet Fundraising
102270
Direct Mail Campaign, Mama Grizzly Video
752811
Postage, Supplies, Telecom, Bank Fees
33182
Meat and Trinkets, Photographer
17181
Going Rogue for Kristan
2463
Travel
150376
Donations to Candidates
254500
Donor Refunds
-250
Total
2239828
THE BRAIN TRUST
Orion Strategies
Orion is a public relations, political consulting and advertising company founded by Randy Scheunemann.He was John McCain’s foreign policy adviser during the 2000 presidential campaign and according to Game Change, served as his national security adviser.He was asked to tutor Palin after her selection as the VP candidate.According to Game Change, on page 370, In the days since the pick, Schmidt had spent enough time with Palin to get a sense of how much instruction she would need. “You guys have a lot of work to do,” he warned Scheunemann.“She doesn’t know anything.” Game Change, on p. 404, described Scheunemann as a participant in the special debate prep that was held in Sedona, AZ.
Scheunemann was speculated to have been one of Palin’s Op-Ed ghostwriters, but she has not been published in any legitimate publications in many, many months.SarahPAC paid Orion Strategies $30,000 in December and it has continued to be paid a monthly fee of $10,000 thus far in 2010.What exactly is he doing to earn this money?In the Q3 FEC filing, the type of consulting he is providing is listed as foreign or international issues consulting.
He is reported to have been recommended by Palin to assist Christine O’Donnell in her debate preparation.It has just been reported by Salon that Scheunemann’s company also advises George Soros.
So, does that give Sarah one degree of separation from George Soros?Hope no one tells her bff Glenn Beck.
Pamela Pryor
SarahPAC pays Pryor $6000 monthly for media political consulting. Ms. Pryor may just win the prize for the most steadfast member of Palin’s team of paid advisors. Wonder what exactly she does?
Pick a political hat, and Pam Pryor wears it...or has worn it.
Pryor is among many Oklahomans who have gone to Washington on the staff of a member of Congress and moved on to other, more national, pursuits and the resultant national prominence.
Few have made the climb as far as Pryor, who now talks to the media on behalf of potential Republican presidential candidate Sarah Palin, walks the halls of power with the authority that a lot of years in Washington brings, and speaks across the country on behalf of groups like We Care America and through the White House Writers' Group, consults with the Department of Labor, Habitat for Humanity and Convoy of Hope.
Pryor's current national persona comes as the spokesperson for Palin's Sarah PAC, launched by the former Alaska governor as part of her coalition-building effort across the country.
A member of Palin's team in 2008 says that Pryor today is Palin's "go-to girl. If Sarah has a doubt about anything, she talks to Pam. If Sarah wants to do something, she talks to Pam. Pam is a solid lock in Palin's future.
Timothy Crawford
Initially in 2010, SarahPAC paid its treasurer, Tim Crawford, a $10,000 monthly salary. This was a significant raise from his first year salary with the PAC.During 2009, the PAC paid him a monthly fee of $6000.We see that he has earned yet another salary increase in 2010, is that because he now has to look after the new Palin defense fund?On June 24, the original Palin defense fund was found to violate AK law and a new defense fund was immediately set up.Coincidently at that very time, Treasure Crawford enjoyed what may be a mid-year bonus, being paid $20,000 in July, and settling in at a new monthly salary of $15,000.
Crawford must travel extensively for SarahPAC.In 2009 his expenses were $42,957 and so far in 2010 he has been reimbursed $47,613 for expenses.
He came to SarahPAC directly from the RNC, where he had been the finance director for 2 weeks, before leaving.Politico reported:
The finance director for the Republican National Committee resigned abruptly Friday afternoon, and a source familiar with the situation said he was forced out. Reince Priebus, who’s running the transition team for new RNC Chairman Michael Steele, confirmed that Tim Crawford resigned Friday after just two weeks as the committee’s interim finance director. Priebus declined to discuss the circumstances of Crawford’s departure, saying only that the committee is working to find a replacement for him. But a source familiar with the situation said Crawford was given a choice — resign or be fired.
And back in November, days before the last presidential election, Crawford’s group New Models robocalled thousands of voters with a racist, anti-immigrant message that claimed Barack Obama’s “aunt is living in America illegally.” And that this “illegal alien aunt is living in public housing.” And that “Barack Obama accepted illegal campaign contributions from his illegal alien aunt.”
One word comes to mind as I read the details of Tim Crawford’s illustrious career: classy. Say what you want about Ken Blackwell’s friends, but don’t ever accuse them of being disingenuous, opportunistic, no-class-having fucktards. Tim Crawford is a class fucking act and I challenge anyone to provide proof to the contrary.
Timothy Crawford, the treasurer of Sarah-PAC, presumably has some responsibility for the byzantine structures undergirding Palin’s travels. Before joining Palin, Crawford was the interim finance director of the Republican National Committee. He is currently being investigated by the Ohio secretary of state for his role in Let Ohio Vote, a state-referendum campaign bankrolled in its entirety by New Models, a Virginia organization Crawford owns, which calls itself a nonprofit. Earlier this year, he refused to respond to a subpoena—issued under state laws that prohibit concealment of campaign money—that sought to discover where New Models had gotten the $1.6 million to fund Let Ohio Vote. Ohio secretary of state Jennifer Brunner has called New Models “a ‘straw-person’ out of state corporation.” Also, according to the Cleveland Plain Dealer, New Models “was behind controversial automated calls to Pennsylvania voters made during the 2008 presidential election. The calls told voters that Barack Obama’s aunt was living in America illegally and that he accepted campaign contributions from his ‘illegal alien aunt.’ ”
North Star Strategies
This is Jason Recher’s consulting company.He provided advice to Palin during the campaign and started working with SarahPAC in August 2009 providing political advance.He was frequently seen on the book tour and I fondly began to think of him as the manservant.Jason Recher got a nice little $5000 bonus (or wedding gift) in June, which I am sure was a delightful surprise for the just married Recher.
The company was set up by Rebecca A. Mansour, one of the founders of C4P who had long been rumored to be one of the writers who impersonated Sarah Palin on Facebook. Following the Palingates publication of the investigation and its results, Mansour confirmed her identity and role for Palin in blog communications.
Rebecca A. Mansour ("RAM") had been paid $6000 monthly for ghostwriting at least some of Palin’s Facebook musings and managing Palin's facebook page.She has also been suspected to be a twitter ghost for Palin, although the description of her services used to be consulting internet, grassroots.Our good friend RAM saw a nice little bonus of $4000 in June. Did she get married also too?Looks like her base was bumped to $8000 per month and her job description is now speech writing and political consulting. Nice promotion RAM, you go girl! Maybe she will remember the unemployed Joey Russo (Callisto Consulting) on his birthday with a Target gift card.
As a speech writer and political consultant, we can now see why she felt sufficiently important and informed enough to write a speech for Palin criticizing Federal Reserve policy and the price of milk.
Davis, of Sacramento, CA, was first paid by the PAC in November.According to the FEC filing, he provides political and candidate research consulting. In 2008, he was a VP for Mercury Public Affairs in Sacramento and he contributed to Senator Ted Stevens. He is not listed as an officer of Mercury at this time. What little information available about Davis was found here.Following a lead from standupforournation to Mercury Public Affairs subsequently led to the IGR Group which has an office in Sacramento.No team leader is listed for the Sacramento office.As Andrew Davis has been paid a $7500 monthly fee, further research is necessary to understand what services he may be providing the PAC. Some reports have suggested that he identified candidates for Palin to endorse.It’s hard to imagine that I know.
Aristotle International
Aristotle is paid $6000 once per quarter to provide the PAC with record keeping and FEC compliance service.According to the company site it provides services to PACs.At Aristotle, we have amassed a team of experienced PAC and Compliance professionals to help you and your organization reach your goals. Our staff roster boasts former PAC managers, compliance directors, senior analysts from the Federal Election Commission and other industry professionals. With over 100 collective years of PAC management and administration experience on board, Aristotle is uniquely qualified to service your PAC, Trade Association, 501c3 and 501c4 in this growing and competitive market.
Baker & Hostetler
This Washington, DC law firm provides an unknown service to the PAC; they receive payment at irregular intervals.
Clapp, Peterson, Van Flein, Tiemessen
Thomas Van Flein, Palin’s personal attorney, is a member of this firm.The firm was paid $65,000 in December of 2009 and $80,000 so far in 2010.The FEC filing states that the firm is providing legal services.Palin and her daughters have been widely reported to be receiving legal services from Van Flein and/or other attorneys in this firm.Failed AK senate candidate Joe Miller also utilizes the services of this law firm.
The Washington Times recently uncovered a check made out to Palin’s attorneys at the Anchorage law firm of Clapp, Peterson, Van Flein, Tiemessen & Thorsness in the amount of $128,518.85 to pay billable hours charged while fending off ethics allegations during her time as Governor and a Vice Presidential nominee. When asked by the Times what the check was for, RNC Treasurer Randy Pullen – who co-signed it with RNC Chief Administrative Officer Boyd Rutherford – stated it was in exchange for Palin’s help with party fundraising.
“The initial payment was for Palin to do several different fundraising events and sign fundraising letters for the RNC,” Mr. Pullen told the Times. The next check will be in the amount of $257,037.50.
Other media outlets have reported varying amounts of promised RNC payments.We will have to delve through all the RNC filings to determine the final amount paid.The total RNC payments will amount to $385,556 according to the Politic365 reporting.Palin was forced to return approximately $390,000 from her Alaska Fund Trust illegal defense fund.Has anyone else noticed how close those 2 numbers are?Clapp, Peterson, Van Flein, Tiemessen has been paid $145,000 by the PAC and will be paid $385,556 by the RNC.That’s a tidy sum, $530,556!Now, if only half the bots are true to their word, Palin may have collected another $200,000 or so in her new legal defense fund.Nice work for Van Flein and firm. And the defense fund continues to solicit donations.Maybe the FEC or the IRS will see fit to inquire.
True North L’Attitudes
Robyn Engibous, of Anchorage, AK was first paid in March 2010 for schedule consulting. Her monthly salary of $5417 amounts to $65,000 annually.She is a former staff assistant to Senator Ted Stevens.Engibous felt confident enough in her schedule consulting role to open a corporation.
Hayes is not listed any longer in the Nahigian Strategies site. She has not been paid by SarahPAC since May.In his Vanity Fair article, Michael J. Gross reported that Hayes resigned from further PAC duties in April:Clarification: Lindsay Hayes, identified in this article as Sarah Palin’s speechwriter, left that position in April.
Grey Strategies
This Columbus, OH entity provided $75,000 worth of media-logistics consulting thus far in 2010.TPM Muckraker provided some insight into what this firm provides:
Palin paid $35,000 to Grey Strategies, a Columbus firm that helped her with media, logistics and political consulting. It appears to now be a newly merged firm called Grey Shockley, run by lobbyists Doug McMarlin and Leslie Beyer. According to Hotline on Call, McMarlin also travels with Palin.
This is a mystery company, without an apparent working website.One note was found on a site that described the firm thusly:A premier consulting firm specializing in targeted services to meet the unique goals of its clients by applying an impressive set of local, national and international experience in the areas of Corporate Imagery, Operations Consulting, Issue Advocacy, National and International Business Development, and Financing Strategies. GreyShockley provides proven experience, unparalleled credentials and exceptional results to it's clients.
Sounds like a big bunch of nothing to me. Other finds on one of the named lobbyists – from the Washington Post:
Doug McMarlin: McMarlin is a partner at GreyShockley, an Ohio-based consulting firm, and did advance work for the McCain campaign in 2008. He along with Jason Recher travel with Palin on trips. McMarlin is expected to take on a broadened role -- particularly in dealing with the press -- following Stapleton's departure. Doesn’t seem this has happened yet now does it?
There is little to be found on Doug’s partner Leslie Shockley Beyer. She is active with the RNC and likes Karl Rove according to her Facebook page.
338 Industries
The PAC paid this entity $1500 in June for fundraising consulting. What or who is 338 Industries of Austin, Texas?
The FEC has a question or two about fundraising consulting.We refer to this as how to get more OPM (other peoples’ money).
Matt Hall
Matt was paid $2779 in per diem expenses (travel, lodging, parking) in May and $2501 in July.Just who is Matt Hall of Arlington, VA and what service did he provide?
Carol Ryan and Marilyn Lane
Palin has hired 2 new clerical support staff.Both women are from Wasilla and appear to each have a base salary of $30,000 per year.I wonder if they’re good with kids?As Palin has other clerical support paid by the PAC, she must keep the staff quite busy.Anahita Nemat of Calabasas, CA seems to be working steadily.Ivy Frye has not been paid by the PAC since April.
Altered States Alliance LLC
Altered States provided fundraising consulting in September. The PAC paid Altered States $5000 in September.Our fellow gaters marvinmm and Older Wiser helped to uncover some information about this LLC.
ALTERED STATES ALLIANCE, LLC was registered in FL on May 7, 2010.The registered agent’s St. Petersburg, FL address corresponds to the address of the PAC payee.The LLC Registered Agent is Allison Meyers.Meyers has a mailing address in Washington, DC.That address corresponds to a lovely townhome in Georgetown.
Wonder what Allison does in DC.Oh, let’s make that wonder what Allison did in DC.Allison used to work for the RNC.She was regularly reimbursed by the RNC for travel expenses; the RNC FEC filings list multiple reimbursements to Meyers at the Georgetown address.
Looks like Meyers took some time off, set up her cleverly named FL company and found some work with Sarah Palin. Do you think she will organize some field trips for Palin and her entourage?
The FEC November deficiency letter wants to know more about fundraising consulting:Please clarify all expenditures made for "Fundraising Consulting" and "Intemet and credit card fundraising" on Schedule B. If a portion or all of these expenditures were made on behalf of specifically identified federal candidates, this amount should be disclosed on Schedules B or E supporting Lines 23 or 24 and include the amount, name, address and office sought by each candidate. 11 CFR §§104.3(b) and 106.1
Paideia Research LLC
Paideia provided expensive research consulting service in September.They were paid $12,000. No information is found on this company located at 1617 N Main St, Suite B, Sheridan, WY 82801.Google shows that the address corresponds to a very non-descript single story building.What is this company and what did they research for the PAC that was worth $12,000?
Ten:PM Medial LLC
Palin has a new speech writer; Ten:PM Medial was paid $8000 for work in September.Now we have seen and heard most of her speeches, exactly what does her speech writer do?The address for this consulting company is a single family residence on Nelson Ave., in Alexandria, VA.Gater assistance was most helpful in determining some background on this company.Older Wiser, ProChoiceGrandma and mocha all provided some information.The company is actually Ten Pound Monkey.
The address for the company corresponds to the payee’s address in the PAC report.This property is owned by:HAYES LINDSAY F and MARCELLA JASON A.According to his linkedin profile, Jason Marcella owns Ten:PM.Marcella’s specialties are logo design, branding, advertising and motion graphics.Wrapping this up, Older Wiser said it best, “Well, well, well. Lindsay Hayes IS BACK on the PAC's payroll. I looked up the property owners, ta da.”
Of course, this could be payment for services rendered back in March and April. Those earlier payments were made directly to Hayes at the Nelson Ave address. We shall have to wait and see if the Ten Pound Monkey or Hayes receives any further payment.Again, Michael Gross did report in his Vanity Fair article that Hayes left her gig with Palin in April.
COST OF DOING BUSINESS
Internet Fund Raising
2009
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Total
Edonation
67152
15148
10403
4612
9404
58578
18129
13482
10308
2709
4366
214291
Upstream
64755
64755
TOTAL
67152
15148
10403
4612
9404
58578
18129
13482
10308
2709
69121
279046
2010
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sept
2010 Total
Edonation
1248
952
823
2748
601
456
6828
Upstream
11519
11315
23981
7873
2751
3055
15034
19914
95442
TOTAL
12767
12267
24804
10621
3352
3511
15034
19914
102270
Upstream Communications is the SarahPAC internet fundraiser.This company took over from Edonations in December 2009 although Edonations continued to receive some donations. It seems that the PAC pays a percentage of its incoming receipts to the vendor.Upstream has an interesting history. It is an Austin based company.
Delisi has moved on, and now is a partner in Delisi Communications, along with his wife Deirdre and mother Dianne (and a couple other folks as well). Deirdre has been involved in public service/politics and was Gov Rick Perry's chief of staff. Dianne is a former TX state representative.
Direct Mail and The Mama Grizzly
During the second and third quarters of 2010, the PAC has relied on its direct mail and video campaigns to raise funds.The costs of direct mail includes printing, list acquisition, postage, thank-you correspondence, and direct mail firm services.The Mama Grizzly video, which is a commercial for and about Sarah Palin, appears to have cost the PAC nearly $30,000 to produce.
The photographer, Shealah Craighead, was back in the entourage this quarter or else she was still owed some money.
What’s Up With This?
Going Rogue
Apr
May
Jun
Total
Book Stores
1125
1125
Kristan Cole / Books
1338
1338
Total
1125
1338
2463
In the November FEC deficiency letter, Treasurer Crawford was asked specifically about fundraising consulting and fundraising in general:Please clarify all expenditures made for "Fundraising Consulting" and "Intemet and credit card fundraising" on Schedule B. If a portion or all of these expenditures were made on behalf of specifically identified federal candidates, this amount should be disclosed on Schedules B or E supporting Lines 23 or 24 and include the amount, name, address and office sought by each candidate. 11 CFR §§104.3(b) and 106.1
Planes, Trains and Automobiles
Travel
Q1
Apr
May
Jun
Jul
Aug
Sept
2010 Total
Air Commercial
20156
5257
5977
31390
Air Charter
10509
6756
17265
Amtrak
406
406
Rental Car
1616
550
578
2744
Hotel
17697
3388
310
1399
7794
1137
31725
Visa Bill
10489
24662
4362
106
1533
41152
Limo
6068
1559
661
8288
Restaurants
1662
1662
Compass Travel
582
174
756
Total
14988
69185
41796
310
12288
7900
3909
150376
Getting a little arrogant with that Visa bill aren’t you Sarah? Nearly 30% of the travel expenses are not itemized as required by FEC regulations and just listed as Visa Bill.Could there be charges in that Visa bill that are questionable PAC expenses?
Just another thing for the FEC and IRS to look into.It is also unexplained why all the commercial air expenses listed in the third quarter report are from much earlier in the year and there are no air expenses listed for July, August or September.Do the airlines allow Palin and entourage to run a tab?
There were private charters used during the second quarter.That March swag grab in Hollywood, looks like everybody spent some time at the Beverly Hills Wilshire Hotel.Sweet.Hotels are generally of the 4-5 star variety.Wonder if the sporadic sightings of professional security are covered in the limo category – International Limousine Service, Inc., of DC.
PAC Business
Why did those 2 donors get their money back during the second quarter? Does Palin know the AK donor Gloria Lafferty of Anchorage and for whatever reason wouldn’t take her money? Phillip Isaacson of Grove City, Ohio --- what did he do?
PAC Purpose
2009
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Total
Political Donations
60000
2000
1000
8500
4000
83500
5000
88500
252500
Charity Donations
2000
2000
Donor Refunds
-250
-250
There was a credit for $3500 from an uncashed check to the Mulvaney for Congress campaign (SC).That contribution was originally made by the PAC on 6/24/2010.A contribution was made again on 9/15/2010.Guess the first check got lost in the mail.The FEC, in the November deficiency letter noted that this matter was not reported on the correct lines/schedules.Your report discloses an apparent uncashed contribution from a federal candidate totaling $3,500 on Schedule A supporting Line 16 of the Detailed Summary Page. If the check written by your committee was not cashed, you should itemize the voided check on Schedule B supporting Line 23 as a negative entry. Line 16 should only be used if the recipient committee cashed your check and wrote a refund on its account. Please amend your report to correct this discrepancy or provide clarification regarding this transaction.
There you have it, the PAC report for the second and third quarters of 2010.She spends a lot of OPM promoting herself and her family.She spends a lot of OPM on very expensive advisers and consultants yet she remains unpolished, uninformed, quarrelsome, and defiant. She spends a lot of OPM in questionable ways.Hopefully the FEC will stay on the job.
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UPDATE BY MXM:
Gaters have participated in further identifying two companies doing business with SarahPAC
338 Industries
Jack Slater reported this information:
On Thursday, December 03, 2009, a U.S. federal trademark registration was filed for HANDS OFF AMERICA. This trademark is owned by 338 Industries, LLC, 101 Colorado St., #3201, Austin, TX 78701. Trademarkia.com is a free search engine of publicly available government records. Trademarkia.com is not a law firm and does not represent owners & correspondents listed on this page.
The correspondent listed for HANDS OFF AMERICA is WILLIAM D. WIESE of DUBOIS, BRYANT & CAMPBELL, LLP, 700 LAVACA, SUITE 1300 AUSTIN, TX 78701 . The HANDS OFF AMERICA trademark is filed in the category of Advertising, Business & Retail Services . The description provided to the USPTO for HANDS OFF AMERICA is Providing a web site promoting the interests of people concerned with healthcare, taxes, national security, big government, guns, life and jobs; Providing a website featuring information about political issues; Providing an on-line searchable database for political campaigns which allow users to collect and analyze political information electronically.
The USPTO has given the HANDS OFF AMERICA trademark serial number of 77885483. The current federal status of this trademark filing is REGISTERED.
Hands Off America seems to be an internet based ‘advocacy’ group, Their one page site includes only a short letter to President Obama, and collects the first and last names, email address, and mobile phone numbers of participants. Links to the corresponding Twitter and Facebook pages are available on the site. The site makes no representations that the brief letter has been delivered to the President. It seems to be intended only as a vehicle to collect names and contact information of like-minded individuals. They have published at least one e-newsletter to their followers. In the newsletter, Sarah Palin was featured as was the Tea Party.
No owner or group takes credit for the site and there does not seem to be any current fundraising effort through the site.
SarahPAC paid 338 Industries $1500 in June for fundraising consulting. It seems likely the proprietor (who remains unknown) sold a list of site participants to the PAC for its direct mail fundraising campaign or perhaps SarahPAC participated in its creation.
Paideia Research LLC
Beardog321 went to work for us to try and identify Paideia, here is an excerpt from his comment:
Wyoming has a very business friendly environment of companies of all sorts, like LLCs, non-profits, profits, etc. I checked out the states Domestic Entity Charters As of October 7, 2010 with Date Range Includes: 07/01/2010 through 09/30/2010 @ http://soswy.state.wy.us/Business/docs/2010Q3Domestic.pdf and Paideia research is on page 200 of the pdf. Seems to be a difference in your address, and that on file with the state, but that could be a clerical error. But that address is used in many LLCs, and others, but they are all being registered out of Natrona County, not Sheridan County where we are located. Natrona County is located in the center of the state, and home of Casper, WY, and all you Dick Cheney fans will recognize that connection.
Registration for Paideia was filed in WY on July 16, 2010. The mailing address for the registration is PAIDEIA RESEARCH, LLC, 32565B Golden Lantern St, Ste 140, Dana Point, CA 92629 USA.
Patrick commented that this is nothing more than a mail drop. The PAC paid Paideia $12,000 for research consulting in September.
Why does a person or a company doing business with Sarah Palin need to hide its identity?
The question that the FEC repeatedly asked Treasurer Crawford in its November deficiency letter should also be asked of Paideia Research and 338 Industries:
If a portion of these expenditures were for public communications (as defined by 11 CFR §100.26) or voter drive activity (under 11 CFR §106.6(b)(2)(i)) containing express advocacy as defined under 11 CFR §100.22, this would constitute an in-kind contribution or an independent expenditure and should be properly disclosed on a Schedule B or E supporting Line 23 or 24 as appropriate. Public communications and voter drive activity that refer to a clearly identified Federal candidate, but that do not expressly advocate the election or defeat of that candidate should be reported on Schedule B for Line 21(b) of the Detailed Summary Page. Please clarify whether this activity contained express advocacy and amend your report to properly disclose this activity, if necessary.
Download the PDF with all information available in the WY Business Register.
In addition, our reader DebinWI found more info regarding "Corp95":
It looks like http://www.corp95.com/index.html this company at the Dana Point, CA address creates and forms shelf LLCs and names them and has a bunch of these ready-made LLCs already set up for anyone to buy.
" 1. YOUR NAME IS ON NOTHING! Completely anonymous"
So just because the Paidai Research was registered in July by this Corp95 company, it only means the shelf was registered then. It would have been purchased later, and anyone could have bought this as recently as the PAC payment.
Also, this company does not list its MLR registration code required by all companies providing shell corps due to the 2007 anti money-laundering regulations.
WYOMING CORPORATIONS and LLCs have a tax haven within the United States with no income taxation,anonymous ownership and bearer shares. The annual upkeep costs less and you can issue as many shares as you want with no extra filing fee. We can help you set up banking for your Wyoming LLC or Wyoming corporation from your home state. Did you know that Wyoming invented the LLC? Numerous European companies as well as US companies have used the State of Wyoming for their Wyoming LLCs as well as for corporations.
+++
We can therefore prove that an elaborate system of setting up an anonymous company in WY in combination with two "postbox addresses" in WY and CA was purposely used in order to conceal the true owner of the company "Paideia Research LLC", which received $ 12,000 from SarahPAC.
I am not an expert, but I wonder whether this is compliant with FEC rules.
Sarah Palin, who gets angry about "anonymous sources" on a regular basis, has no problem in paying money to "anonymous companies."
The Brain Trust
The PAC has again invested in direct mail efforts to raise funds. The costs of direct mail campaigns likely include printing, postage, thank-you correspondence, and direct mail firm services. It is unclear if Passcode developed a new video to promote Palin, or if the 2 payments seen in the 4th quarter are remaining amounts due from the Mama Grizzly video.
Four entries documenting likely duplicate transactions appear on page 4 of 5, Schedule B Itemized Disbursements, 11/23 – 12/31. These are big amounts but it is just sloppy, very, very sloppy. There are only 11 or 12 entries per page and just 5 pages total. Timothy Crawford, McLean, VA was reimbursed for postage in the amount of $980 on 12/02/2010. The Arlington, VA postmaster was paid $980 for stamps on 12/17/2010. The Wasilla, AK postmaster was paid $456 for PO Box rental and postage on 11/22/2010. Marilyn Lane, Wasilla, AK was reimbursed for PO Box rental and postage in the amount of $456 on 11/24/2010. They sure look like dupes to me, or were they acutally paid twice?
The PAC did not invest in any trinkets, photos or holiday gifts during the last quarter. Wasn’t there a book tour? Notrinkets? No photographs? I am not going to talk about the meat again.
What do you read?
The PAC is still not itemizing expenses covered under the Visa bill; 24% of travel expenses are not itemized as required by FEC regulations. Three private charters were used during the fourth quarter. There are no travel expenses for December. Again, it looks like Palin runs a tab with airlines and hotels. Or she is getting someone else to pay?
There were credits for uncashed checks to the Michele Bachmann for Congress, MN, campaign (2500) and the Coffman for Congress, CO, campaign (5000). Did these candidates have scruples?
