Guest post by MXM
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.
A second FEC letter listing deficiencies was dated November 10 and this letter requests a great deal of additional information and explanation.
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.
Pie Spy LLC is owned by Sarah Palin herself!
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 instrumental in advising candidate McCain in preparing to speak to President Saakashvili of Georgia during that country’s war with Russia and he made an appearance with Sarah Palin in Hong Kong in September 2009, when she addressed the CLSA conference in Hong Kong.
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.
Micmac reported on Crawford for Palingates, and Patrick told us he was the man behind the curtain for the new Palin legal defense fund (see their website).
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.
Another interesting background piece on Tim Crawford was found on Plunderbund, (apologies to the sensitive, Plunderbund uses descriptive language):
Last March Tim Crawford was “forced out” of his position as interim finance director for the RNC for “reasons having to do with allegations of impropriety by certain of his colleagues.” I’m still researching who he groped and fondled. Hope to have more details as soon as they become available.
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.
Michael Gross also reported on Crawford in his recent Vanity Fair Article, Sarah Palin: The Sound and the Fury:
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.
Aries Petra
The company identified in PAC filings as Aries Petra Consulting was investigated by Palingates:
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.
Kim Daniels
Wonder what’s up with Kim Daniels? SarahPAC last paid Daniels in May. She was first paid by the PAC in November for consulting on issues and political matters. Kathleen introduced us to Ms. Daniels in a post in April 2010.
Andrew Davis
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.
Lindsay Hayes
Hayes received $2000 from the PAC in March 2010 for speechwriting, $3000 in April and $2700 in May.Hayes is a Senior associate at Nahigian Strategies in Alexandria, VA. Worked for over four years as primary speechwriter for Sen. Ted Stevens (R-AK).
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.
Well, what did Allison do for the RNC? It seems she arranged outings for the Young Eagles and when she crossed the bounds of proprietary with her events, she was fired on March 30. Or she took the fall for the boys.
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.
The company was founded by Karl Rove, as Karl Rove + Co. in 1981. He sold the company to Ted Delisi and Todd Olsen in 2000, so that he could dedicate himself to Bush. The company is tightly woven into the fabric of TX and GOP politics.
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.
| Programs | Apr | May | Jun | Jul | Aug | Sep | Total |
| Direct Mail | 116880 | 118925 | 5700 | 91958 | 216895 | 172698 | 723056 |
| Passcode (video) | | | | | | 29755 | 29755 |
| Total | 116880 | 118925 | 5700 | 91958 | 216895 | 202453 | 752811 |
Supplies, Postage, Telephone, Miscellaneous Expenses
| 2009 | Feb | Mar | Apr | May | Jun | Jul | Aug | Sep | Oct | Nov | Dec | Tot |
| MISC | | 248 | 30 | 30 | 560 | 240 | 2884 | 1970 | 3426 | 2540 | 477 | 12405 |
| 2010 | Jan | Feb | Mar | Apr | May | Jun | Jul | Aug | Sept | Total |
| Postage | 1949 | 1554 | 1000 | 7188 | 3012 | 4116 | 948 | 107 | 68 | 19942 |
| UPS, Fed Ex | 2757 | | | | | | 21 | | | 2778 |
| Domain | | | 710 | | | | | | | 710 |
| Bank Fees | | | 45 | 50 | 540 | 549 | 1519 | 247 | 1766 | 4716 |
| Supplies | | 192 | | 602 | | | | | | 794 |
| Storage | | | | 715 | | | | | | 715 |
| Telecom | 330 | 332 | 336 | 338 | 333 | | 1095 | | 763 | 3527 |
| Total | 5036 | 2078 | 2091 | 8893 | 3885 | 4665 | 3583 | 354 | 2597 | 33182 |
Trinkets and Meat
| | Q1 Total | Apr | May | Jun | Jul | Aug | Sept | 2010 Total |
| Nico & LaLa Trinkets | 1244 | | 10046 | | | | | 10046 |
| Photographer | 11596 | | | | 2715 | 612 | | 3327 |
| Meat | | 3808 | | | | | | 3808 |
| TOTAL | 12840 | 3808 | 10046 | | 2715 | 612 | | 17181 |
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.
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.
http://www.handsoffamerica.net/
http://twitter.com/handsoffamerica
http://www.facebook.com/pages/wwwhandsoffamericanet/149895718412
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.
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.
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.
Beardog also made a video about Paideia's official address, with a special personal touch at the end!
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.
Corp 95
210 Nichols Ave
Casper, WY 82601 USA
Manager:
Pyramid Management, LLC
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.
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.
More info on Shelf corps on Wikipedia.
The Wyoming BBB lists Corp 95 and Paideia Research have the same Main St. Sheridan address, which we now know is just a letterbox service.
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.
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."
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