STATE OF MINNESOTA CAMPAIGN FINANCE AND PUBLIC DISCLOSURE BOARD

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Friday, November 21, 1997

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St. Croix Conference Room
Second Floor, Centennial Office Building

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MINUTES

Meeting was called to order by Chair Anderson.Members present: Anderson, Owens Hayes, Pauly, Slocum, Wilson.Others present: Olson, Goldsmith, Swanson, Perreault, staff; Gretz, counsel.

Ms. Rodriguez previously informed the Board she would be unable to attend the Board meeting.

MINUTES (October 31, 1997)

Ms. Wilson's MOTION: To approve the October 31, 1997, minutes as drafted.

Vote on MOTION: Unanimously passed by four members (Owens Hayes abstained).

CHAIR'S REPORT

Board Meeting Schedule

Next Board meeting: Friday, January 23, 1998.

Board Working Rules (See October 31st minutes)

The Board reviewed a draft of the Board Working Rules.

Ms. Pauly's MOTION: To approve the Board Working Rules as drafted.

Vote on MOTION: Unanimously passed.

EXECUTIVE DIRECTOR'S REPORT

Ms. Olson reported the following:

Staff activities

Ms. Swanson and Ms. Olson went to Des Moines, Iowa to a one-day seminar on electronic filing and introduction of Iowa's campaign finance software. The seminar, funded by the Joyce Foundation, was geared to assist agency staff in ensuring that the maximum number of clients use the software. Ms. Olson is the COGEL representative for another grant that the Joyce Foundation has given to COGEL.

Personnel

The Information System Specialist II position has been filled. Gregory Messetler will begin work in the Board office on December 1, 1997.

Independent Legal Counsel

Staff requests direction from the Board on the matter of seeking independent legal counsel if the filing of a declaratory judgment action in regards to Board Advisory Opinion 274 occurs.

Ms. Wilson's MOTION: To grant Chair Anderson and the Executive Director authority to seek independent legal counsel if a declaratory judgment action is filed against the Board.

Vote on MOTION: Unanimously passed.

Chair Anderson questioned if Board members want to intervene and be able to present the Board's position in the matter before the court, in the event the Board is not named as a party in the judgment.

Ms. Owens Hayes' MOTION: To direct Chair Anderson and the Executive Director authority to intervene in the action and seek independent legal counsel if the Board is not named as a party in the declaratory judgment action.

Vote on MOTION: Unanimously passed.

Ms. Olson noted that the Legislative Recommendation Committee may wish to request the legislature to clarify Minn. Stat. §10A.25, subd. 10.

Enforcement Report

Ms. Perreault presented the following enforcement matters for Board action:

Consent Item

Board Action: Authorization of a certified letter for nonpayment of a late filing fee that accrued for the late filing of a Supplementary Statement of Economic Interest due April 15, 1997, and subsequent legal action in the event the fee is not paid. Two notices have been previously sent to the client.

Marilyn Nelson, Psychology Board: $100

Ms. Owens Hayes' MOTION: To authorize the action specified in the consent matter.

Vote on MOTION: Unanimously passed.

Discussion Items

Acceptance of termination with a balance discrepancy

Harold High, candidate, United Brotherhood of Fathers, Candidate Harold High for Attorney General - Mr. High filed the Report of Receipts and Expenditures for the period covering January 1 through December 31, 1996, on May 1, 1997, and requested that the committee be terminated. Staff review of the report disclosed a balance discrepancy between the 1995 year end cash balance of $226.05, and his 1996 beginning cash balance of $0. By letter dated May 5, 1997, staff requested that Mr. High amend the report to correct the balance discrepancy before his committee could be terminated. Two subsequent letters were sent. Staff has not received a response from Mr. High to date. The committee registered with the Board in September of 1995, and reported one contribution of $2,786.61, from Mr. High. No transactions were reported on the 1996 report. Mr. High did not receive public subsidy and there are no outstanding loans. Mr. High, who is currently residing in Denver, CO, owes a late filing fee of $100.

Staff requests Board direction on whether to proceed with further enforcement.

Ms. Pauly's MOTION: To: 1) suspend efforts to obtain the amended Report of Receipts and Expenditures from Harold High; 2) continue efforts to collect the $100 late filing fee by placing it with the state's collections program; 3) accept the committee's last report as a termination report; and 4) place all correspondence in Mr. High's file and remove the file from the active files section in the Board office.

Vote on MOTION: Unanimously passed.

Reinstatement of a Principal Campaign Committee

Steven Freimuth, treasurer, Friends of Jim Olson Volunteer Committee - On November 10, 1997, staff received a letter from the Friends of Jim Olson Volunteer Committee requesting guidance as to the proper disposition of its $349.34 remaining cash balance. The committee terminated on December 31, 1996. In the process of attempting to meet the necessary requirements to terminate, it gave a contribution of $349.34 to the (Michael) Osskopp Volunteer Committee. The check was never cashed and was returned to the Jim Olson Volunteer Committee in January of 1997. The committee requests the Board reinstate it for the sole purpose of disposing of the $349.34. The bank account was never closed. The committee stated in it's letter that the remaining funds would be disbursed to charitable organizations. According to a phone conversation with staff on November 17, 1997, the committee would also like to disburse funds by giving to principal campaign committees.

Ms. Pauly's MOTION: To: 1) reinstate the Friends of Jim Olson Volunteer Committee for the sole purpose of disposing of the remaining $349.34 in funds by making charitable contributions; and 2) deny the Friends of Jim Olson Volunteer Committee's request to make additional contributions to political committees and political funds.

Ms. Owens Hayes suggested that all transactions by the Friends of Jim Olson Volunteer Committee must be completed by December 31,1997. Ms. Pauly accepted the friendly amendment to her motion.

Ms. Pauly's AMENDED MOTION: To: 1) reinstate the Friends of Jim Olson Volunteer Committee for the sole purpose of disposing of the remaining $349.34 in funds; and 2) deny the Friends of Jim Olson Volunteer Committee's request to make additional contributions to political committees and political funds and that the funds must be disbursed no later than December 31, 1997.

Vote on MOTION: Unanimously passed.

Waiver/ Payment Plan request

Bradley Clifford, (Coalition for the Advance of Telecommunications in Minnesota) - On November 13,1997, staff received a letter from Mr. Clifford requesting that the $55 late filing fee that he accrued be waived or that he be allowed to pay it in installments. Mr. Clifford accrued a $55 late filing fee for the late filing of his Lobbyist Disbursement Report due April 15, 1997, and received in the Board office on July 9, 1997. Mr. Clifford states that he did not receive the reporting forms because he was not a resident at the address to which the report was mailed. Mr. Clifford asks that he be granted time to pay the burden of the $55, or as an alternative contribute community service to help pay the fine with his time. In a phone call with staff on November 17, 1997, Mr. Clifford suggested an installment plan of $25 after the next reporting period (January 15th), and the remaining $30 the second reporting period (April 15th), or another plan allowing for comparable time to obtain the funds.

Ms. Wilson's MOTION: To deny Mr. Clifford's request to waive the $55 late filing fee.

Ms. Wilson withdrew her MOTION. No motion was made.

Waiver Request

Steven Wright, treasurer, (Connie) Janssen Volunteer Committee (See September 26th Board minutes)

Ms. Owens Hayes MOTION: To: 1) waive $100 of the late filing fee; 2) impose a $50 late filing fee for the period Mr. Wright served as treasurer of record for the Janssen Volunteer Committee; and 3) vacate the judgment against Mr. Wright.

Vote on MOTION: Unanimously passed.

Informational Items

Payment of Late Filing Fees

Jeannette Marie Smith, treasurer, 19th Senate District DFL: $165

Donald Moos, treasurer, Becky Livermore Volunteer Committee: $50

(Final payment on installment plan)

All payments have been deposited in the general fund of the state pursuant to statute.

ADVISORY OPINION REQUESTS

Requests for the following advisory opinions are nonpublic data.

Advisory Opinion #279 - Contribution limit for merged political funds

The Board reviewed a draft response to an advisory opinion request by representatives of two political funds who ask if contributions from the political funds of two associations which merge must be attributed to a new fund established by the post-merger association.

Ms. Owens Hayes' MOTION: To approve Advisory Opinion #279 as drafted.

Vote on MOTION: Unanimously passed.

SUMMARY: ADVISORY OPINION #279 signed by Chair Barry Anderson, November 21, 1997:

When two associations which each had a political fund merge, contributions from the pre-merger political funds are attributed to any new political fund formed by the merged associations for the purpose of determining whether the new political fund may make additional contributions to a candidate's principal campaign committee.

Advisory Opinion #280 - Provision of local telephone directories to legislators

The Board reviewed a draft response to an advisory opinion request by a representative of a corporation doing business in Minnesota who asks if the Corporation, which is a lobbyist principal, can give to a legislator of a copy of the legislator's home district telephone directories under Minn. Stat. § 10A.071.

Ms. Owens Hayes' MOTION: To approve Advisory Opinion #280 as drafted.

Vote on MOTION: Unanimously passed.

SUMMARY: ADVISORY OPINION #280 signed by Chair Barry Anderson, November 21, 1997:

A gift from a lobbyist principal to a legislator of home district telephone directories falls within an exception to the gift prohibition because it is the provision of a service to assist an official in the performance of official duties.

Advisory Opinion #281 - Campaign expenditure limit increase for first time candidate

The Board reviewed a draft response to an advisory opinion request by the representative of a candidate who asks if the 10% increase in the campaign expenditure limit provided in Minn. Stat. § 10A.25, subd. 2(c), is applicable each year of an election cycle or only in the election year.

Ms. Wilson's MOTION: To approve Advisory Opinion #281 as drafted.

Vote on MOTION: Unanimously passed.

SUMMARY: ADVISORY OPINION #281 signed by Chair Barry Anderson, November 21, 1997:

The campaign expenditure limit increase applicable to first time candidates applies in both election years and non-election years.

Advisory Opinion #282 - Legal services provided by lobbyist to principal campaign committee

The Board reviewed a draft response to an advisory opinion request by a registered lobbyist who asks if legal services provided under the circumstances described are considered volunteer services and, thus, not a contribution to a candidate's principal campaign committee and not subject to reporting requirements or contribution limits; and are volunteer legal services a prohibited gift under Minn. Stat. § 10A.071 because the requester is a lobbyist.

Mr. Slocum's MOTION: To approve Advisory Opinion #282 as drafted.

The Board agreed to certain language changes to the draft response.

Mr. Slocum's MOTION: To approve Advisory Opinion #282 as amended in discussion.

Vote on MOTION: Unanimously passed.

SUMMARY: ADVISORY OPINION #282 signed by Chair Barry Anderson, November 21, 1997:

Legal services provided without charge by an attorney to a principal campaign committee are volunteer services provided by the attorney. However the value of any support or resources provided by the firm is a contribution to the candidate's principal campaign committee which may be limited or prohibited by Minnesota Statutes Chapter 10A. A donation of volunteer services to a principal campaign committee is not a gift to the candidate on whose behalf the principal campaign committee was established.

Request for the following advisory opinion is public data.

Advisory Opinion #283 - Gift of greeting cards

The Board reviewed a draft response to an advisory opinion request by Tanja Kozicky, Legal Counsel to the Governor, who asks if the gift from Hallmark Cards, Inc. to the Minnesota Department of Health of a greeting card which will be printed with the signature of the Governor and First Lady constitutes a prohibited gift under Minn. Stat. § 10A.071, a campaign contribution to the Governor's principal campaign committee, or a lobbying disbursement by Hallmark.

Mr. Slocum's MOTION: To approve Advisory Opinion #283 as drafted.

Vote on MOTION: Unanimously passed.

SUMMARY: ADVISORY OPINION #283 signed by Chair Barry Anderson, November 21, 1997:

A gift to the state, accepted by the Commissioner of Health under statutory authority, is not a prohibited gift to an official under Minn. Stat. § 10A.071 nor is it a contribution to an official's principal campaign committee. Where the gift is not for a lobbying purpose, its cost is not a lobbyist disbursement under Minnesota Statutes Chapter 10A.

LEGAL COUNSEL'S REPORT

Board members reviewed a memo from Counsel Gretz outlining the status of cases which have been turned over to the Attorney General's office (see copy of memo attached).

LEGISLATIVE RECOMMENDATIONS COMMITTEE REPORT

Ms. Olson stated that the committee would meet today following the Executive Committee session and that all Board members were invited to attend.

OTHER BUSINESS

A nonpublic advisory opinion request was provided to Board members.

Ms. Wilson's MOTION: To lay over discussion of the advisory opinion request to the January 23, 1998, Board meeting.

Vote on MOTION: Unanimously passed.

REPORT FROM EXECUTIVE SESSION

Findings in the Matter of an Investigation Regarding the Complaint of Brian Bates and Michael Ravnitzky and John Marty Regarding Governor Carlson, Phillip Morris, Inc., New York Society for International Affairs, and American-European Community Association

The Board issued findings concerning probable cause in the matter of an investigation regarding Governor Carlson, Phillip Morris, Inc., New York Society for International Affairs, and American-European Community Association. The Board ordered that the findings and the record of the investigation be made a part of the public records of the Board (see copy of findings attached).

Investigation of a Contribution from an Unregistered Committee

The Board reviewed the matter of a contribution from the Shakopee Mdewankanton Sioux community ("Community"), an unregistered committee, to the Minnesota DFL State Central Committee ("Committee"). By letter dated November 7th, Alan Weinblatt, counsel for the Committee stated that the contribution will be returned to the Community. The Board ordered that the matter be made a part of the public records of the Board and if the contribution is not returned to the community before December 31,1997, the matter be brought back to the Board at its meeting of January 23, 1998. (see copies of correspondence attached).

ADJOURNMENT

Meeting adjourned.

Respectfully submitted,

Sidney Pauly, Secretary

(Minutes by staff)

TO       :    JEANNE OLSON                            DATE   :    November 13, 1997  
              Executive Director, Campaign Finance                                   
              and                                                                    
              Public Disclosure Board                                                


FROM    :     SUSAN GRETZ                            PHONE   :   297-2424 (Voice)   
              Assistant Attorney General                         296-1410 (TDD)     
              Labor Law Division                                                    


SUBJECT  :    Status Report of Campaign Finance and Public Disclosure Board       
Matters                                                             


I. MAJOR CASES/MAJOR ISSUES:

None at this time.

II. ENFORCEMENT MATTERS.

CFPDB v. Michael Forbes and the Olmstead County DFL Women's Club. Failure to file YE Report of Receipts and Expenditures and pay $100.00 late filing fee. Default judgment was granted at 9/9/97 hearing. We have received certified judgment from Ramsey County, which is in the process of being docketed in Olmsted County. (Roe)

CFPDB v. Jill Henderson, the Stebbens for State Senate Committee, and the Stebbens for State Representative Committee. Failure to file YE Report of Receipts and Expenditures and pay $200.00 in late filing fees. While we have served Henderson and the Committees with summons and complaint, attempts at service on Stebbens have been unsuccessful. Default judgment papers served this week. Default hearing set for December 22, at 9:00 a.m. (Roe)

CFPDB v. Michael Schultz and the Schultz Volunteer Committee. Failure to file YE Report of Receipts and Expenditures and pay $100.00 late filing fee. As of 9/9/97, we have been unable to complete service on the Committee because Schultz is never at last known address (we personally served Schultz by leaving summons and complaint with his mom at that address). He is the only registered representative of the Committee. We are confirming that Schultz currently resides in Oregon, and if so, will confirm with Board whether service should be attempted there. (Tichey)

CFPDB v. Jeanette Smith and the 19th Senate District DFL. Board granted partial waiver of fee at 10/31/97 Board meeting. We will close file.

CFPDB v. Rick Stafford and the 61st Senate District DFL. Failure to file YE Report of Receipts and Expenditures and pay $100.00 late filing fee. Report and late filing fee were paid. File returned to Board for collection of service of process fees. (Tichey)

CFPDB v. Steve Swonder. Failure to file Supplementary Statement of Economic Interest due 4/15/97 and pay $100.00 late filing fee. Summons and Complaint served this week. (Tichey)

CFPDB v. Harold High. Failure to file Amended Report of Receipts and Expenditures due 1/31/97 and pay $100.00 late filing fee. Demand letter sent. Report was filed, and file returned to Board for collection of late filing fee via conciliation court. (Tichey)

12. CFPDB v. Heisenfelt. Failure to pay fine for acceptance of contributions in excess of statutory limits. Demand letter sent on 10/16/97. Drafting summons and complaint. (Roe)

13. CFPDB v. Kevin Correy: Action for return of public subsidy money. Demand letter sent 11/12/97. (Tichey)

14. CFPDB v. Dougas Hofman: Report filed, so action for return of public subsidy extinguished. We will close our file. (Tichey)

15. CFPDB v. Bradley Clifford: Action for collection of late filing fee. Demand letter sent. File returned to Board. (Tichey)

16. CFPDB v. Mark Nygaard: Action for failure to file Lobbyist Disbursement Reports for January 1, 1997 to June 30, 1997. Mr. Nygaard has indicated that he has not lobbied since April of 1997. Board has notified Mr. Nygaard that it cannot terminate his registration unless reports are filed. Attempting contact by telephone. (Roe)

17. CFPDB v. Lebens: Failure to file Year End Report of Receipts and Expenditures due January 31, 1997. Mr. Lebens filed the report and paid late filing fee on August 27, 1997, but failed to pay $80.00 service of process fee. Demand letter sent November 10, 1997. (Roe)

18. Files Referred to MCE for Post-Judgment Collection:

Roger Anderson

Stephen Baretz

Dale Ubelhoer and the Paul Revere PAC

George Bateman

Diane Listerud and the Paul Revere PAC

Charles J. O'Connor

Mark G. Nygaard and R-KIDS

Al LaFontaine

Jill Block, Kevin Correy and the Kevin Correy for Senate Committee

19. CFPDB v. Phil Ratte: Bench warrant remains for Ratte.

STATE OF MINNESOTA CAMPAIGN FINANCE AND PUBLIC DISCLOSURE BOARD

(formerly Ethical Practices Board)

FINDINGS IN THE MATTER OF COMPLAINTS REGARDING

GOVERNOR ARNE CARLSON AND PHILIP MORRIS INCORPORATED

Procedural Background

On August 11, 1997, Brian Bates and Michael Ravnitzky filed a complaint with the Campaign Finance and Public Disclosure Board ("Board") alleging that Governor Arne Carlson and Philip Morris Incorporated violated certain provisions of Minnesota Statutes, Chapter 10A. Supplements to the complaint were filed by Brian Bates on August 29, 1997 and by Michael Ravnitzky on November 4, 1997.

On October 9, 1997, Senator John Marty filed a complaint with the Board alleging that Governor Arne Carlson and Philip Morris Incorporated violated certain provisions of Minnesota Statutes, Chapter 10A.

Both complaints allege that Governor Carlson accepted a prohibited gift from Philip Morris Incorporated, a lobbyist principal, and that the gift was in the form of an eight day trip to Australia in June, 1996, worth about $7,000. The complaints further allege that even though the gift was offered by the National Governors' Association ("NGA") and sponsored by the New York Society for International Affairs ("NYSIA") and the American-European Community Association ("AECA"), two not for profit organizations, it was financed indirectly by Philip Morris Incorporated through large contributions made to the NYSIA and AECA. Both complaints further allege that acceptance of the gift violated Minn. Stat. §10A.071, which prohibits gifts from a lobbyist or lobbyist principal to officials, and prohibits officials from accepting gifts from a lobbyist or lobbyist principal.

The evidence submitted by Brian Bates and Michael Ravnitzky in support of their complaint consists of copies of articles from several newspapers and other publications. Senator John Marty filed his complaint based on published news reports, but did not submit copies of the reports.

Tanja Kozicky, counsel to Governor Carlson, addressed the matter in a letter dated October 24, 1997. Counsel Kozicky stated that when the invitation for the trip was received an investigation was made into the groups offering and funding the trip. It was determined that the NGA, NYSIA, or AECA did not have lobbyists registered with the Board, and that they were not lobbyist principals. Counsel Kozicky further stated that even if Philip Morris Incorporated supplied funding for the trip, it would not be a prohibited gift because Governor Carlson is a member of a group, the NGA, the majority of whose members are not officials, and the trip was offered to all members of the group.

James Erickson, counsel for Philip Morris Incorporated, addressed the matter in a letter dated October 22, 1997. Counsel Erickson stated that the trip to Australia was an official NGA tour, which received financial support from the NYSIA and the AECA. Counsel Erickson further stated that Philip Morris Incorporated gave contributions to NYSIA or AECA, but did not convey any expressed or implied direction for the use of those contributions.

Christopher Wolf, counsel for the NGA stated in letters dated October 22, and October 23, 1997, that all members of the NGA were invited to participate in the trip to Australia. Counsel Wolf further stated that only governors of the fifty states and five commonwealths and territories are eligible for membership in the NGA.

The matter was considered by the Board in executive session on August 22, and September 26, 1997. The Board further considered the matter in executive session on October 31, 1997, at which time the Board combined the complaints for the purpose of investigation and issuing findings concerning probable cause. Governor Carlson and Philip Morris Incorporated did not request to have representatives present at those meetings. The matter was considered based on the complaints, responses supplied by counsel for Governor Carlson and Philip Morris Incorporated, and submissions by the NGA.

Based on the record before it, the Board issues the following:

STATEMENT OF THE EVIDENCE

1. Brian Bates and Michael Ravnitzky allege that Governor Arne Carlson participated in an eight day trip to Australia in June, 1996, and that the trip was financed indirectly by Philip Morris Incorporated, a lobbyist principal. Mr. Bates and Mr. Ravnitzky further allege that the trip was a prohibited gift under Minn. Stat. §10A.071.

2. Senator John Marty alleges that Governor Arne Carlson participated in an eight day trip to Australia in June, 1996, and that the trip was financed indirectly by Philip Morris Incorporated, a lobbyist principal. Senator Marty further alleges that the trip was a prohibited gift under Minn. Stat. §10A.071.

3. The complaints filed by Brian Bates/Michael Ravnitzky and Senator John Marty ("Complainants") were combined by the Board for the purpose of investigation and issuing findings concerning probable cause.

4 Governor Arne Carlson is a public official as defined in Minn. Stat. §10A.01, subd. 18(b).

5. Philip Morris Incorporated is a lobbyist principal which has lobbyists registered with the Campaign Finance and Public Disclosure Board.

6. The National Governors' Association ("NGA") is an association open only to governors of the fifty states and the five commonwealths and territories. By virtue of the State's payment of membership dues, Governor Carlson is a member of the NGA. A majority of the members of the NGA are not officials as defined under Minn. Stat. §10A.071, subd. 1(c).

7. Governor Carlson accepted an invitation by the NGA to participate in a trip to Australia in June, 1996, sponsored by the New York Society for International Affairs ("NYSIA") and the American-European Community Association ("AECA"), two not for profit organizations. All members of the NGA were invited to participate in the trip sponsored by the NYSIA and the AECA.

8. The Complainants allege that Philip Morris Incorporated made large contributions to the NYSIA and the AECA, and that as a result the trip was actually a prohibited gift paid for by a lobbyist principal.

Based on the above Statement of the Evidence, the Board makes the following:

FINDINGS CONCERNING PROBABLE CAUSE

1. The National Governors' Association invited all of its members to participate in a trip to Australia in June, 1996. The trip was sponsored by the New York Society for International Affairs and the American-European Community Association, two not for profit organizations.

2. Governor Carlson is a member of the National Governors' Association, the majority of whose members are not officials as defined under Minn. Stat. §10A.071.

3. Minn. Stat. §10A.071, prohibits a lobbyist or lobbyist principal from giving a gift or requesting another to give a gift to an official. The statute further prohibits an official from accepting a gift from a lobbyist or lobbyist principal. However, Minn. Stat. §10A.071, subd. 3(b)(1), provides that the prohibition does not apply if the gift is given because of the recipient's membership in a group, a majority of whose members are not officials, and an equivalent gift is given to the other members of the group. Making the gift available to all members of the group is sufficient to meet the requirement that the gift be given to all members, even if some of the members of the group do not accept it.

4. The evidence submitted is not sufficient to determine whether Philip Morris Incorporated should be considered the giver of the gift because of its contributions to the New York Society for International Affairs and the American-European Community Association.

5. It is not necessary that the Board determine to what entity the gift should be attributed, because even if the gift was requested or given by a lobbyist or a lobbyist principal, it falls within the exception to the gift prohibitions provided in Minn. Stat. §10A.071, subd. 3(b)(1).

6. There is no probable cause to believe that the gift to Governor Arne Carlson of the trip to Australia in June, 1996, was prohibited by Minn. Stat. §10A.071.

Based on the above Findings, the Board issues the following:

ORDER

The complaints of Brian Bates/Michael Ravnitzky and Senator John Marty regarding Governor Arne Carlson and the Philip Morris Corporation are dismissed in all respects. The Board investigation of this matter is hereby made a part of the public records of the Board pursuant to Minn. Stat. §10A.02, subd. 11.

Copies of this document shall be provided to the complainants and the respondents.

Dated: 11/21/97

G. Barry Anderson, Chair
Campaign Finance and Public Disclosure Board