-Caveat Lector-

http://www.judicialwatch.org/pressrelease/FECcomplaint.htm

March 23, 2001

VIA CERTIFIED MAIL

Office of the General Counsel
Federal Election Commission
999 E Street, N.W.
Washington, D.C. 20463

Re: Complaint Against Senator Hillary Rodham Clinton.

Dear Sir/Madam:

  Judicial Watch, Inc., (hereinafter �Judicial Watch�) is a
non-profit, public interest law firm that investigates and
prosecutes government corruption.  Judicial Watch, in the public
interest, hereby submits this complaint to the Federal Election
Commission against Senator Hillary Rodham Clinton of New York
State.

Specifically, Judicial Watch alleges Senator Hillary Rodham
Clinton is in violation of the provisions of 2 U.S.C. � 431(2)
and 2 U.S.C. � 441a of the Federal Election Campaign Act
(�FECA�), which limit the amount of contributions any federal
candidate can receive.  The FEC publication Supporting Federal
Candidates: A Guide for Citizens, define the term �contribution�
as: �donations of checks or currency, donated items or services,
purchases of fund-raising tickets and items, loans, endorsements
and guarantees of bank loans and advances of personal funds.� [1]
(emphasis added).  2 U.S.C. � 431(8) defines the term
�contribution� to include: � any gift, subscription, loan,
advance, or deposit of money or anything of value made by any
person for the purpose of influencing any election for Federal
office.� (Emphasis added).  Senator Clinton was a candidate for
federal elective office within the meaning of the FECA as of May
16, 1999, and her conduct must be taken into account from that
date forward.  Hillary Rodham Clinton as both Candidate and
United States Senator has accepted gifts from constituents and
others totaling over $190,000.00.[2]

These gifts are reported to include items of furniture, artwork,
china, flatware, apparel, electronics, and lighting.  Ms. Denise
Rich[3], the estranged wife of Mr. Marc Rich, gave $70,000 to
help fund Hillary Clinton�s Senate Campaign and gifts such as two
coffee tables and two chairs valued at over $7,375.  Mr. Marc
Rich received a pardon from Senator Clinton�s husband, President
Clinton[4], in what appears to be an illegal, unethical quid pro
quo.

The House Committee on Government Reform is conducting an
investigation into the pardon of Marc Rich.  The Committee
recently questioned Ms. Denise Rich on the pardon of her
ex-husband and gifts that she gave to former President Clinton or
to Senator Hillary Rodham Clinton.  In the matter of both
questions Ms. Denise Rich asserted her privilege under the Fifth
Amendment of the United States Constitution and refused to answer
questions submitted by the Committee on Government Reform.  See
Exhibit 2, attached.  Ms. Denise Rich�s invocation of the Fifth
Amendment, coupled with her lack of cooperation and other evasive
behavior lead to an inference that, in fact, Ms. Rich�s
contributions to the Clintons were in exchange for the pardon of
Marc Rich.  See S.E.C. v. Netelkos, 592 F.Supp.906 (D.C.N.Y.
1984); Baxter v. Palmigiano, 425 U.S. 308, 318-319 (1975) (In
civil cases, courts may draw adverse inferences from witnesses�
invocation of the Fifth Amendment privilege.).

 In addition, courts may also draw adverse inferences against a
party based upon the assertion of the Fifth Amendment privilege
by an agent or employee. The factors courts consider in
determining whether to draw an adverse inference against a party
based upon a Fifth Amendment invocation by another are: (1) the
nature of the witness� relationship with the loyalty to the
party; (2) the degree of control the party has vested in the
witness with regard to the facts and subject matter of
litigation; (3) whether the witness� assertion of the privilege
advances the interests of the party; and (4) whether the witness
was a key figure in the litigation and played a controlling role
in the underlying facts.  See LiButti v. United States, 107 F.3d
110, 123-24 (2nd Cir. 1997).  In LiButti, the Court emphasized
that the above circumstances may be unique to a particular case,
and that �the overarching concern is fundamentally whether the
adverse inference is trustworthy under all the circumstances and
will advance the search for truth.� Id. at 124; see also RAD
Services, Inc. v. Aetna Casualty and Surety Company, 808 F.2d 271
(3rd Cir. 1986).  �An adverse inference may be given significant
weight because silence when one would be expected to speak is a
powerful persuader.� Libutti v. United States, 178 F.3d 114, 120
(2nd Cir. 1999) (citing United States ex rel. Bilokumsky v. Tod,
263 U.S. 149, 153-54 (1923)).

The law could not be more clear and strong--adverse factual
inferences must be drawn against Senator Hillary Rodham Clinton
based upon Ms. Denise Rich�s invocation of the Fifth Amendment
privilege against self-incrimination, regarding her gifts to
Senator Hillary Rodham Clinton.  In addition to a Congressional
investigation, a criminal investigation by prosecutors in New
York has been opened regarding the pardon of Marc Rich and
whether he bought a pardon by donating gifts to Senator Hillary
Rodham Clinton through his ex-wife, Ms. Denise Rich.  The United
States attorney responsible for the investigation is Mary Jo
White, a Clinton appointee, which raises the level of doubt
regarding the merit of such investigation or whether this
investigation is simply a political spin to protect Senator
Hillary Rodham Clinton.

An e-mail dated December 19, 2000 from Robert Fink (Marc Rich�s
Attorney) to Avner Azulay, the Director of Marc Rich�s foundation
in Tel Aviv (also a former Mossad operative) mentions �Hillary�
and that she is on very friendly terms with Avraham Burg, the
Speaker of the Knesset.  The subject matter discusses the
possibility of having Avrahm Burg call �Potus� (President of the
United States) or �Hillary� on behalf of the Marc Rich petition.
See Exhibit 5, attached.  Another e-mail dated December 26, 2000
from Robert Fink to Jack Quinn (Marc Rich�s Attorney) discusses
that Ms. Denise Rich �is the best person to call Hillary.� In an
additional e-mail that same day from Robert Fink to Jack Quinn,
the �HRC option� is discussed as the only option to have �real
potential� and that there would be �peril� if not handled
properly.  See Exhibit 6, attached.

 Judicial Watch understands that the FEC has strict rules and
regulations regarding disclosure.  FEC publication �Supporting
Federal Candidates: A Guide for Citizens� states that Federal
election laws requires candidate committees, party committees,
and political action committees who receive contributions in
excess of $200 from any individual to disclose the name of the
contributor.  Since the FEC�s definition of a �contribution� is
clear and such gifts such as furniture were not disclosed,
Senator Hillary Rodham Clinton is in violation of FEC rules and
regulations regarding disclosure.  It would be naive to justify
the actions of Ms. Denise Rich as her simply making a normal
contribution since she and Senator Hillary Rodham Clinton
apparently violated the intent of the limit of campaign
contributions and such donations were given in exchange for a
Presidential Pardon of Marc Rich.  Any actions by Hillary Rodham
Clinton regarding the petition for a Presidential Pardon for Marc
Rich can clearly been seen as an �offset to the contributions� by
Denise Rich.

Also, as reported by the Washington Times and Washington Post,
Hugh Rodham, Senator Hillary Rodham Clinton�s brother, received
almost $400,000 for services regarding the pardon of Glenn
Braswell and the commutation of Carlos Vignali.  Glen Braswell
was pardoned by former President Clinton and the sentence of
Carlos Vignali was commuted.  Mr. Vignali was serving a 15-year
term for distribution of illegal narcotics.  Mr. Vignali�s
father, Horacio Vignali, contributed nearly $200,000 to the
Democratic Party.  Federal prosecutors were in opposition to the
Vignali Commutation, but despite their pleas of opposition his
sentence was still commuted. [5]

Senator Clinton maintains a close relationship with her brother
Hugh Rodham, which has been noted by the media, including
speaking for his senate campaign in 1994.  It would be naive to
believe that Hillary Rodham Clinton was unaware of Hugh Rodham�s
pardon activities. Senator Clinton also indicated in her February
22, 2001 press conference that the $400,000 Hugh Rodham received
was being returned. On March 4, 2001, Attorney Nancy Luque, who
is representing Hugh Rodham, announced that Hugh Rodham has
returned only $300,000 of the money he received for his services.
One can only be left with the question as to what happened to the
missing $100,000.  The concept can be built that because of
Hillary Rodham Clinton�s close relationship with Hugh Rodham and
her lack of credibility regarding the return of such money, it�s
likely Hillary Rodham Clinton herself benefitted financially from
the money Hugh Rodham received.  This matter should also be
investigated, especially in light the other brother of Hillary
Rodham Clinton, Tony Rodham is involved in the scandal. [6] See
Exhibit 7, attached.

In a press conference with Senator Hillary Rodham Clinton held on
February 22, 2001 in the Russell Senate Office Building, Senator
Clinton made the statement, �Oh, you know, as I have said in the
past, when it became apparent around Christmas that people knew
the president was considering pardons, there were many, many
people who spoke to me or, you know, asked me to pass on
information to the White House Counsel�s Office. I�ve already
said that I did that , and I did.  There were many, many people
who had an interest, a friend, a relative, but it was all passed
on to the White House Counsel�s Office, and they along with the
president, made the decisions.� Senator Clinton�s statements in
her press conference clearly point out that she was aware of
pardon requests.  As reported by the media, William Cunningham
III, Mrs. Clinton�s treasurer during her Senate Campaign, has
been implicated regarding the Presidential Pardon of Robert
Clinton Fain and James Lowell Manning, who were convicted on tax
charges.  Mr. Cunningham was paid $4,000 for his services
regarding the pardon application of Fain and Manning. [7]

The FEC also has a serious obligation to investigate another
apparent illegal, unethical quid pro quo surrounding Senator
Clinton�s involvement in the clemency grants of four men from the
Hasidic community of New Square, Rockland County, New York.
Apparently, after receiving promises from Candidate Clinton that
she would support clemency for the Hasidim, Candidate Clinton
received 99% of the community�s votes (1,400 to 12 votes for Mr.
Lazio).  Remarkably, the rest of New York�s Hasidic community
voted overwhelmingly in favor of Candidate Clinton�s opponent.[8]
The clemency grants were for men convicted of cheating the
federal government of approximately 40 million dollars in student
aid grants for the needy.  In addition to promising support for
Hillary Clinton�s Senate candidacy, the leaders of New Square met
with Mrs. Clinton, one of the meetings being in the White House,
where it was likely they discussed the quid pro quo arrangement.
The evidence shows that Senator Clinton was the only U.S. Senator
involved in the pardon process, receiving financial and other
remuneration from the petitioners and/or their agents.

The commutations by former President Clinton and Hillary Rodham
Clinton�s role are also reportedly under criminal investigation.

Senator Clinton took her oath of office and assumed her official
duties on January 3, 2001.  She reportedly claimed and took
direct personal possession of approximately $190,000 worth of
gift items, for her personal use and enjoyment, on or about
January 20, 2001 � seventeen days into office and nearly two
years since becoming a candidate for elective federal office.
Senator Clinton�s behavior in this matter is so outrageous as to
compel even the Washington Post to opine in their lead editorial
of January 24, 2001 that �they have no capacity for
embarrassment.  Words like shabby and tawdry come to mind.  They
don�t begin to do it justice.�

Judicial Watch is a 501 (c)(3) not-for-profit public interest
organization.  One of its purposes is to provide the public with
information which exposes government activities that are contrary
to the law.  Judicial Watch is, an educational foundation, as
well as a law firm, which uses several mechanisms for the
dissemination of the information it acquires, and operates to
ensure that this information will be made available to the public
on a daily basis:

Judicial Watch, as a press entity itself, produces several press
releases each week.

The Judicial Watch Newsletter has a monthly circulation of over
300,000 copies nationwide.


* Judicial Watch maintains a website on which people can view
copies of, among other things, FOIA documents, press releases,
responsive documents, deposition transcripts and court opinions.
This website is viewed by over 20,000 people per day on average,
and on a few occasions, had logged up to 1,000,000 visitors in a
single day.

* Over 60,000 people subscribe to our �Infonet� listserve for
daily updates on our lawsuits, FOIA requests, investigations and
public education programs.

* Judicial Watch is involved in the production and broadcast of a
twice weekly one hour news and information television program.
Judicial Watch Report, is seen across the country.

* Judicial Watch produces its own weekly radio program, The
Judicial Watch Report, which airs nationwide on 36 stations and
on the Internet.  Judicial Watch disseminates information it
obtains through this medium as well.

*Judicial Watch�s Chairman has been invited to testify before
Congressional committees as an expert witness on legal matters,
including, but not limited to the Privacy Act and the Freedom of
Information Act.

* Judicial Watch�s Chairman and other employees frequently appear
on nationally broadcast radio and television programs to provide
information, analysis and commentary concerning government
corruption and other legal issues.

* Judicial Watch has been credited by Courts, the Congress and
various media outlets on several occasions for uncovering
information and documents concerning government corruption,
illegal and/or inappropriate activities, and documented instances
of government attempts to �stonewall� requests for information
and accountability in the public interest.[9]

* Judicial Watch hosts and sponsors conferences and rallies as
public education forums for the dissemination of the information
it acquires.  For example, Judicial Watch hosted an Ethics in
Government 2000 Conference at the Washington Hilton on October
20-21, 2000.


In short, Judicial Watch�s efforts to expose government
corruption make news on almost a daily basis, and it functions,
in part, as a member of the media.

Senator Hillary Rodham Clinton�s failure to properly disclose
contributions through the FEC by Ms. Denise Rich and the services
provided for such contributions presents an attempt to keep
public information private.  Judicial Watch and the American
public are entitled to such information and Judicial Watch is an
instrument for providing information to the American public. The
cover-up of information by Senator Hillary Rodham Clinton
provides information injury to Judicial Watch as such information
would have been provided to the public by Judicial Watch.

Judicial Watch has proven before that we have �informational
standing.� Judicial Watch demonstrated that the DNC and the 1996
Clinton/Gore reelection campaign were required under FECA to
report � offsets to contributions,� �contribution refunds� and
other �disbursements� to the FEC, which the FEC in turn was
obligated to make public.  The sale of seats on Department of
Commerce trade missions, effectively coopted by the DNC and the
1996 Clinton/Gore reelection campaign and sold to donors in
exchange for campaign contributions, were �offsets to
contributions,� �contribution refunds� or other disbursements�
that had to be reported under FECA.

Considering all the above circumstances, any reasonable person
would have to conclude that Senator Clinton�s acceptance of gifts
and campaign contributions were in exchange for the pardons her
husband, Bill Clinton, bestowed upon Marc Rich and the Hasidic
Jews, among others.  This bribery scheme is part of a pattern of
similar conduct.  Indeed, in the �Chinagate� scandal, Nolanda
Hill testified that Mrs. Clinton was the mastermind behind
selling seats on Department of Commerce trade missions for
campaign contributions.[10]

Judicial Watch, in the public interest, respectfully requests
your prompt investigation of these clear violations of law by
Senator Clinton.  Thank you for you attention to this important
matter.

Sincerely,

JUDICIAL WATCH, INC.
Thomas J. Fitton
President
WASHINGTON, DISTRICT OF COLUMBIA

Subscribed and sworn to before me this 23rd day of March, 2001 by
Thomas J. Fitton, who is personally known to me.

________________________________________

Christopher J. Farrell
Notary Public, District of Columbia
My Commission expires November 14, 2004
-------------------------------------------------------------------

[1] Found at www.fec.gov/pages/citnlist.htm

[2]Clinton Discloses Gifts He�ll Keep, Associated Press, January
19, 2001; Thomas B. Edsall, Clintons Take Away $190,000 In Gifts;
Holywood Helped With Furnishings, Washington Post, January 21,
2001, at A18; Kenneth Bazinet, Clintons Cart Off Truckload of
Gifts; Amount is Called �Absolutely Unprecedented,� Detroit Free
Press (January 21, 2001)
<http://www.freep.com/news/politics/clint21_20010121.html>; Gifts
Galore, The Orlando Sentinel, January 21, 2001, at A23.; Maxim
Kniazkov, Clinton Rakes In More Than 190,000 Dollars in Gifts in
2000, Agence France Press, January 21, 2001.; Bill Nichols, After
Chaos of Last Days; He�s Citizen Bill Clinton, USA Today, January
22, 2001, at 8A.; Dan K. Thomasson, Clinton Around Forever,
Scripps Howard News Service, January 22, 2001.; Clinton Keeping
Gifts Valued at $190,000, The New York Times, January 22, 2001,
at A11; Maureen Dowd, Liberties; Cats, Dogs and Grifters, The New
York Times, January 24, 2001, at A19; Count the Spoons,
Washington Post, January 24, 2001, at A14; Who Says You Can�t
Take It With You, Washington Post (January 26, 2001)
<http://www.washingtonpost.com/wp-dyn/articles/A48477-2001Jan25.html>.
See Exhibit 1, attached.

[3]Who Says You Can�t Take It With You, Washington Post (January
26, 2001)
<http://www.washingtonpost.com/wp-dyn/articles/A48477-2001Jan25.html>.
See Exhibit 3, attached.

[4]Pardon Grants January 2001, U.S. Department of Justice,
<http://www.usdoj.gov/opa/pardonchart1st.html>.  See Exhibit 4,
attached.

[5] Jerry Seper, Hillary�s brother returns cash for pardon work,
Washington Times, February 22, 2001, at front page.  See Exhibit
8, attached.

[6] CNN.com, �Tony Rodham says he talked to Clinton about pardon,
March 3, 2000, found at
www.cnn..com/2001/ALLPOLITICS/03/03/clinton.pardons.rodh/index.html

[7] John Solomon, Sen. Clinton Aide Helped in Pardons, Associated
Press Writer (February 22, 2001)
<http://www.dailynews.yahoo.com/h/ap/200101222/ts/clinton_pardons_34.html>.
See Exhibit 9, attached.

[8]Larry Cohler-Esses, U.S. Att�y Ripped Hasidic Pardons, Daily
News, January 25, 2001, at 4; Larry Cohler-Esses, Mayor Askes
Probe of Clemency, Daily News, January 25, 2001, at 4;

 Larry Cohler-Esses, Hasidim Pushed for Hil,� Daily News, January
26, 2001, at 2; Jonathon Peterson and Lisa Getter, Clinton Pardon
Raises Questions of Timing, Motive, Los Angeles Times, January
28, 2001, at A1;  John Riley, Questioning Clinton; Pardon, Other
Distractions Shroud New Senator�s Work, Newsday, January 29,
2001, at A7.  See Exhibit 10, attached.

[9]See attached press releases (exhibit 11).

[10]Transcript of Testimony of Nolanda Hill, p. 55:19 � 59:9,
Monday March 23, 1998 in Judicial Watch v. Department of
Commerce, Civil Action No. 95-133 (RCL).  See Exhibit 12,
attached.


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             Kadosh, Kadosh, Kadosh, YHVH, TZEVAOT

  FROM THE DESK OF:
                    *Michael Spitzer*  <[EMAIL PROTECTED]>
                     ~~~~~~~~~~~~~~~
  The Best Way To Destroy Enemies Is To Change Them To Friends
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