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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 512 10TH STREET NW |
Address2 | |
City | WASHINGTON |
State | DC |
Zip Code | 20004 |
Country | USA |
3. Principal place of business (if different than line 2)
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State | |
Zip Code | |
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5. Senate ID# 28481-12
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6. House ID# 316440000
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TYPE OF REPORT | 8. Year | 2009 |
Q1 (1/1 - 3/31) | Q2 (4/1 - 6/30) | Q3 (7/1 - 9/30) | Q4 (10/1 - 12/31) |
9. Check if this filing amends a previously filed version of this report
10. Check if this is a Termination Report | Termination Date | |
11. No Lobbying Issue Activity |
INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
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12. Lobbying | 13. Organizations | ||||||||
INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
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Provide a good faith estimate, rounded to the nearest $10,000, of all lobbying related income for the client (including all payments to the registrant by any other entity for lobbying activities on behalf of the client). | 14. REPORTING Check box to indicate expense accounting method. See instructions for description of options. | ||||||||
Method A.
Reporting amounts using LDA definitions only
Method B. Reporting amounts under section 6033(b)(8) of the Internal Revenue Code Method C. Reporting amounts under section 162(e) of the Internal Revenue Code |
Signature | Digitally Signed By: Douglas Johnson, Legislative Director |
Date | 07/18/2009 |
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code BUD
16. Specific lobbying issues
Contacts to House and Senate offices in support of continuation of traditional prolife provisions in appropriations bills for fiscal year 2010, including Hyde Amendment to HHS appropriations bill, prohibition on use of appropriated funds for abortions in Financial Services appropriations bill (H.R. 3170), and the prohibition on abortion-related litigation by Legal Services Corporation in Commerce-Justice appropriations bill (H.R. 2847).
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Douglas |
Johnson |
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Susan |
Muskett |
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Andrea |
Lyon |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code CIV
16. Specific lobbying issues
Response to inquiries regarding possible amendments to "hate crimes" legislation (H.R. 1913); no formal position taken on any amendments offered in the House.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Douglas |
Johnson |
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Susan |
Muskett |
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Andrea |
Lyon |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code COM
16. Specific lobbying issues
Contacts in support of S. 34 and H.R. 226, Broadcaster Freedom Act, to prevent reimposition of the so-called Fairness Doctrine.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Douglas |
Johnson |
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Susan |
Muskett |
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Andrea |
Lyon |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code FAM
16. Specific lobbying issues
Contacts with House and Senate in opposition to the "Freedom of Choice Act" (FOCA), a bill to invalidate virtually all state and federal laws and policies that in any way limit access to abortion, the reintroduction of which is anticipated sometime during the 111th Congress. (continued)
Contacts to House in support of Child Interstate Abortion Notification Act (CIANA) (H.R. 634) and the Child Custody Protection Act (unnumbered).
Contacts in support of S. 85 and H.R. 614, legislation to exclude certain abortion providers from funding under Title X of the Public Health Service Act.
Contacts in support of H.R. 636, the Positive Alternatives Act, sponsored by Rep. Michele Bachmann.
Contacts generally supportive of certain titles of S. 270 and H.R. 605, Pregnant Women and Family Support Act, while not taking a position on the overall omnibus legislation at this time. Contacts expressing objections to certain components of S. 21 and H.R. 463.
Contacts in support of H.R. 649, the Ultrasound Informed Consent Act; H.R. 213, the Adoption Tax Relief Guarantee Act; and H.R. 195, the Informed Choice Act (aid for ultrasound machines for certain centers).
Consultations regarding legislation to protect conscience rights of health-care providers with respect to abortion, and contacts in support of Coburn Amendment No. 828 to the Senate budget resolution, S. Con. Res. 13.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Douglas |
Johnson |
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Susan |
Muskett |
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Andrea |
Lyon |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code FOR
16. Specific lobbying issues
Contacts in support of Chris Smith amendment to Foreign Relations Authorization Act (H.R. 2410), to prevent attacks on foreign abortion laws by the State Department Office for Global Women's Issues, and in opposition to the bill after the Rules Committee refused to make the amendment in order (see letters to the House dated June 5 and June 9, 2009). Contacts to Senate in opposition to ratification of CEDAW and to House in opposition to H.Res. 22, a pro-CEDAW resolution. (continued)
Contacts in support of H.R. 1967, sponsored by Rep. F. James Sensenbrenner, to prohibit funding of organizations that support or participate in the management of programs that include coercive abortion or involuntary sterilization.
Contacts to House expressing general concerns about abortion-related issues that may arise during anticipated reauthorization/rewrite of the Foreign Assistance Act.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Douglas |
Johnson |
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Susan |
Muskett |
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Andrea |
Lyon |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code HCR
16. Specific lobbying issues
Contacts in support of exclusion of abortion mandates and abortion subsidies from all health care reform legislation currently under development. Contacts in opposition to "Tri-Committee bill" draft released in House in June, 2009, and draft bill proposed by Senator Kennedy and referred to HELP Committee (unnumbered). Contacts encouraging certain House members to sign a letter originated by Rep. Dan Boren to Speaker Pelosi urging exclusion of abortion from "health care reform" legislation.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Douglas |
Johnson |
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Susan |
Muskett |
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Andrea |
Lyon |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code HCR
16. Specific lobbying issues
On Senator Max Baucuss Call to Action: Health Reform 2009 [commonly known as the Baucus White Paper on Health Reform], opposed rationing of health care, supported the addition of variable withhold financing method to avoid rationing. (continued)
On the Senate Health Education Labor and Pensions Chairmans Mark titled, Affordable Health Choices Act, Opposed rationing of health care. Supported the addition of variable withhold financing method to avoid rationing. Urged that the secretary be precluded from rejecting plans based on: their having a fee-for service structure, or by imposing premium price controls, or by placing treatment limits. Urged against the incentivizing the denial of treatments deemed to be cost-ineffective on quality of life grounds. Urged against reimbursement methods which give broad authority to the Secretary to prohibit reimbursement to providers on safe treatments or procedures they wish to prescribe. Urged the support of Sen. Enzi amendments, 7 and 8, which would prohibit use of comparative effectiveness research to ration healthcare based on the governments assessment of whether elderly, disabled or medically dependent individuals merit treatment by preventing treatment denial.
On potential Finance Committee Health Care legislation, opposed rationing of health care. Supported the addition of variable withhold financing method to avoid rationing. Urged that there be a prohibition of any standard that discounts the value of a period of life based on the patients present or predicted disability or quality of life. Urged that provisions be added to Comparative Effectiveness elements of any bill that would ensure that patients competence, age, expected length of life, present or predicted disability, degree of medical dependency, or quality of life not be used as the basis for denial of Medicare benefits to patients against their wishes.
On the Healthy Americans Act (S. 391), opposed rationing of health care, supported the addition of variable withhold financing method to avoid rationing.
Discussions generally on potential health care reform generally, opposed rationing of health care, supported the addition of variable withhold financing method to avoid rationing.
On the tri-committee House draft, H. R. __, titled To provide affordable, quality health care for all Americans and reduce the growth in health care spending, and for other purposes, opposed rationing of health care. Supported the addition of variable withhold financing method to avoid rationing. Urged that the secretary be precluded from rejecting plans based on: their having a fee-for service structure, or by imposing premium price controls, or by placing treatment limits. Urged that there be a prohibition of any standard that discounts the value of a period of life based on the patients present or predicted disability or quality of life. Urged the removal of elements that incentivize denial of treatment. Urged against the incentivizing the denial of treatments deemed to be cost-ineffective on quality of life grounds. Urged against reimbursement methods which give broad authority to the Secretary to prohibit reimbursement to providers on safe treatments or procedures they wish to prescribe. Urged that provisions be added to Comparative Effectiveness elements of any bill that would ensure that patients competence, age, expected length of life, present or predicted disability, degree of medical dependency, or quality of life not be used as the basis for denial of Medicare benefits to patients against their wishes.
Discussion generally on potential Comparative Effectiveness elements of health reform bills, regarding comparative effectiveness standards in Medicare, worked to ensure that patients competence, age, expected length of life, present or predicted disability, degree of medical dependency, or quality of life will not be used as the basis for denial of Medicare benefits to patients against their wishes.
On Senate 1213, The Patient-Centered Outcomes Research Act of 2009, regarding comparative effectiveness standards in Medicare, worked to ensure that patients competence, age, expected length of life, present or predicted disability, degree of medical dependency, or quality of life will not be used as the basis for denial of Medicare benefits to patients against their wishes.
On Senate 1133, Empowering Medicare Patient Choices Act, supported the removal of language which creates an unacceptable disincentive for balanced counseling and assistance that genuinely attempts to elucidate patients values and preferences, and an incentive to steer them toward rejection of treatment, including life-preserving treatment. Urged for the inclusion of representatives of disability rights groups and groups who advocate for treatment without regard to patients quality of life. (continued)
On Senate 1263 Senior Navigation and Planning Act of 2009, supported the removal of language which creates a disincentive for balanced counseling and assistance that genuinely attempts to elucidate patients values and preferences, and an incentive to steer them toward rejection of treatment, including life-preserving treatment. Urged for the inclusion of representatives of disability rights groups and groups who advocate for treatment without regard to patients quality of life. Urged for continuing oversight and evaluation of created board. Urged for changes to provisions regarding portability of advanced directives across states. Urged for the inclusion of conscience protections.
On Senate 1150 Advance Planning and Compassionate Care Act of 2009, urged for a qualified oversight body make recommendations concerning various informational elements of the legislation. Strongly opposed provisions that would repeal provisions of the Assisted Suicide Funding Restriction Act. Sought the inclusion of protective language that would safeguard state modifications when the state adopted the Uniformed Health Care Decisions Act.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Thomas (Burke) |
Balch |
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Jennifer |
Popik |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code INS
16. Specific lobbying issues
Contacts in support of exclusion of abortion mandates and abortion subsidies from all health care reform legislation currently under development. Contacts in opposition to "Tri-Committee bill" draft released in House in June, 2009, and draft bill proposed by Senator Kennedy and referred to HELP Committee (unnumbered). Contacts encouraging certain House members to sign a letter originated by Rep. Dan Boren to Speaker Pelosi urging exclusion of abortion from "health care reform" legislation.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Douglas |
Johnson |
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Susan |
Muskett |
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Andrea |
Lyon |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code MED
16. Specific lobbying issues
Contacts in opposition to anticipated authorization legislation to allow or require federal funding of research that requires killing of human embryos and/or creation of human embryos by cloning, and urging continuation of Dickey-Wicker embryo-protection language on FY 2010 appropriations bill for Labor-HHS. (continued)
Contacts in support of H.R. 877, Patients First Act, sponsored by Reps. Forbes and Lipinski (to promote federal funding of ethical forms of stem cell research), and H.R. 1050, the Human Cloning Prohibition Act, sponsored by Reps. Bart Stupak and Zach Wamp, to prohibit the creation of embryos of the species homo sapiens by cloning.
Contacts in opposition to H.R. 872 and H.R. 873, sponsored by Reps. DeGette and Castle, and S. 487, sponsored by Senators Harkin and Specter, bills to authorize federal funding of embryo-destructive research.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Douglas |
Johnson |
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Susan |
Muskett |
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Andrea |
Lyon |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code MMM
16. Specific lobbying issues
On Senator Max Baucuss Call to Action: Health Reform 2009 [commonly known as the Baucus White Paper on Health Reform], opposed rationing of health care, supported the addition of variable withhold financing method to avoid rationing. (continued)
On the Senate Health Education Labor and Pensions Chairmans Mark titled, Affordable Health Choices Act, Opposed rationing of health care. Supported the addition of variable withhold financing method to avoid rationing. Urged that the secretary be precluded from rejecting plans based on: their having a fee-for service structure, or by imposing premium price controls, or by placing treatment limits. Urged against the incentivizing the denial of treatments deemed to be cost-ineffective on quality of life grounds. Urged against reimbursement methods which give broad authority to the Secretary to prohibit reimbursement to providers on safe treatments or procedures they wish to prescribe. Urged the support of Sen. Enzi amendments, 7 and 8, which would prohibit use of comparative effectiveness research to ration healthcare based on the governments assessment of whether elderly, disabled or medically dependent individuals merit treatment by preventing treatment denial.
On potential Finance Committee Health Care legislation, opposed rationing of health care. Supported the addition of variable withhold financing method to avoid rationing. Urged that there be a prohibition of any standard that discounts the value of a period of life based on the patients present or predicted disability or quality of life. Urged that provisions be added to Comparative Effectiveness elements of any bill that would ensure that patients competence, age, expected length of life, present or predicted disability, degree of medical dependency, or quality of life not be used as the basis for denial of Medicare benefits to patients against their wishes.
On the Healthy Americans Act (S. 391), opposed rationing of health care, supported the addition of variable withhold financing method to avoid rationing.
Discussions generally on potential health care reform generally, opposed rationing of health care, supported the addition of variable withhold financing method to avoid rationing.
On the tri-committee House draft, H. R. __, titled To provide affordable, quality health care for all Americans and reduce the growth in health care spending, and for other purposes, opposed rationing of health care. Supported the addition of variable withhold financing method to avoid rationing. Urged that the secretary be precluded from rejecting plans based on: their having a fee-for service structure, or by imposing premium price controls, or by placing treatment limits. Urged that there be a prohibition of any standard that discounts the value of a period of life based on the patients present or predicted disability or quality of life. Urged the removal of elements that incentivize denial of treatment. Urged against the incentivizing the denial of treatments deemed to be cost-ineffective on quality of life grounds. Urged against reimbursement methods which give broad authority to the Secretary to prohibit reimbursement to providers on safe treatments or procedures they wish to prescribe. Urged that provisions be added to Comparative Effectiveness elements of any bill that would ensure that patients competence, age, expected length of life, present or predicted disability, degree of medical dependency, or quality of life not be used as the basis for denial of Medicare benefits to patients against their wishes.
Discussion generally on potential Comparative Effectiveness elements of health reform bills, regarding comparative effectiveness standards in Medicare, worked to ensure that patients competence, age, expected length of life, present or predicted disability, degree of medical dependency, or quality of life will not be used as the basis for denial of Medicare benefits to patients against their wishes.
On Senate 1213, The Patient-Centered Outcomes Research Act of 2009, regarding comparative effectiveness standards in Medicare, worked to ensure that patients competence, age, expected length of life, present or predicted disability, degree of medical dependency, or quality of life will not be used as the basis for denial of Medicare benefits to patients against their wishes.
On Senate 1133, Empowering Medicare Patient Choices Act, supported the removal of language which creates an disincentive for balanced counseling and assistance that genuinely attempts to elucidate patients values and preferences, and an incentive to steer them toward rejection of treatment, including life-preserving treatment. Urged for the inclusion of representatives of disability rights groups and groups who advocate for treatment without regard to patients quality of life.
(continued)
On Senate 1263 Senior Navigation and Planning Act of 2009, supported the removal of language which creates a disincentive for balanced counseling and assistance that genuinely attempts to elucidate patients values and preferences, and an incentive to steer them toward rejection of treatment, including life-preserving treatment. Urged for the inclusion of representatives of disability rights groups and groups who advocate for treatment without regard to patients quality of life. Urged for continuing oversight and evaluation of created board. Urged for changes to provisions regarding portability of advanced directives across states. Urged for the inclusion of conscience protections.
On Senate 1150 Advance Planning and Compassionate Care Act of 2009, urged for a qualified oversight body to make recommendations concerning various informational elements of the legislation. Strongly opposed provisions that would repeal provisions of the Assisted Suicide Funding Restriction Act. Sought the inclusion of protective language that would safeguard state modifications when a state had adopted the Uniformed Health Care Decisions Act.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Thomas (Burke) |
Balch |
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Jennifer |
Popik |
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|
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code SCI
16. Specific lobbying issues
Contacts in opposition to anticipated authorization legislation to allow or require federal funding of research that requires killing of human embryos and/or creation of human embryos by cloning, and urging continuation of Dickey-Wicker embryo-protection language on FY 2010 appropriations bill for Labor-HHS. (continued)
Contacts in support of H.R. 877, Patients First Act, sponsored by Reps. Forbes and Lipinski (to promote federal funding of ethical forms of stem cell research), and H.R. 1050, the Human Cloning Prohibition Act, sponsored by Reps. Bart Stupak and Zach Wamp, to prohibit the creation of embryos of the species homo sapiens by cloning.
Contacts in opposition to H.R. 872 and H.R. 873, sponsored by Reps. DeGette and Castle, and S. 487, sponsored by Senators Harkin and Specter, bills to authorize federal funding of embryo-destructive research, including distribution of letter dated March 31, 2009.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Douglas |
Johnson |
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Susan |
Muskett |
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Andrea |
Lyon |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code GOV
16. Specific lobbying issues
Contacts in opposition to confirmation of Dawn Johnsen as assistant attorney general for the Office of Legal Counsel. Contacts raising questions regarding whether Judge Sonia Sotomayor, nominated to a seat on the U.S. Supreme Court, would respect the text and history of the Constitution, and refrain from overturning legislative enactments that are not inconsistent with that text and history.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Douglas |
Johnson |
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Susan |
Muskett |
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Andrea |
Lyon |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
Information Update Page - Complete ONLY where registration information has changed.
20. Client new address
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22. New General description of client’s business or activities
LOBBYIST UPDATE
23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client
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ISSUE UPDATE
24. General lobbying issue that no longer pertains
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AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
Internet Address:
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
1 | 3 | 5 |
2 | 4 | 6 |
FOREIGN ENTITIES
27. Add the following foreign entities:
Name | Address |
Principal place of business (city and state or country) |
Amount of contribution for lobbying activities | Ownership percentage in client | ||||||||||
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28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization
1 | 5 | 9 |
2 | 6 | 10 |
3 | 7 | 11 |
4 | 8 | 12 |