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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 1050 CONNECTICUT AVE., NW 4TH FLR |
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City | WASHINGTON |
State | DC |
Zip Code | 20036 |
Country | USA |
3. Principal place of business (if different than line 2)
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5. Senate ID# 1808-12
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6. House ID# 310280000
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TYPE OF REPORT | 8. Year | 2023 |
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 |
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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: Holly Cook |
Date | 1/22/2024 6:57:41 PM |
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
FY 2024 Commerce, Justice, Science and Related Agencies Appropriations - funding for the Legal Services Corporation; funding for the Department of Justice Executive Office for Immigration Review's Legal Orientation Program.
FY 2024 Financial Services and General Government Appropriations - Defense Services Office, Administrative Office of the US Courts.
FY 2024 Department of State, Foreign Operations, and Related Programs Appropriations - funding for democracy, human rights, and rule of law programs.
FY 2024 Legislative Branch Appropriations - funding for the Library and Law Library of Congress.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, White House Office, Justice - Dept of (DOJ), Health & Human Services - Dept of (HHS), State - Dept of (DOS), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), Legal Services Corporation
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 |
Michael |
O'Neill |
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Denise |
Cardman |
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Kristi |
Gaines |
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Holly |
Cook |
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Larson |
Frisby |
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Ken |
Goldsmith |
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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
H.R.17, S. 728 - Paycheck Fairness Act
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES
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 |
Denise |
Cardman |
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Holly |
Cook |
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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 EDU
16. Specific lobbying issues
Support for student loan debt forgiveness, reforming and strengthening the Public Service Loan Forgiveness (PSLF) program, reduced student loan interest rates and ability to refine loans, and the continued suspension of federal student loan payments.
General policy research and discussions surrounding student debt relief developments, including the Freedom to Invest in Tomorrows Workforce Act that would allow the use of 529 accounts for professional degrees and certifications.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Education - Dept of, Justice - Dept of (DOJ)
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 |
Michael |
O'Neill |
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Holly |
Cook |
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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 FIN
16. Specific lobbying issues
Consumer Financial Protection Bureau Statement of Policy Regarding Prohibition on Abusive Acts or Practices; Docket No CFPB-2023-0018; 88 Fed. Reg. 21883 (April 12, 2023)-provisions that could require creditor attorneys and law firms to act in the interests of consumers instead of their creditor clients in violation of the attorneys' existing ethical obligations or that would conflict with other existing state court ethical obligations
ENABLERS Act - draft legislation regulating certain attorneys and law firms as financial institutions under the Bank Secrecy Act and requiring them to report certain attorney-client privileged and other protected client information to the Treasury Department.
Restoring Court Authority Over Litigation Act - draft legislation clarifying that attorneys engaged in litigation should be regulated and disciplined solely by courts, federal agencies have no authority to regulate attorneys litigation activities, and parties in litigation have no federal private right of action against their opponents attorney for alleged litigation misconduct.
Department of the Treasury Financial Crimes Enforcement Network Final Rule on Beneficial Ownership Information Access and Safeguards; Document No. 2023-27973; RIN 1506-AB49/AB59, 88 Fed. Reg. 88732 (December 22, 2023).
Department of the Treasury Financial Crimes Enforcement Network Final Rule on Beneficial Ownership Information Reporting Requirements; Document No. 2022-21020; RIN 1506-AB49, 87 Fed. Reg. 59498 (September 30, 2022).
Department of the Treasury Financial Crimes Enforcement Network Advance Notice of Proposed Rulemaking on Anti-Money Laundering Regulations for Real Estate Transactions; Docket No.
FINCEN-2021-0007; RIN 1506-AB54, 86 Fed. Reg. 69589 (December 8, 2021).
Financial Action Task Force Public Consultation Paper, Proposed Updates to Risk-Based Guidance to the Real Estate Sector-provisions requiring attorneys to submit suspicious transaction reports on their clients high-risk real estate transactions even when the information is protected by the attorney-client privilege.
Financial Action Task Force White Paper for Public Consultation, Potential Amendments to Recommendation 24 (Transparency and Beneficial Ownership of Legal Persons)-provisions considering requiring attorneys to hold their company clients' beneficial ownership information and disclose it to government authorities.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Treasury - Dept of, White House Office
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 |
Larson |
Frisby |
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Holly |
Cook |
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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
Communications regarding increased support for investigation and prosecution of atrocity crimes, particularly crimes committed by Russian forces in Ukraine.
Draft legislation to amend U.S. law to extend domestic jurisdiction over crimes against humanity.
Support for U.S. ratification of the United Nations Convention on International Settlement Agreements Resulting from Mediation (Singapore Convention on Mediation).
Issues relating to facilitating U.S. support and engagement with the International Criminal Court.
Support for increased funding for democracy, human rights, and rule of law programs.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, State - Dept of (DOS), U.S. Agency for International Development (USAID)
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 |
Kristi |
Gaines |
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Holly |
Cook |
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Larson |
Frisby |
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Thomas |
Susman |
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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
H.R. 927, S. 325 - Supreme Court Ethics Act
H.R. 926, S. 359 - Supreme Court Ethics, Recusal, and Transparency Act of 2023
Support for authorizing new and filling existing vacant federal judgeships.
Issues regarding diversity jurisdiction - to treat unincorporated and incorporated entities the same.
H.Res.314 - to end the territorial incorporation doctrine.
Activity in support of expanding measures to address judicial security.
Support for permanently establishing/forming within the Department of Justice, the Office for Access to Justice.
Proposed federal laws/ regulations related to artificial intelligence, cybersecurity, data security, digital/personal privacy, intellectual property, in addition to how these issues could impact the legal profession, such as undermining the attorney-client privilege, the lawyers ethical duty to protect client confidentiality, the work product doctrine, and access to justice, as well as questions related to the federal courts longstanding authority to regulate and oversee the legal profession.
Comments on the proposed rule change on Foster Care Legal Representation, published on September 27, 2023 (88 FR 66769). T
Federal Energy Regulatory Commission Notice of Proposed Rulemaking on Duty of Candor; Docket No. RM22-20-000, 87 Fed. Reg. 49784 (August 12, 2022)-provisions regulating certain attorneys engaged in the practice of law and requiring them to disclose certain attorney-client privileged and other protected client information.
Draft Model Rules of Representative Conduct to be developed by an Administrative Conference of the United States working group that would regulate the conduct of attorneys and non-attorneys who represent parties and other interested persons in administrative adjudicative proceedings.
Administrative Conference of the United States study on Regulation of Representatives in Agency Proceedings to explore how federal agencies regulate the conduct of attorneys and non-attorneys who represent parties and other interested persons in administrative adjudicative proceedings, and related best practices for federal agencies.
Proposed Department of Justice Office of Legal Counsel legal opinion further clarifying the ability of government attorneys and other employees to participate more fully in outside organizations, including legal professional associations.
Revised Department of Justice ethics guidance (Representations Before the Government) further clarifying the ability of government attorneys and other employees to participate more fully in outside organizations, including legal professional associations.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), Congressional Budget Office (CBO), Justice - Dept of (DOJ), White House Office, Federal Energy Regulatory Commission (FERC)
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 |
Michael |
O'Neill |
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Denise |
Cardman |
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Larson |
Frisby |
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Holly |
Cook |
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Kristi |
Gaines |
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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 IMM
16. Specific lobbying issues
S. 3178, H.R.6145 Immigration Court Efficiency and Childrens Court Act of 2023
S. 3965, Fair Day in Court for Kids Act of 2023
General issues regarding the potential dismantling of asylum protections in supplemental appropriations negotiations.
H.R. 5415, Working for Immigrant Safety and Empowerment Act of 2023 - provisions relating to protections for immigrant victims of crime, including human trafficking, rape, torture, domestic violence, sexual assault, and sexual exploitation.
S.1885, the Protect Vulnerable Immigrant Youth Act.
S.2327, H.R.4627, the Afghan Adjustment Act and other measures to facilitate permanent legal status for certain Afghans present in the U.S.
Recommendations on implementation of the Circumvention of Lawful Pathways rule and other issues related to the asylum system.
RIN 1125-AB18 Docket No. EOIR 021-0410, Appellate Procedures and Decisional Finality in Immigration Proceedings; Administrative Closure - provisions relating to briefing schedules for pro se litigants, administrative closure, termination of proceedings for unaccompanied children, unilateral sua sponte termination of proceedings, use of inclusionary and nondiscriminatory terms, and retroactivity of Matter of Thomas and Matter of Thompson
RIN 0970-AC93, Department of Health and Human Services Unaccompanied Children Program Foundational Rule - provisions relating to the consideration of a childs gender and cultural identity; State agency licensing requirements; appointment and role of the attorney, representative, and child advocate; the use of certain terminology (i.e., EOIR accredited representative, legal custody, specific consent, etc.); community-based care; the Sponsor Care Agreement; SIJS eligibility for the Unaccompanied Minor Refugees (URM) program; Post Release Services (PRS); legal, educational, and language access services; access to case files; permissible use of restraints and seclusion; emergency or influx facilities; placement review process; and ombuds offices.
RIN 1653-AA92, Clarifying and Revising Custody Determination and Detention Classification Procedures - provisions regarding consideration of ability to pay when determining bond amounts
Issues relating to access to counsel for individuals in immigration removal proceedings and increasing funding for the Legal Orientation Program.
Issues regarding the operations of the immigration courts, including establishing an independent Article I immigration court system.
Issues relating to decreasing the use of detention and expanding alternatives to detention.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Homeland Security - Dept of (DHS), Health & Human Services - Dept of (HHS), Justice - Dept of (DOJ), White House Office
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 |
Kristi |
Gaines |
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Holly |
Cook |
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Christina |
Ennis |
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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 LAW
16. Specific lobbying issues
H.R. 3479/S. 1753, the RESTORE Act, which would end the federal permanent lifetime ban on SNAP assistance for those with a past drug conviction and allow persons to apply for SNAP within 30 days of their release from prison.
H.R.4987/S. 1677, the Democracy Restoration Act and other activity in support of restoring the right to vote in federal elections for those leaving prison.
H.R. 3019/S. 1401, the Federal Prison Oversight Act, and other activity in support of increased transparency and oversight of the conditions of federal prisons.
Activity in support of a health and harm-reduction approach to combating criminal activity involving fentanyl analogs in lieu of increased criminalization and harsh mandatory minimum sentences for even nonviolent offenses.
Activity in support of reintroduction of the Effective Assistance of Counsel in the Digital Era Act concerning attorney-client confidentiality between attorneys and their incarcerated clients.
Activity in support of elimination of the trial penalty, i.e., harsher charges or sentences for defendants who choose to proceed by trial rather than plead guilty.
General research and discussions surrounding Supreme Court ethics rule, funding for the federal courts and federal defender legal services, and cameras in the courtroom.
H.R. 2955/S. 1351, the Stop Institutional Child Abuse Act - to provide greater oversight for youth treatment programs and promote best practices for identifying and preventing institutional child abuse.
Proposed changes to Customs and Border Protection Directive No. 3340-049 (Border Search of Electronic Devices Containing Information, dated August 20, 2009), Customs and Border Protection Directive No. 3340-049A (Border Search of Electronic Devices, dated January 4, 2018), and Immigration and Customs Enforcement Directive No. 7-6.1 (Border Searches of Electronic Devices, dated August 18, 2009) to prevent border officials from reading, duplicating, seizing, or sharing attorney-client privileged or confidential client documents or information contained on attorneys laptop computers, cell phones, and other electronic devices at U.S. border crossings unless the officials first obtain a subpoena based on reasonable suspicion or a warrant supported by probable cause.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Justice - Dept of (DOJ), White House Office, Federal Trade Commission (FTC), Homeland Security - Dept of (DHS), Consumer Financial Protection Bureau (CFPB)
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 |
Ken |
Goldsmith |
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Larson |
Frisby |
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David |
Eppstein |
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Holly |
Cook |
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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 LBR
16. Specific lobbying issues
H.R. 20 and S. 567, Richard L. Trumka Protecting the Right to Organize Act-provisions in Section 202 that would amend Section 203(c) of the Labor-Management Reporting and Disclosure Act of 1959, 29 U.S.C. 433(c), to require attorneys to report certain confidential client information to the Department of Labor.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Labor - Dept of (DOL), White House Office
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 |
Larson |
Frisby |
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Holly |
Cook |
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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
Support reintroduction of legislation that would establish clear criteria for when a Medicare set-aside may be reviewed by Medicare, provides a time frame for CMS to review set-aside submissions and provides an optional direct payment of set-aside amounts to Medicare.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES
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 |
David |
Eppstein |
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Holly |
Cook |
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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 TRD
16. Specific lobbying issues
Communications regarding international trade in legal services and overseas market access for U.S. firms and lawyers.
17. House(s) of Congress and Federal agencies Check if None
U.S. Trade Representative (USTR), Commerce - Dept of (DOC)
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 |
Kristi |
Gaines |
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Holly |
Cook |
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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
Communications regarding implementing a Guardianship Court Improvement Program.
Support for legislation that would allow a private right of action for people with disabilities harmed by air carriers.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES
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 |
David |
Eppstein |
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Holly |
Cook |
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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 BAN
16. Specific lobbying issues
S.2860, the Secure and Fair Enforcement Regulation Banking Act, or the SAFER Banking Act - a bill would allow financial institutions to provide legally-operating cannabis businesses access to critical banking services - including bank accounts, credit cards, and checks - without fear of retribution by federal regulators.
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 |
David |
Eppstein |
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Holly |
Cook |
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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 BNK
16. Specific lobbying issues
Draft legislation that would make the temporary Subchapter 5 and Chapter 13 threshold adjustments in the Bankruptcy Threshold Adjustment and Technical Corrections Act of 2022 (P.L. 117-151, S. 3823) permanent.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES
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 |
Larson |
Frisby |
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Holly |
Cook |
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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 FIR
16. Specific lobbying issues
General communications on issues related to reducing gun violence.
17. House(s) of Congress and Federal agencies Check if None
White House Office, 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 |
David |
Eppstein |
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Holly |
Cook |
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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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21. Client new principal place of business (if different than line 20)
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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:
Name | Address |
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
1 | 2 | 3 |
FOREIGN ENTITIES
27. Add the following foreign entities:
Name | Address |
Principal place of business (city and state or country) |
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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 | 3 | 5 |
2 | 4 | 6 |
CONVICTIONS DISCLOSURE
29. Have any of the lobbyists listed on this report been convicted in a Federal or State Court of an offense involving bribery,
extortion, embezzlement, an illegal kickback, tax evasion, fraud, a conflict of interest, making a false statement, perjury, or money laundering?
Lobbyist Name | Description of Offense(s) |