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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 1625 L STREET, NW, 7TH FLOOR |
Address2 | |
City | WASHINGTON |
State | DC |
Zip Code | 20036 |
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# 2321-12
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6. House ID# 310180000
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TYPE OF REPORT | 8. Year | 2013 |
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: Charles M. Loveless, Director of Federal Government Affairs |
Date | 01/22/2014 |
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
Repealing the Sustainable Growth Rate (SGR); Medicaid eligibility determinations, beneficiary costs
HJ Res 59 - Bipartisan Budget Relief Act; revenues, nondefense discretionary funding, sequestration, taxes, Medicare, Medicaid, Social Security, federal employee pensions, ACA funding, education, aid to state and local governments, unemployment insurance program extension
Appropriations and DOL rulemaking
Budget and the need to raise taxes
Tax exclusion for employer-provided health care
S 1553, HR 3666 - Support for Stop Tax Haven Abuse Act
Opposition to means testing Medicare premiums
Opposing to raising Medicare age
Federal discretionary spending caps
S 1569, HR 775 - Federal debt ceiling
HR 900 - Sequester, decrease spending reductions to non-security discretionary
HR 2775 - Appropriations Continuing Resolution
Funding for East-West Center
S.Con.Res 8, H.Con.Res 25 - FY 2014 Budget Resolution
S 1243, HR 2610 - Transportation-HUD Appropriations
S 1284 - Labor-HHS-Education Appropriations
HR 3273 - Deficit Reduction and Economic Growth Act of 2013
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, 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 |
Linda |
Bennett |
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Frances |
Bernstein |
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Barbara |
Coufal |
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Marc |
Granowitter |
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Edwin S. |
Jayne |
Jr. |
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Rebecca |
Levin |
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Charles M. |
Loveless |
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Nanine |
Meiklejohn |
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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
Ratification of the Convention on the Rights of Persons with Disabilities
Access to language services in health care
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Health & Human Services - Dept of (HHS)
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 |
Linda |
Bennett |
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Charles M. |
Loveless |
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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 ECN
16. Specific lobbying issues
Job Creation
S 1356 - Workforce Investment Act of 2013
HR 803, HR 798 - SKILLS Act/Workforce Investment Act of 2013
HJ Res 59 - Continuing Appropriations Resolution for 2014; benefit cuts, unemployment insurance program extension, tax revenues
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, 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 |
Edwin S. |
Jayne |
Jr. |
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Charles M. |
Loveless |
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Nanine |
Meiklejohn |
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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
S 1094 - Strengthening America's Schools Act of 2013 - background checks for school employees
S 1086 - Child Care Development Block Grant (CCDBG) Reauthorization - background checks
S 1697, HR 3641 - Strong Start for America's Children Act - training and compensation for preK and child care providers, Child Care and Early Head Start partnerships, background checks, licensing requirements/inspections
HR 2083 - Protecting Students from Sexual and Violent Predators Act
S 1356 - Workforce Investment Act of 2013
HR 803, HR 798 - SKILLS Act/Workforce Investment Act of 2013
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 |
Rebecca |
Levin |
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Charles M. |
Loveless |
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Nanine |
Meiklejohn |
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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
HR 3712, S 1810 - The Family and Medical Insurance Leave (FAMILY) Act
S 1086 - Child Care Development Block Grant (CCDBG) Reauthorization- background checks
S 1697, HR 3641 - Strong Start for America's Children Act- training and compensation for preK and child care providers, Child Care and Early Head Start partnerships, background checks, licensing requirements/inspections
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 |
Rebecca |
Levin |
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Charles M. |
Loveless |
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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
HR 2374 - Retail Investor Protection Act
HR 992 - Swaps Regulatory Improvement 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 |
Marc |
Granowitter |
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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
Senate rules reform
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 |
Marta |
David |
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Charles M. |
Loveless |
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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
Improving the quality of home care
Access to language services in health care
S 1562 - Older Americans Reauthorization Act of 2013, programs to help older adults remain as healthy and independent as possible in their homes and communities
Appropriations and DOL rulemaking
HR 3350 - Keep Your Health Plan Act
Federal tax exclusion for employer sponsored health insurance
Medicare and Medicaid Reform
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, 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 |
Linda |
Bennett |
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Barbara |
Coufal |
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Marc |
Granowitter |
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Edwin S. |
Jayne |
Jr. |
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Charles M. |
Loveless |
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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 HOU
16. Specific lobbying issues
Mel Watt for FHFA
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 |
Marc |
Granowitter |
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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
HR 15 - Border Security, Economic Opportunity, and Immigration Modernization Act; employment visas, public benefits, citizenship pathway, E-Verify
S 744, HR 15 - comprehensive immigration reform, in general
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 |
Frances L. |
Bernstein |
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Barbara |
Coufal |
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Charles M. |
Loveless |
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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
Improving the quality of home care
Appropriations and DOL rulemaking
HR 982 - Asbestos Claims Transparency Act
HR 3223, S 1567 - Federal Employee Retroactive Pay Fairness Act
HR 1010, S 460 - Fair Minimum Wage Act of 2013
HR 3573 - Wage Grade Employee Parity Act
HR 2288 - Commuter Parity Act
HR 1120 - Preventing Greater Uncertainty in Labor Management Relations Act
HR 107 - Federal Employee Accountability Act (official time)
S 815 - Employee Nondiscrimination Act
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Labor - Dept of (DOL)
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 |
Linda |
Bennett |
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Barbara |
Coufal |
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Marta |
David |
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Rebecca |
Levin |
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Charles M. |
Loveless |
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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
S 815 - Employee Nondiscrimination Act
Judicial and Executive Branch Nominations/Rule Change
Judicial Nominations to US Court of Appeals, DC Circuit - Nina Pillard and Robert Wilkins
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 |
Edwin S. |
Jayne |
Jr. |
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Rebecca |
Levin |
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Charles M. |
Loveless |
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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
Access to language services in health care
trade policy impacts on Medicare/Medicaid
HR 1588, S 740 - Medicare Drug Savings Act of 2013
Repealing the Sustainable Growth Rate (SGR); Medicaid eligibility determinations, beneficiary costs
Medicaid funding/benefits
Medicare funding/benefits/policy/eligibility age/means test
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Health & Human Services - Dept of (HHS), Executive Office of the President (EOP)
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 |
Linda |
Bennett |
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Barbara |
Coufal |
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Marc |
Granowitter |
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Charles M. |
Loveless |
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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 PHA
16. Specific lobbying issues
Trade policy impacts on Medicare/Medicaid
HR 1588, S 740 - Medicare Drug Savings Act of 2013
Access to language services in health care
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Executive Office of the President (EOP)
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 |
Linda |
Bennett |
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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 POS
16. Specific lobbying issues
S 1486 - Postal Reform Act of 2013, health care and worker compensation
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 |
Marta |
David |
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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 RET
16. Specific lobbying issues
HConRes 34, SConRes 15 - Social Security funding/policy, chained CPI
Reductions to earned retirement benefits
S 1270, HR 1628 - Public Pensions Transparency Act
S 567, HR 3118 - Strengthening Social Security Act
S 308, HR 649 - Protecting and Preserving Social Security Act
HJRes 59 - Continuing Appropriations Resolution for 2014, benefit cuts, unemployment insurance program extension, tax revenues
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 |
Marc |
Granowitter |
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Edwin S. |
Jayne |
Jr. |
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Charles M. |
Loveless |
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Nanine |
Meiklejohn |
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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 TAX
16. Specific lobbying issues
Budget and the need to raise taxes in general
Tax exclusion for employer-provided health care
S 1553, HR 3666 - Stop Tax Haven Abuse Act
Limits on itemized tax deductions and selected exclusions
Federal income tax deduction for state and local government tax
Federal income tax exclusion for interest on state and local government public purpose bonds
Federal tax reform impact on state and local government revenues
Estate tax
Reduced tax rates on capital gains and dividends
S 321, HR 766 - Paying a Fair Share Act of 2013
HR 694, S 250, S 268, S 307 - Corporate Tax Reform
Corporate tax rates, loopholes, repatriation, territorial system
S 250 - Corporate Tax Dodging Prevention Act
S 743, HR 684 - Marketplace Fairness Act of 2013
S 410, HR 880 - Wall Street Trading and Speculators Tax Act
Tax reform fast-track reconciliation instructions
Medical Device tax
Build America Bonds
HR 2084 - Partnership to Build America Act of 2013
HR 2084 - Repatriation Tax Amnesty and Infrastructure Bank
Tax Reform issues
HR 2429, S 1183 - Death Tax Repeal Act
S 743 - Internet Sales Tax
HJRes 59 - Bipartisan Budget Act of 2013
SConRes8, HConRes 25 - FY 2014 Budget Resolution
HR 775 - Debt Limit Increase
S 1284 - Labor-HHS-Education Appropriations
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, 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 |
Barbara |
Coufal |
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Marc |
Granowitter |
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Edwin S. |
Jayne |
Jr. |
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Charles M. |
Loveless |
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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 TOR
16. Specific lobbying issues
HR 982 - Asbestos Claims Transparency Act
17. House(s) of Congress and Federal agencies Check if None
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 |
Barbara |
Coufal |
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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
Trade policy impacts on Medicare/Medicaid
Trans-Pacific Partnership Agreement, provisions related to reimbursements for drugs and medical devices by public programs
Trans-Atlantic Trade and Investment Partnership, provisions related to reimbursements for drugs and medical devices by public programs
Fast track authority, incorporating transparency provisions, provisions that limit governments' use of cost controls in public health coverage programs
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Executive Office of the President (EOP), 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 |
Linda |
Bennett |
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Barbara |
Coufal |
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Charles M. |
Loveless |
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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 TRA
16. Specific lobbying issues
HR 3080 - Water Resources Development Act, Young/Petri Amendment
17. House(s) of Congress and Federal agencies Check if None
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 |
Marta |
David |
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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 UNM
16. Specific lobbying issues
HJRes 59 - Bipartisan Budget Relief Act, extension of federal extended unemployment benefits program
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 |
Frances L. |
Bernstein |
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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 WEL
16. Specific lobbying issues
S 954, HR 3120 - SNAP work provision in Farm Bills
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 |
Charles M. |
Loveless |
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Nanine |
Meiklejohn |
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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 |
Principal Place of Business (city and state or country) |
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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 |