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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. | ||||||||
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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 |
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| Signature | Digitally Signed By: Holly Cook |
Date | 4/20/2023 5:52:14 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; the John R. Justice Prosecutor and Defender Loan Repayment program; funding for the federal courts; and authorization of Second Chance Act funding for voter education for those leaving prison.
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)
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.
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
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.
Department of the Treasury Financial Crimes Enforcement Network Notice of Proposed Rulemaking on Beneficial Ownership Information Access and Safeguards, and Use of FinCEN Identifiers for Entities; Docket No. FINCEN-2021-0005; RIN 1506-AB49/AB59, 87 Fed. Reg. 77404 (December 16, 2022).
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 FIR
16. Specific lobbying issues
Research and advocacy regarding legislative solutions to reduce incidents of gun violence and steps to improve gun safety, specifically involving guns on higher education campuses and expanded background checks.
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 |
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
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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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.
Legislation regarding diversity jurisdiction - to treat unincorporated and incorporated entities the same.
Support for introduction of resolution to end the territorial incorporation doctrine.
H.R. 1360 - the American Cybersecurity Literacy Act
Support for permanently establishing/forming within the Department of Justice, the Office for Access to Justice.
Comments regarding a proposed rule change allowing Separate Licensing Standards for Relative or Kinship Foster Family Homes.
Support increasing administrative law judge independence through establishing a code of ethics for them along with merit-based hiring practices and an independent decision making body.
Support for measures related to ensuring that any covered entities under a federal cybersecurity, data security and/or digital privacy statute include clearly stated obligations and/or duties; New federal laws/ regulations should protect, not undermine, the attorney-client privilege, the lawyers ethical duty to protect client confidentiality, the work product doctrine, and state supreme courts longstanding authority to regulate and oversee the legal profession; Include provisions that protect intellectual property rights; Ensure that developers, integrators, suppliers, and operators (Developers) of A.I. systems and capabilities should ensure that their products, services, systems, and capabilities are subject to human authority, oversight, and control.
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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Thomas |
Susman |
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Larson |
Frisby |
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Holly |
Cook |
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Kristi |
Gaines |
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David |
Eppstein |
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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
Draft legislation on Afghan Adjustment Act and other measures to facilitate permanent legal status for certain Afghans present in the U.S.
Comments in response to the Notice of Proposed Rulemaking regarding Circumvention of Lawful Pathways and other issues related to the asylum system.
Comments on a Proposed Rule on U.S. Citizenship and Immigration Services Fee Schedule and Changes to Certain Other Immigration Benefit Request Requirements and other issues relating to immigration fees.
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.
Communications in regard to ending the use of section 265 of Title 42 to block asylum seekers from applying for protection at the U.S. border and to remove them without any adjudication of their claims.
Issues relating to increasing visa availability for children with approved petitions for Special Immigrant Juvenile status.
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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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. 1062, S. 524 - the EQUAL Act, to equalize the sentencing for offenses involving crack vs powder cocaine.
Activity in support of the Democracy Restoration Act, to restore eligibility to vote in federal elections following the completion of ones felony sentence.
Activity in support of the Effective Assistance of Counsel in the Digital Era Act, which would ensure that the attorney-client privilege applies to digital messages sent between federal prisoners and their lawyers.
Activity in support of a health 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 expungement, case record sealing, and removal of a permanent federal ban on access to nutrition assistance for persons convicted of a drug offense.
Research and policy discussions regarding cybersecurity and artificial intelligence as they relate to developing technologies and emerging challenges potentially affecting the legal profession.
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.
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.
Proposed Amendments to United States Sentencing Guidelines 1B1.13; Reduction in Term of
Imprisonment under 18 U.S.C. 3582(c)(1)(A) (Policy Statement) (February 2, 2023)-provisions that would improve access to, and judicial discretion over, requests for a reduction to ones sentence based on extraordinary and compelling circumstances.
Draft legislation applying the same attorney-client privilege protections to electronic messages between individuals held in Bureau of Prisons facilities and their attorneys that already apply to all other forms of communication.
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.
Food and Drug Administration Recommendations for Evaluating Donor Eligibility Using Individual Risk-Based Questions to Reduce the Risk of Human Immunodeficiency Virus Transmission by Blood and Blood Products; Docket No. FDA-2015-D-1211-0152.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Food & Drug Administration (FDA)
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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Larson |
Frisby |
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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
Activity in support of legislation to add veterans to the Fair Housing Act, prohibiting their discrimination while also preserving veterans preference under Department of Veterans Affairs housing programs.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Veterans Affairs - Dept of (VA), Housing & Urban Development - Dept of (HUD)
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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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:
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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 | 2 | 3 |
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 | 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) |