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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 815 16TH STREET, NW |
Address2 | |
City | WASHINGTON |
State | DC |
Zip Code | 20006 |
Country | USA |
3. Principal place of business (if different than line 2)
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Zip Code | |
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5. Senate ID# 363-12
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6. House ID# 310190000
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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: Jonathan P. Hiatt, Chief of Staff |
Date | 01/21/2010 |
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
Medical Bankruptcy Fairness Act of 2009, S.1624
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 |
Greg |
Jefferson |
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William |
Samuel |
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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 BUD
16. Specific lobbying issues
National Defense Authorization Act of Fiscal Year 2010, HR 2647
National Defense Authorization Act of Fiscal Year 2010, S. 1390
Department of State, Foreign Operations and Related Programs Appropriations Act, S. 1434
Commerce, Justice, Science, and Related Agencies Appropriations Act, 2010, H.R. 2847
State, Foreign Operations 2010 Appropriations, H.R. 3081
Fiscal Year 2010 Defence Appropriations, H.R. 3326, C-17 Aircraft Funding
Department of Defense Appropriations Act, 2010, H.R. 3326, Unemployment Insurance and COBRA extensions
Departments of Labor, Health, and Human Services, and Education, and Related Agencies Appropriations Act of 2010, H.R. 3293
Military Construction and Veterans Appropriations Act, S. 1407
Military Construction and Veterans Appropriations Act, H.R. 3082
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Energy - Dept of, Labor - Dept of (DOL), Office of Management & Budget (OMB), 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 |
Byron |
Charlton |
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Dave |
Mallino |
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William |
Samuel |
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Cecelie |
Counts |
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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
Employment Non-Discrimination Act of 2009, S. 1584
Employment Non-Discrimination Act of 2009, H.R. 3017
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), 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 |
Cecelie |
Counts |
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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 CSP
16. Specific lobbying issues
Consumer Financial Protection Agency Act of 2009, H.R. 3126
Fair Credit Reporting Act, H.R. 3763
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 |
Greg |
Jefferson |
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William |
Samuel |
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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
Jobs Proposals
Prescribe Benefits and Jobs Act of 2009, H.R. 3936
Debt Ceiling Extensions
Small Business Assistance
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), Office of Management & Budget (OMB), 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 |
William |
Samuel |
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Gail |
Dratch |
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Lauren |
Rothfarb |
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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
Education Related Federal Programs and Education Agenda for the 111th Congress
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), Education - Dept of
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 |
Cecelie |
Counts |
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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 ENG
16. Specific lobbying issues
Clean Renewable Energy and Economic Development Act, S. 539
21st Century Energy Technology Deployment Act, S. 949
Clean Energy Jobs and American Power Act, S. 1733
Department of Energy Carbon Capture and Sequestration Program Amendment Act of 2009, S. 1013
American Clean Energy and Security Act of 2009, H.R. 2454
American Clean Energy Leadership Act of 2009, S. 1462
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Energy - Dept of, Executive Office of the President (EOP), 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 |
David |
Mallino |
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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 ENV
16. Specific lobbying issues
Climate Change issues
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Energy - Dept of, Executive Office of the President (EOP), Environmental Protection Agency (EPA), 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 |
David |
Mallino |
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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
International Monetary Fund Reform
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), State - Dept of (DOS), 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 |
William |
Samuel |
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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
Over-the-Counter Derivatives Markets Act, H.R. 3795
Accountability and Transparency Act, H.R. 3890
Private Fund Investment Advisory Registration Act, H.R. 3818
Investment Protector Act, H.R. 3817
Financial Stability Improvement Act, H.R. 3996
Wall Street Reform and Consumer Protection Act, H.R. 4173
Proxy Access
Corporate Governance
Financial Regulation
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), Treasury - Dept of, Securities & Exchange Commission (SEC), Federal Reserve System
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 |
Greg |
Jefferson |
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William |
Samuel |
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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
General Executive Branch Appointments
Judicial Nominations
Open Access to Courts Act of 2009, H.R. 4115
Notice Pleading Restoration Act of 2009, S. 1504
Procurement Policy
Census Issues
Lobbyist Regulation
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), Office of Personnel Management (OPM), Office of Management & Budget (OMB), 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 |
Cecelie |
Counts |
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Lauren |
Rothfarb |
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William |
Samuel |
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Gail |
Dratch |
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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
America's Affordable Health Choices Act, H.R. 3200
Health Care Reform
Patient Protection and Affordable Care Act, H.R. 3590
Emergency Influenza Containment Act, H.R. 3991
Affordable Health Care for America Act, H.R. 3962
America's Healthy Future Act of 2009, S. 1796
Health Industry Antitrust Enforcement Act
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Office of Management & Budget (OMB), Executive Office of the President (EOP), Health & Human Services - Dept of (HHS), Office of the Vice President of the United States
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 |
Gail |
Dratch |
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Brett |
Gibson |
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Gerron |
Levi |
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David |
Mallino |
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Kelly |
Ross |
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Lauren |
Rothfarb |
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William |
Samuel |
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Byron |
Charlton |
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Gerald |
Shea |
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Joann |
Volk |
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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
CIR-ASAP Act of 2009, H.R. 4321
H-1B and L-1 Visa Reform Act of 2009, S. 887
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), Homeland Security - Dept of (DHS), 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 |
Sonia |
Ramirez |
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William |
Samuel |
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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
Performance Rights Act, S. 379
Performance Rights Act, H.R. 848
Paycheck Fairness Act, S. 182
Employee Free Choice Act, S. 560
Employee Free Choice Act, H.R. 1409
Working for Adequate Gains for Employment in Services Act (Amend FLSA), H.R. 2590
James Zadroga 9/11 Health and Compensation Act of 2009, H.R. 847
Arbitration Fairness Act of 2009, S. 931
Healthy Families Act, S. 1152
James Zadroga 9/11 Health and Compensation Act of 2009, S. 1334
Arbitration Fairness Act of 2009, H.R. 1020
Protecting America's Workers Act, H.R. 2067
Healthy Families Act, H.R. 2460
H1N1 Virus (swine flu) Worker Protections
Public Safetty Employer-Employee Cooperation Act of 2009, H.R. 413
Jobs Policy
Airborne Infection Disease Control
Protecting America's Workers Act, S. 1580
Combustible Dust Rule
OSHA Safety Emergecy Plans
Mine Safety Issues
OSHA Training Grants
Airborne Infectuous Diseases
Pandemic Protection for Workers, Families and Businesses Act, H.R. 4092
Workforce Development and Training
American Worker Transition and Community Assistance Act, S. 2742
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), Office of Personnel Management (OPM), 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 |
Byron |
Charlton |
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Cecelie |
Counts |
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Brett |
Gibson |
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Greg |
Jefferson |
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Gerron |
Levi |
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William |
Samuel |
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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 MAN
16. Specific lobbying issues
Restoring America's Manufacturing Leadership Act, S. 661
Manufacturing Policy Issues
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 |
David |
Mallino |
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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
Postal Service Retiree Health Benefits Funding Reform Act of 2009, S. 1507
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 |
Byron |
Charlton |
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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
Pension Funding Relief
Social Security Payments
Entitlement Commission
Social Security Act, Part B, H.R. 4313
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 |
Gail |
Dratch |
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Lauren |
Rothfarb |
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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 TEC
16. Specific lobbying issues
Broadband Access
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 |
Cecelie |
Counts |
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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
Columbia Free Trade Agreement
Currency Reform for Fair Trade Act, S. 1027
Currency Reform for Fair Trade Act, H.R. 2378
Andean Trade re GSP system of trade
Tariffs and related issues
Korea Free Trade Agreement
Currency Reform for Fair Trade Act of 2009, S. 1027
Currency Reform for Fair Trade Act, H.R. 2378
TRADE Act of 2009, H.R. 3012
OPIC Issues
Doha Round
Trans-Pacific Partnership
Bilateral Investment Treaty
Andean Preferences Act, H.R. 4284
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), U.S. Trade Representative (USTR), State - Dept of (DOS), Commerce - Dept of (DOC), Overseas Private Investment Corp (OPIC)
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 |
Brett |
Gibson |
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William |
Samuel |
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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
Unemployment Insurance Proposals
Emergency Unemployment Compensation Extension, H.R. 3548
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 |
Cecelie |
Counts |
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William |
Samuel |
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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 VET
16. Specific lobbying issues
Various Veterans Issues
Veterans' Worker Retraining Act of 2009, H.R. 1098
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 |
Byron |
Charlton |
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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
Tax Extenders Act, H.R. 4213
Taxpayer Responsibility, Accountability and Consistency Act of 2009, H.R. 3408
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, 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 |
N/A |
N/A |
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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
High Speed Rail Investment
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 |
N/A |
N/A |
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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 |