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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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State | |
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 | 2012 |
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 | 10/22/2012 |
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
S. 2079, A bill to extend the pay limitation for Members of Congress and Federal employees
P.L-112-25, Budget Control Act of 2011: sequestration
Deficit reduction packages: provisions that would reduce Medicare and Medicaid spending
H.J. Res. 117, Continuing Appropriations Resolution, 2013
Defense Authorization FY 2013: A-76 process; reduction of civilian workforce, inventory contractor work
House, Labor, HHS and Education Appropriations: Social Security Administration appropriations
Customs re-authorization: analysis, trade enforcement, job creation
Deficit Reduction Proposals: provisions that would increase beneficiary costs
FY 2012 House, Labor-HHS Appropriations-OSHA and MSHA funding
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 |
William |
Samuel |
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Gregory |
Jefferson |
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Byron |
Charlton |
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Raymond |
Liebfried |
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Lauren |
Rothfarb |
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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 EDU
16. Specific lobbying issues
Education: Background checks
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 |
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 ENV
16. Specific lobbying issues
Enhanced Oil Recovery/ Carbon Capture and sequestration: report from advisory group
17. House(s) of Congress and Federal agencies Check if None
Energy - Dept of, 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
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
P.L. 111-15, Special Inspector General for the Troubled Asset Relief Program Act of 2009
Regulation of Fiduciaries
Derivatives
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 |
Greg |
Jefferson |
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Raymond |
Liebfried |
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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
Judicial Nominations
S. 2219, DISCLOSE Act
H.R. 414, Presidential Funding Act
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 |
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 HCR
16. Specific lobbying issues
S. 915, American Health Security Act of 2011 - single payer health plan
P.L 111-148, Patient Protection and Affordable Care Act: Implementation, affordability standard in employer requirement to provide
coverage; definition of full time employee for purposes of employer requirement; proposed repeal of the law;
implementation of Medicaid expansion
H.R. 1200, American Health Security Act of 2011: provisions establishing a single payer health plan
H.R. 1206, Access to Professional Health Insurance Advisors Act of 2011 - provisions allowing for insurance brokers to be
exempted
H.R. 2077, MLR Repeal Act of 2011: provisions that would repeal medical loss ratio requirements for insurers
Medicare Rules
Preservation of the income tax exclusion for employer-provided healthcare benefits
Preservation of Medicare benefits: Medicare eligibility age cost-sharing requirements
Restructuring of Medicaid financing for deficit reduction: use of block grants or per capita caps to reduce funding
H.R. 6079, Repeal of Obama Care Act: provisions related to repeal of the Affordable Care Act
H.R. 1063, Strengthening Medicare and Repaying Taxpayers Act of 2011: provisions related to payments from trust fund
PL 112-152, Health Care and Education Reconciliation Act of 2010: affordability standard in employer requirement to provide coverage definition of full time employee
Health: regulatory agenda, SGR fix
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), Labor - Dept of (DOL), Treasury - Dept of, Agency for Health Care Policy & Research, Centers For Medicare and Medicaid Services (CMS), 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 |
Raymond |
Liebfried |
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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 IMM
16. Specific lobbying issues
Comprehensive Immigration Reform
H-2B: prevailing wage rule
H-2B Comprehensive Rule
Secure Communities
Immigration: temporary work visas, comprehensive immigration reform, deferred action for childhood arrivals, deferred action work authorization, H-1B visas, CA Trust Act, ICE Union
Work Authorization
S. 3553, Benefits to Research and American Innovation Through Nationality Statutes Act: H-1B Visas
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Labor - Dept of (DOL), Homeland Security - Dept of (DHS), 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 |
Andrea Zuniga |
DiBitetto |
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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
Hydraulic Fracturing: worker safety, regulations
Labor issues
NLRA and NLRB: oversight hearings
Prevent human trafficking
Labor Recruiter Regulations
H.R. 6429, STEM Jobs Act: H-1B Visas
H.R. 6412, Attracting the Best and Brightest Act of 2012
FLSA: companionship regs, computer professional exemption, minimum wage
H.R. 1519, Paycheck Fairness Act
S. 797, Paycheck Fairness Act
ENFORCE Act: right of unions to bring a claim
OSHA regulatory and enforcement issues
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Labor - Dept of (DOL), Energy - Dept of, Environmental Protection Agency (EPA), Occupational Safety & Health Administration (OSHA), 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 |
Cecelie |
Counts |
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William |
Samuel |
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Andrea Zuniga |
DiBitetto |
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Thomas |
Trotter |
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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
Manufacturing Policy: Investment policies, trade, tax infrastructure
Manufacturing Policy and Made in America
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Council of Economic Advisers (CEA), 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 |
Brett |
Gibson |
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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
Social Security: opposing benefit cuts, improving benefits, electronic statements, disability
Electronic disclosure of materials related to retirement benefits
Highway Bill: provisions related to defined benefit pension plans
Retirement Policy
Retirement Security Proposal: defined benefit pension proposal
H.R. 5727, Rebuild America Act: Social Security improvements
Pension "De-Risking"
PBGC Participant Advocate Position
Defined Benefit Pension plans: fiduciary rule and lifetime income, savers credit
Retirement: regulatory agenda
Pension and retirement savings: regulatory agenda
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Labor - Dept of (DOL), Treasury - Dept of, 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 |
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 TRD
16. Specific lobbying issues
Trans-Pacific Partnership: labor, investment, procurement, services
Columbia FTA: labor rights, violence, funding, oversight, analysis
Russia PNTR: policy, analysis, Senate & House mark-up, enforcement, labor, human rights
Honduras/CAFTA Complaint: FTA labor petition
Peru FTA: labor rights
Outsourcing: policy
General Trade Issues: 301s, FTA Model
Guatamala CAFTA Complaint
China trade: analysis, SOES, WTO Compliance
Middle East-North Africa Trade Initiative: labor rights and progressive trade
International Labor Rights
Bangladesh Labor Rights & GSP Petition
Mexico Labor Rights
Korea FTA: trade deficit, Kaesong
Georgia Labor Rights and GSP Petition
Columbia labor conditions: Implementation of Labor Action Plan
Burma sanctions: labor conditions in Burma
Trade policy: jobs impact
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, U.S. Trade Representative (USTR), Treasury - Dept of, State - Dept of (DOS), Labor - Dept of (DOL), U.S. Trade Representative (USTR), U.S. International Trade Commission (ITC), 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 |
Brett |
Gibson |
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William |
Samuel |
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Greg |
Jefferson |
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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
Bush Tax Cuts: expiration of upper income
Health Care Tax Exclusion
S. 3412, Middle Class Tax Cut Act
Tax 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 |
Gregory |
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 TRA
16. Specific lobbying issues
S. 876, Safe Highways and Infrastructure Preservation Act
H.R. 4348, MAP-21: surface transportation re-authorization, transportation infrastructure funding
S. 1813, MAP-21: surface transportation
Amtrak: hearings
H.R. 6169, Pathway to Job Creation through a Simpler, Fairer Tax Code of 2012
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE,
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Thomas |
Trotter |
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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
Economic policy
H.R. 4297, Workforce Investment Act of 2012
0Buy America: policy, support
H.R. 5442, Bring Jobs Home Act: provisions to disincentivize companies from moving jobs
S. 2884, Bring Jobs Home Act: provisions to disincentivize companies from moving jobs
S. 3364, Bring Jobs Home Act: job creation, tax provisions
H.R. 8, Job Protection and Recession Prevention Act of 2012
Infrastructure: job creation aspects
H.R. 4078, Red Tape Reduction and Small Business Job Creation Act: regulatory impacts
S. 3468, Independent Agency Regulatory Analysis Act: regulatory impacts
H.R. 3630, Middle Class Tax Relief and Job Creation Act of 2012: increase retirement contributions of federal workers
General economic policy, job creation
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Reserve System, Labor - Dept of (DOL), U.S. Trade Representative (USTR), 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 |
Raymond |
Liebfried |
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William |
Samuel |
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Gregory |
Jefferson |
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Brett |
Gibson |
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Thomas |
Trotter |
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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 HOU
16. Specific lobbying issues
Foreclosure Crisis
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), Vice President of the U.S.
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 CIV
16. Specific lobbying issues
Election Reform/Voting Rights: Voter ID
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 VET
16. Specific lobbying issues
Veterans issues: healthcare, education, employment
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Veterans Affairs - Dept of (VA),
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 FIR
16. Specific lobbying issues
H.R. 58, Firearms Interstate Commerce Reform 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 |
Raymond |
Liebfried |
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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: rule interpretation
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 |
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 POS
16. Specific lobbying issues
S. 1789, 21st Century Postal Service Act of 2012: healthcare, pensions
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 |
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 AGR
16. Specific lobbying issues
S. 3240, Agriculture Reform, Food and Jobs Act of 2012: conservation titles, NLRA amendments, subsidies, various other sections, jobs
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Thomas |
Trotter |
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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 DEF
16. Specific lobbying issues
DoD Design Teams: performance management, workplace incentives, hiring flexibilities
17. House(s) of Congress and Federal agencies Check if None
Defense - Dept of (DOD), 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
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 |