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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 |
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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 | 2017 |
Q1 (1/1 - 3/31) | Q2 (4/1 - 6/30) | Q3 (7/1 - 9/30) | Q4 (10/1 - 12/31) |
9. Check if this filing amends a previously filed version of this report
10. Check if this is a Termination Report | Termination Date |
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11. No Lobbying Issue Activity |
INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
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12. Lobbying | 13. Organizations | ||||||||
INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
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Provide a good faith estimate, rounded to the nearest $10,000, of all lobbying related income for the client (including all payments to the registrant by any other entity for lobbying activities on behalf of the client). | 14. REPORTING Check box to indicate expense accounting method. See instructions for description of options. | ||||||||
Method A.
Reporting amounts using LDA definitions only
Method B. Reporting amounts under section 6033(b)(8) of the Internal Revenue Code Method C. Reporting amounts under section 162(e) of the Internal Revenue Code |
Signature | Digitally Signed By: Thomas M. Susman |
Date | 10/20/2017 4:26:00 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
H.R. 3267 and S. 1662, FY 2018 Commerce, Justice, Science and Related Agencies appropriations Act; H.R. 601, Continuing Appropriations Act, 2018; H.R. 3354 and Senate draft bill, Make America Secure and Prosperous Appropriations Act, 2018 - provisions relating to funding for Legal Services Corporation, funding for immigration courts.
H.R. 3280 and Senate draft bill, FY 2018 Financial Services and General Government appropriations bills; H.R. 601, Continuing Appropriations Act, 2018; H.R. 3354 and Senate draft bill, Make America Secure and Prosperous Appropriations Act, 2018 - provisions relating to funding for the Internal Revenue Service, the U.S. Courts, and the Administrative Conference of the United States.
H.R. 3362, S. 1780, FY 2018 State, Foreign Operations, and Related Programs Appropriations Act - funding for foreign assistance democracy, human rights and rule of law programs.
H.R. 3358, S.1771, FY 2018 Labor, Health and Human Services, and Education Appropriations Act - funding for the Office of Refugee Resettlement.
H.R. 3355, FY 2018 Department of Homeland Security Appropriations Act - funding for immigration detention and alternatives to detention.
Language regarding the Legal Services Corporation in the White House Budget
Activity in opposition to efforts to repeal the federal public service loan forgiveness program through the budget reconciliation process.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), 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 |
Holly |
Cook |
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Larson |
Frisby |
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Jared |
Hess |
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Aloysius |
Hogan |
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Kristi |
Gaines |
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Thomas |
Susman |
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Ken |
Goldsmith |
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Denise |
Cardman |
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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
S. 819, H.R.1869, Paycheck Fairness Act
S. 635 Jury ACCESS Act/ H.R. 1515 Juror Non-Discrimination Act of 2017 - provisions relating to prohibiting the exclusion of citizens from service as a grand or petit juror in federal courts on account of sexual orientation or gender identity.
H.R. 968 and S. 328, the Equal Justice Under Law Act of 2017, as it relates allowing individual litigants to equitable relief in federal court for systemic violations of the right to counsel
Request to integrate ABA identified best practices and proposed policies to provide future generations with the right to a quality education and the tools needed for effective citizenship into federal programs
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 |
Denise |
Cardman |
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Jared |
Hess |
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Thomas |
Susman |
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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
General activity in opposition to proposals to cut or repeal federal public service loan forgiveness and support for proposals that increase access and affordability of law school.
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 |
Jared |
Hess |
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Ken |
Goldsmith |
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Thomas |
Susman |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code FAM
16. Specific lobbying issues
H.R. 253, the Family First Prevention Services Act
Communications to the Department of Health and Human Services Administration for Children and Families regarding the Final Rule for the Adoption and Foster Care Analysis Reporting System
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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Thomas |
Susman |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code FIN
16. Specific lobbying issues
H.R.1849, Practice of Law Technical Clarification Act
S.851 and H.R.1932, Stop Tax Haven Abuse Act-provisions subjecting lawyers that act as formation agents to the anti-money laundering and suspicious activity reporting requirements of the Bank Secrecy Act
S. 1454, TITLE Act-provisions requiring states, certain businesses, and company formation agents to obtain and disclose beneficial ownership information regarding new companies, and provisions subjecting lawyers that act as formation agents to the anti-money laundering and suspicious activity reporting requirements of the Bank Secrecy Act
S. 1717 and H.R. 3089, Corporate Transparency Act-provisions requiring states or the Treasury Departments Financial Crimes Enforcement Network (FinCEN), certain businesses, and company formation agents to obtain and disclose beneficial ownership information regarding new companies, and provisions subjecting lawyers that act as formation agents to the anti-money laundering and suspicious activity reporting requirements of the Bank Secrecy Act
Draft legislation requiring all United States entities to have an employer identification number issued by the Secretary of the Treasury and hence to file IRS Form SS-4 listing responsible party information for each entity in order to combat money laundering and terrorist financing
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Deposit Insurance Corporation (FDIC), Treasury - Dept of, White House Office, Federal Trade Commission (FTC)
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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Thomas |
Susman |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code FOR
16. Specific lobbying issues
Funding levels for FY18 Democracy and Governance programs
Communications on appropriate implementing instruments for democracy programs
H.R.3030, S. 1158, the Elie Wiesel Genocide and Atrocities Prevention Act of 2017
Draft legislation on incorporating Crimes Against Humanity into U.S. criminal code
Support for the Department of State decision to retain the Office of Global Criminal Justice Ambassador position and encouraging it to maintain the resources needed to continue the vital functions of its department as it makes difficult business decisions. Also support for prioritizing the promotion of democracy, human rights, justice, and the rule of law in its diplomacy and development assistance.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, State - Dept of (DOS)
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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Thomas |
Susman |
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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 GOV
16. Specific lobbying issues
S.237, H.R. 720, Lawsuit Abuse Reduction Act
H.R. 985, Fairness in Class Action Litigation
H.R. 1215, Protecting Access to Care Act
S. 1107, the Bankruptcy Judgeship Act of 2017 - also H.R. 2266,Additional Supplemental Appropriations for Disaster Relief Requirements Act, 2017 - incorporating Bankruptcy Judgeship Act
S.295, Circuit Court of Appeals Restructuring and Modernization Act
S.276, Judicial Administration and Improvement Act of 2017
H.R. 250, Judicial Administration and Improvement Act of 2016
H.R.196, Ninth Circuit Court of Appeals Judgeship and Reorganization Act of 2017
General advocacy on filling of judicial vacancies
Draft legislation expanding public access to materials that has been incorporated by reference into proposed or final federal agency regulations
Draft legislation amending 28 U.S.C. 1500 to clarify the respective jurisdiction of the U.S. Court of Federal Claims and the U.S. District Court and allowing plaintiffs with claims against the U.S. government to bring simultaneous claims in both courts, with a presumptive stay of the first-filed action
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), White House Office, Congressional Budget Office (CBO), 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 |
Denise |
Cardman |
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Larson |
Frisby |
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Thomas |
Susman |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code HCR
16. Specific lobbying issues
H.R. 1215, Protecting Access to Care Act of 2017
H.R. 2797, S. 1334, the Patient Choice and Quality Care Act of 2017
Communications regarding Senate health care reform proposals, specifically regarding the Graham-Cassidy-Heller-Johnson health reform proposal's potential impact to weaken Medicaid
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 |
Susman |
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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
H.R. 495, the Protection of Children Act of 2017
General communications relating to government appointed counsel for children in immigration proceedings, decreasing use of detention and expanding alternatives to detention, particularly for families and children, increasing resources for the immigration court system, and expanding the Legal Orientation Program.
General advocacy on the U.S. Refugee Resettlement Program
General communications on issues relating to implementation of the National Detention Standards, conditions in immigration detention, and use of alternatives to detention
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Health & Human Services - Dept of (HHS), Justice - Dept of (DOJ), Homeland Security - Dept of (DHS)
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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Thomas |
Susman |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code LAW
16. Specific lobbying issues
S. 860, the Juvenile Justice Delinquency Prevention Act (JJDPA) and H.R. 1809, the Juvenile Justice Reform Act of 2017 - bills to reauthorize the Juvenile Justice and Delinquency Prevention Act of 1974.
H.R 1437, the No Money Bail Act of 2017 - provisions relating to the use of money as a condition of pretrial release in state criminal cases where the state receives federal grant funding and as a condition of pretrial release in Article III court.
S. 1593, Pretrial Integrity and Safety Act - bill to limit the use of money as a condition of pretrial release
H.R. 2899, Second Chance Reauthorization Act of 2017 - bill to provide grants for reentry services to state and local governments and nonprofit associations that reduces recidivism and increases public safety
H.R. 1795, Due Process Act to Civil Asset Forfeiture - bill to shift the burden of proof to the government and increase due process in civil asset forfeiture cases
H.R. 2851, Stop the Importation and Trafficking of Synthetic Analogues Act of 2017 - general discussions about notice of criminality, due process rights, and mandatory minimums contained in the bill
H.R.584, the Cyber Preparedness Act of 2017
S.178, the Elder Abuse Prevention and Prosecution Act
S. 1757, Building Americas Trust Act - an immigration and national border security bill that contains provisions that relate to mandatory minimums for immigrants who enter the United States illegally or commit crimes and Kates Law specifically.
Sentencing Reform and Corrections Act (114th Congress), general discussions about potential sentencing reform in the 115th Congress and smarter sentencing generally.
Bureau of Consumer Financial Protection Proposed Rule on Amendments Relating to Disclosure of
Records and Information; Docket No. CFPB-2016-0039; RIN 3170-AA63, 81 Fed. Reg. 58310 (August 24, 2016)-provisions (1) expanding the Bureaus discretion to share confidential information it receives from supervised and regulated entities with other foreign, state, and other governmental agencies and (2) prohibiting subjects of investigations and other recipients of civil investigative demands from disclosing information regarding the Bureaus investigation.
Proposed changes to Customs and Border Protection Directive No. 3340-049 (Border Search of Electronic Devices Containing Information, dated August 20, 2009) 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 lawyers laptop computers, cell phones, and other electronic devices at U.S. border crossings unless the officials first obtain a subpoena based on reasonable suspicion or a warrant supported by probable cause
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Consumer Financial Protection Bureau (CFPB), Justice - Dept of (DOJ), White House Office, Homeland Security - Dept of (DHS)
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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Larson |
Frisby |
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David |
Eppstein |
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Thomas |
Susman |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code LBR
16. Specific lobbying issues
Department of Labor Final Rule-Interpretation of the Advice Exemption in Section 203(c) of the
Labor-Management Reporting and Disclosure Act; RIN 1215-AB79 and 1245-AA03, 81 Fed. Reg. 15924 (April 24, 2016); and related Department of Labor Proposed Rule-Rescission of Rule Interpreting Advice Exemption in Section 203(c) of the Labor-Management Reporting and Disclosure Act; RIN 1245-AA07, 82 Fed. Reg. 26877 (June 12, 2017).
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Labor - Dept of (DOL), Office of Management & Budget (OMB), 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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Thomas |
Susman |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code MMM
16. Specific lobbying issues
Communications regarding Senate health care reform proposals, specifically regarding the Graham-Cassidy-Heller-Johnson health reform proposal's potential to weaken Medicaid
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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Thomas |
Susman |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code TAX
16. Specific lobbying issues
Draft Senate Finance Committee and House Ways & Means Committee tax reform bills-provisions imposing limitations on use of cash method of accounting
Draft legislation to amend the Internal Revenue Code of 1986 to exclude from gross income amounts received on account of claims based on certain unlawful discrimination and to allow income averaging for back pay and front pay awards received on account of such claims.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), 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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David |
Eppstein |
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Thomas |
Susman |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code TOR
16. Specific lobbying issues
H.R. 985, the Fairness in Class Action Litigation Act of 2017
H.R. 1215, the Protecting Access to Care Act of 2017
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 |
David |
Eppstein |
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Thomas |
Susman |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code TRD
16. Specific lobbying issues
General communications regarding trade in legal services and market access for U.S. lawyers and firms overseas, including regarding the implementation of the Korea-U.S. Free Trade Agreement and re-negotiation of the North American Free Trade Agreement
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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Thomas |
Susman |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code VET
16. Specific lobbying issues
S.1072, the Homeless Veteran Prevention Act (Burr, Tester, Hirono), to among other things, authorize private-public partnerships with the VA to deliver legal services to homeless veterans
S.591, the Military and Veteran Caregiver Services Improvement Act of 2017 (Murray), to expand, among other things, services available to caregivers under the VA Family Caregiver program to include legal.
H.R. 1993, the Homeless Veterans Legal Services Act (Beatty, Stivers, Tiberi), to authorize private-public partnerships with the VA to deliver legal to homeless veterans.
Activity in support of alternative methods of discharge review for veterans eligible for such review.
Activity in support of the recognition of the ABA and its veterans legal support initiatives as a strategic partner to the VA.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Veterans Affairs - Dept of (VA), 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 |
Ken |
Goldsmith |
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Thomas |
Susman |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code FIR
16. Specific lobbying issues
H.R. 38, the Concealed Carry Reciprocity Act of 2017 and S.446, the Constitutional Concealed Carry Reciprocity Act of 2017 - provisions relating to national reciprocity for state concealed carry permits.
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 |
Holly |
Cook |
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Thomas |
Susman |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
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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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:
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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 |