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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 | 2022 |
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: Holly Cook |
Date | 1/20/2023 3:56:40 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
P.L. 117-328 (H.R. 2617) - the Consolidated Appropriations Act, 2023
FY2023 Commerce, Justice, Science, and Related Agencies Appropriations - funding for the Legal Services Corporation; federal courts; immigration legal representation; immigration courts; Legal Orientation Program.
FY2023 State, Foreign Operations, and Related Programs Appropriations - funding for democracy and rule of law programs, funding for contributions to international organizations.
FY2023 Labor, Health and Human Services, and Education, and Related Agencies Appropriations - funding for the Office of Refugee Resettlement related to unaccompanied children legal services program, and funding to meet the educational needs of students in foster care.
Support for increased annual appropriations as well as robust funding for the Legal Services Corporation.
Support for student loan debt forgiveness, reforming and strengthening the Public Service Loan Forgiveness 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, 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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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. 7, S. 205, the Paycheck Fairness Act
H.R. 5444, the Truth and Healing Commission on Indian Boarding School Policies
H.R. 8404, S.4556, Respect for Marriage Act
H.R. 8297, the Ensuring Access to Abortion Act
H.R. 8452, the Reproductive Health Travel Fund Act of 2022
S. 4505, the Freedom to Travel for Health Care Act of 2022
S. 1486, the Pregnant Workers Fairness Act
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, 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 |
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
H.R. 1814/S. 879, the Civics Secures Democracy Act.
S. 2598 - FRESH START Through Bankruptcy Act of 2021.
S.Res.46 - A resolution calling on the President of the United States to take executive action to broadly cancel Federal student loan debt.
General support for student loan debt forgiveness, reforming and strengthening the Public Service Loan Forgiveness 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 |
Kristi |
Gaines |
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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
P.L. 117-263 (H.R. 7776, H.R. 7900, and S. 4543) - the James M. Inhofe National Defense Authorization Act for Fiscal Year 2023 -amendments 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.
P.L. 117-328 (H.R. 2617) - the Consolidated Appropriations Act, 2023 - amendments 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.
H.R. 5525, ENABLERS Act-provisions 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.
H.R. 1996, S. 910, the Safe Banking Act.
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)
Department of the Treasury Financial Crimes Enforcement Network Notice of Proposed Rulemaking on Beneficial Ownership Information Reporting Requirements; Docket No. FINCEN-2021-0005; RIN 1506-AB49, 86 Fed. Reg. 69920 (December 8, 2021)
Department of the Treasury Financial Crimes Enforcement Network Advance Notice of Proposed
Rulemaking on Beneficial Ownership Information Reporting Requirements; Docket No. FINCEN-
2021-0005; RIN 1506-AB49, 86 Fed. Reg. 17557 (April 5, 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.
U.S. Government Accountability Office study mandated by Congress in P.L. 116-283, Title LXIV of National Defense Authorization Act, Anti-Money Laundering Act of 2020, on the problems of money-laundering and terrorist financing and the roles that certain stakeholders, including attorneys and other gatekeepers, can play in combatting this illicit conduct.
Consumer Financial Protection Bureau Final Rule on Debt Collection Practices (Regulation F); Docket No. CFPB-2019-0022; RIN 3170-AA41, 85 Fed. Reg. 76734 (November 30, 2020)-provisions in original proposed rule creating a safe harbor for meaningful attorney involvement in debt collection litigation submissions.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Trade Commission (FTC), Consumer Financial Protection Bureau (CFPB), Treasury - Dept of, White House Office, Government Accountability Office (GAO)
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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David |
Eppstein |
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Michael |
O'Neill |
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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 suicide prevention, guns on higher education campuses, and assault weapons.
H.R. 8361, Preventing Suicide Through Voluntary Firearm Purchase Delay 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 |
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
S. 4240, the Justice for Victims of War Crimes Act and other draft legislation to amend U.S. law to extend jurisdiction over crimes against humanity.
Support increased funding for Democracy Programs and Contributions for International Organizations.
Communications regarding the UN Convention on International Settlement Agreements Resulting from Mediation (Singapore Convention).
S.4787, H.R. 8685, the Afghan Adjustment Act
Issues related to facilitating U.S. support and engagement with the International Criminal Court
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, State - Dept of (DOS), Natl Security Council (NSC), 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. 5720, S. 3069, the Courthouse Ethics and Transparency Act.
H.R. 4436, S. 2340, the Daniel Anderl Judicial Security and Privacy Act of 2021.
H.R. 4827, S. 2553, the Judiciary Accountability Act.
S. 789, the Repealing Existing Substandard Provisions Encouraging Conciliation with Tribes Act.
S.2701, H.R.4501, Office for Access to Justice Establishment Act of 2021.
S. 2614, the Open Courts Act.
S. 4573, the Electoral Count Reform and Presidential Transition Improvement Act
Communications regarding ethics guidance to government lawyers participating in outside professional organizations.
Activity in support of permanently establishing the Office for Access to Justice in the U.S. Department of Justice.
Support for authorizing new and filling existing vacant federal judgeships.
Legislation regarding diversity jurisdiction - to treat unincorporated entities the same are incorporated ones.
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.
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.
Administrative Conference of the United States' Recommendation 2021-5 titled "Clarifying Statutory Access to Judicial Review of Agency Action," adopted by the agency on September 17, 2021, and forwarded to congressional leaders for their consideration.
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 proceedings, and related best practices for federal agencies.
Office of Management and Budget Request for Information on Improving and Reforming Regulatory Enforcement and Adjudication; Docket No. OMB-2019-0006; 85 Fed. Reg. 5483 (January 30, 2020)-recommendations for certain amendments to the Administrative Procedure Act and other proposed reforms to the administrative adjudication process.
Revised Department of Justice ethics guidance (Representations Before the Government) further clarifying the ability of government lawyers and other employees to participate more fully in outside organizations, 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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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
S.4787, H.R. 8685, the Afghan Adjustment Act and other measures to facilitate permanent legal status for Afghans in the U.S.
Issues regarding enhancing access to legal representation for individuals in immigration removal proceedings and increasing funding for the Legal Orientation Program.
Issues relating to deferred action and increasing visa availability for children with approved petitions for Special Immigrant Juvenile status.
Issues regarding operations of the immigration courts, including establishing an Article I court.
H.R. 6577, the Real Courts, Rule of Law Act
Communications regarding decreasing the use of detention and expanding alternatives to detention, ensuring access to counsel for those in detention.
Issues relating to concerns about the establishment of a Dedicated Docket for certain families in removal proceedings and access to legal representation and information for those on the dockets.
Communications requesting the Attorney General to reverse the decision in Matter of Thomas & Matter of Thompson.
Communications in regard to ending the use of section 265 of Title 42 of the U.S. Code to block asylum seekers from applying for protection at the U.S. border and to expel them from this country without any adjudication of their claims.
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. 9393, the Restoring Court Authority Over Litigation Act
S. 79, the EQUAL Act, to equalize the sentencing for offenses involving crack vs powder cocaine.
S. 431, the Democracy Restoration Act, to restore eligibility to vote in federal elections following the completion of ones sentence.
H.R. 546, S. 3524, 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.
Support for full funding of programs authorized under the Violence Against Women Act.
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.
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)
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. 842/S. 420, 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
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
H.R. 3124, S. 653, the Coordination of Medicare Payments and Workers Compensation Act - to 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 TEC
16. Specific lobbying issues
H.R. 8152, the American Data Privacy and Protection Act - determining whether digital privacy legislation would place unique burdens on the legal profession.
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 |
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 TRD
16. Specific lobbying issues
General communications regarding international trade in legal services and market access for U.S. lawyers and law firms.
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.
Proposals relating to providing a private right of action for people with disabilities harmed by air carriers.
Support for reauthorization of the Child Abuse Prevention and Treatment 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 |
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
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 |
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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 |
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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) |