FW: Follow up

Leslie,

As we discussed, I have attached an opinion letter from my election law attorney.

Please note the bolded section below in the final paragraph:

Since the direct mail pieces you have described meet none of those four standards, they
do not meet the “content” prong of the three-part coordination test and thus will not be
considered in-kind contributions.  Furthermore, since they will not advocate for or against any
particular candidates, nor will they even “promote, support, attack, or oppose” such a
candidate, a group that limits its activities to funding these ads will not constitute a political
committee, and thus will not have to comply with the limits, prohibitions, and disclosure
obligations imposed on such committees but the Federal Election Campaign Act.  

For the reasons detailed in the letter, that means that any payment from Mr. Epstein to my firm (Gold Communications Company) for issue advocacy mail will not be subject to any disclosure nor will it be disclosed to the FEC or anyone else.

Please let me know if Mr. Epstein has any other questions. If not, please let me know how he wishes the invoice to be prepared and I will send it to you.

Many thanks,

Dave Gold
President
Gold Communications
www.goldcommunications.com
575-776-1486