March 22, 2011

Bob Kabel, Chairman

DC Republican Committee
1275 K Street, NW
Suite 102
Washington, DC 20005

Re: Preliminary Investigation 2011-105

Dear Mr. Kabel:

This is to inform you that the Office of Campaign Finance (OCF) has initiated a
preliminary investigation pursuant to the complaint you filed alleging that
Councilmember Harry Thomas, Jr., might have violated certain provisions of the
Campaign Finance and Conflict of Interest Act. OCF determined that an investigation
was warranted following an extensive review of the information compiled in this matter.

Specifically, you alleged that Mr. Thomas failed to disclose the receipt a motor vehicle
from a Limited Liability Company (LLC) with whom he is affiliated and that he also did
not disclose travel expenses he received from a non-profit organization known as “Team
Thomas”. You additionally alleged that the LLC in question was paid in excess of
$10,000 by the Councilmember’s Principal Campaign Committee for services.

An additional issue of whether Mr. Thomas and members of his Council staff used
government resources for other than official government business in violation of the
Standards of Conduct will also be examined.

D.C. Official Code § 1-1106.02(a) states in pertinent part: “… the Mayor, the members of
the Council, and members of the Board of Education shall also disclose annually all
outside income and honoraria, as defined in § 1-1108.01, accepted during the calendar
year…”

DPM § 1804.1 states in pertinent part: “ An employee may not engage in any outside
activity which is not compatible with the full and proper discharge of his or her duties
and responsibilities as a government employee. Activities or actions which are not
compatible with government employment include but are not limited to the following:
Bob Kabel, Chairman
Preliminary Investigation 2011-105
Page Two

“ (b) Using government time or resources for other than official business, or
approved or sponsored activities, except that a District employee may spend a
reasonable amount of government time and resources on such projects, reports,
and studies as may be considered in aid of other government jurisdictions (local,
state, federal), provided the work so performed is within the scope of the
individual’s regular assignments as a District employee;

“ (c) Ordering, directing or requesting subordinate officers or employees to

perform during regular working hours any personal service not related to official
government functions and activities;” and,

“ (e) Engaging in any outside employment, private business activity, or interest

which permits an employee, or others, to capitalize on his or her official title or
position.”

The Office of Campaign Finance has opened an investigation into this matter to
determine whether there is merit to the allegations. Please see 3 D.C. M. R.,
§3701(2010). You are further advised that all proceedings and records of the Office of
Campaign Finance relating to the initiation or conduct of any investigation are held in
confidence until final disposition by order by the Director. However, the final disposition
of this matter shall be made part of the public record. See 3 D.C. M. R., §§ 3700.4 and
3700.5.

Finally, please refer to the above referenced Preliminary Investigation number on all
correspondence you transmit regarding this matter.

If you have any questions, do not hesitate to contact William O. SanFord, General
Counsel, on (202) 671-0550.

Sincerely

Cecily E. Collier-Montgomery
Director

cc: William O. SanFord

General Counsel