ron calderon asks for contempt in fbi affidavit leak

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GERAGOS f GERAGOS A PROFESSIONAL CORPORATION

LAWYERS HISTORIC ENGINE CO. NO. 28 644 SOUTH FIGUEROA STREET

Los ANGELES, CALIFORNIA 9001 7-341 1 TELEPHONE (21 3) 625-3900 FACSIMILE (213) 625-1600

[email protected]

RONALD S. CALDERON,

Plaintiff/Petitioner

v.

UNITED STATES,

Defendant/ Respondent

IN RE: CRIMINAL VIOLATION OF COURT ORDER SEALING AFFIDAVIT

CASE NO.:

NOTICE OF MOTION AND MOTION FOR ORDER TO SHOW CAUSE WHY GOVERNMENT SHOULD NOT BE HELD IN CONTEMPT FOR VIOLATION OF MAGISTRATE JUDGE'S ORDER SEALING FBI AFFADAVIT; MEMORANDUM OF POINTS AND AUTHORITIES; REQUEST FOR SANCTIONS

TO BE FILED PUBLICLY — NOT TO BE PLACED UNDER SEAL

INITIATING DOCUMENT

Trial Date: TBD Hearing Date: TBD Time: TBD Place: TBD

MARK J. GERAGOS SBN 108325 Attorneys for RONALD S. CALDERON

UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF CALIFORNIA,

SACRAMENTO DIVISION

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NOTICE OF MOTION AND MOTION FOR ORDER TO SHOW CAUSE WHY GOVERNMENT SHOULD NOT BE HELD IN CONTEMPT FOR VIOLATION MAGISTRATE JUDGE'S ORDER

SEALING FBI AFFADAVIT; MEMORANDUM OF POINTS AND AUTHORITIES; REQUEST FOR SANCTIONS

Case 2:13-at-01311 Document 1 Filed 11/13/13 of 14

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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE that on a date and time to be determined by the above-

captioned Court, located at 501 I Street, Sacramento, California 95814, moving party Senator

Ronald S. Calderon will, and hereby does, move this Court for an Order to Show Cause as to

why the United States Government, and its agents, should not be held in contempt for

illegally leaking an affidavit, sealed pursuant to the orders of the Federal Magistrate Judge of

this Honorable Court, to the media in an effort to defame and retaliate against Senator

Calderon for not cooperating in its "sting" operation against Senator Darrell Steinberg and

Senator Kevin de Leon.

PLEASE TAKE FURTHER NOTICE that Senator Ronald S. Calderon will, and

herby does, seek all appropriate sanctions against the United States Government, and its

agents, for irreparably tainting future grand jury proceedings and causing irreparable harm to

Senator Calderon's reputation.

This motion is based on this Notice, the accompanying Memorandum of Points and

Authorities, the attached exhibits, and such other argument and evidence as may be

presented at the hearing on this Motion.

DATED: November 13, 2013

GERAG AGOS, APC

By: MAR AGOS Attorneys fo Defendant RONALD S. CALDERON

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MEMORANDUM OF POINTS AND AUTHORITIES

I. INTRODUCTION

Senator Ronald S. Calderon was approached on six separate occasions by high level

agents of the Federal Bureau of Investigation and on two occasions by the Assistant United

States Attorney for the Central District of California Doug Miller demanding that Senator

Calderon participate in a sting operation against Senate President pro Tern Darrel Steinberg.

The FBI agents requested that Senator Calderon wear a wire and secretly record his

conversations with Senator Steinberg and Senator Kevin de Leon. The FBI was specifically

interested in Senator Steinberg's financial activities with Michael Drobot, the former Chief

Executive Officer of Pacific Hospital of Long Beach. Senator Calderon refused to continue

participating in the FBI's sting operation, and rejected their demands to secretly record

conversations with Senator Steinberg and Senator de Leon. Senator Calderon, through the

law office of Geragos & Geragos, APC, returned the wire equipment supplied by the FBI to

the agents working for United States Attorney's Office for the Central District of California.

Attached hereto as Exhibit "A" is a true and correct copy of the "Acknowledgement of

Receipt" signed by the FBI for the wireless transmitter-serial number P235, returned by

Senator Calderon.

Further, on June 4, 2013—shortly after Senator Calderon refused the FBI's request to

participate in its sting operation—the FBI conducted a raid on Senator Calderon's office.

The media was alerted to the raid, as it was taking place, by sources at the FBI working for

Assistant United States Attorney-Central District of California (AUSA-CDC). The FBI raid

of Senator Calderon's office became a media spectacle with camera crews present for the

entire ordeal. The FBI raid was conducted after the FBI presented an affidavit which

included numerous false and defamatory allegations about Senator Calderon. The FBI

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affidavit omitted facts that just days before the affidavit was prepared, the FBI was

attempting to use Senator Calderon as an informant against Senators Steinberg and de Leon.

The FBI affidavit was ordered sealed by the Magistrate Judge of this Honorable Court.

On October 30, 2013, the news outlet "Al Jazeera America" published an article

which included the FBI's affidavit relating to the search warrant of Senator Calderon's

office. The article included other confidential details concerning the FBI's investigation.

Attached hereto as Exhibit "B" and "C" are true and correct copies of the Al Jazeera Article

and FBI affidavit attached to the article. The source of the leaked affidavit could only have

come from the FBI and/or the AUSA-CDC which was directing the FBI operation. The

details of the FBI's investigation, the strategy and direction of the investigation, the potential

charges being considered by the government, and the contents of the FBI's affidavit are all

information that could be known only to those within the U.S. Attorney's office.

The AUSA-CDC has a history of having confidential and sealed documents under the

office's control leaked to the press. Specifically, the pattern of illegal leaks coming from the

office of AUSA Doug Miller is troubling, with the media sensationalism created by those

leaks bearing no relation to the ultimate facts and law. Here, it is clear that the FBI and/or

AUSA-CDC engaged in a campaign to smear the reputation of Senator Calderon and convict

him in the press and public before a grand jury was assembled and while it was hearing

evidence. Short of that, they seek to have him removed from office. The egregious

constitutional violations committed in this case were not motivated by the ends of justice, but

were instead efforts by the AUSA-CDC to retaliate against Senator Calderon for derailing

the FBI/AUSA sting operation on the California State Senate by refusing to participate as

their informant.

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II. FACTUAL BACKGROUND

A. The Leak

On October 30, 2013, Al Jazeera America published an article written by Trevor

Aaronson and Josh Bernstein which describes the allegations contained in the FBI's sealed

affidavit. The article contains a downloadable copy of the FBI affidavit. The affidavit was

ordered to be sealed and kept confidential by the Magistrate Judge for the United States

District Court, Eastern District of California. Leaking the sealed affidavit to the press is

expressly prohibited and illegal.

The October 30, 2013 Al Jazeera article claims that the FBI's affidavit was provided

to Al Jazeera America's Investigative Unit. The article contains descriptions of names of

numerous potential witnesses, the nature of the purported allegations against Senator

Calderon, the details of the investigation conducted by the FBI, purported conversations with

Senator Calderon, and other blatant hearsay. All of this information was under seal. The

article admits that the affidavit is "still under seal." The article continues by using

completely false and fabricated information taken from the affidavit to smear Senator

Calderon and his family. Al Jazeera claims that its attorneys redacted portions of the

affidavit to protect the identities of the FBI agents involved in the raid. We have evidence

that Al Jazeera reporters were in prior contact with FBI Public Information Officer Samora

Ivera.

Following the publication of the October 30 Al Jazeera article, the FBI announced an

investigation into the unauthorized leak of the sealed affidavit'. On November 7, 2013 the

I FBI seeks investigation of source of leaked affidavit, The Sacramento Bee (November 1, 2013). at hap://blogs.sacbee.comicapitolalertlatest/2013110/fbi-seeks-investigation-of-source-oldeaked-affidavit.html.

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FBI released another statement refusing to comment on the pending investigation and

confirming that the investigation into the source of the leak was referred to the Department

of Justice.2 However, the FBI's "investigation” into the illegal leak is little more than the fox

guarding the proverbial henhouse since the likely source of the illegal leak is inside the

Department of Justice where the so-called investigation has now been referred.

B. Retaliation by the FBI and/or the AUSA-CDC

The leaker in this case deliberately released the FBI's sealed affidavit to publicly

disgrace Senator Calderon. The false information contained in the FBI affidavit, the illegal

raid on Senator Calderon's office, and the most recent leak of the under seal affidavit were

part of a calculated effort by the FBI and/or the AUSA-CDC to retaliate against Senator

Calderon.

Shortly before the FBI raid took place, Senator Calderon refused to participate in the

sting operation planned by the FBI and AUSA Miller against Senator Steinberg. Senator

Calderon was given a wire to wear and was asked to record his communications with Senator

Steinberg and Senator de Leon. High level FBI agents met with Senator Calderon on six

occasions and AUSA Miller met with Senator Calderon on two separate occasions to try and

convince the Senator to participate in the sting operation targeting the financial dealings

between Senator Steinberg and Michael Drobot and other donors to the Senate pro Tem' s

political action committees. Senator Calderon refused to participate in the sting operation

and returned the wire equipment to the FBI. In response, the FBI and AUSA Miller pursued

frivolous and fabricated allegations against Senator Calderon and permitted such allegations

2 Randy Economy & Brian Hews, BREAKING: FBI Issues Statement on Al lazeera America Expose on The Calderons, Los Cerritos Community Newspaper (November 7, 2013). at http://www.Ioscerritotint wsJiet/20 13/ 1 0/3 I /breaking,- fbi-issues-statement-on-al-j a ica-expose-on-the- ialkr(- 15/.

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to leak to the press in violation of Court order.

The AUSA-CDC has attempted to convict Senator Calderon in the press through an

illegal disinformation campaign. While false information concerning Senator Calderon has

been illegally leaked to the press, critical facts regarding the AUSA-CDC's activities have

been omitted or misrepresented. For example, the Los Angeles Times reported that AUSA

Miller subpoenaed Senator de Leon in connection with the investigation of Senator Calderon

but "indicat[ed] that de Leon is not target of the investigation."3 However, this statement, in

a letter to Senator de Leon's attorney signed by AUSA Miller, is demonstrably false since

Senator Steinberg and Senator de Leon were the main targets of the investigation, for which

Senator Calderon was requested to be the FBI's informant.

C. Similar Leaks Have Plagued the Government's Investigations into Other Cases Handled by the AUSA-CDC

The illegal leak of under seal records in this case is apparently the modus operandi for

how high profile and sensitive cases are handled by AUSA Miller's office. AUSA Miller

has been the common thread in a string of illegal leaks over the years. For example, AUSA

Miller was involved in the investigation into steroid use in major league baseball in 2003-

2004. In June 2009, the New York Times published an article disclosing a name of a player

who purportedly appeared on the "positive results" lists in an under seal filing. The New

York Times Article quoted "an anonymous source" who did not want to be identified as

discussing matter because it was sealed with the court. See In re: GRAND JURY LEAKS,

2011 WL 2766956 (C.D. Cal 2011). Additionally, in 2011 AUSA Miller headed the

3 See Federal prosecutor probing Calderon is used to high-profile cases , Los Angeles Times (November 1,

2013), at http://www.latimes.com/local/political/la-me-pc-ron-calderon-investigation-prosecutor-20131101,0.3060451.story#axzz2kTDG9vSN

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government' s investigation of professional athlete Lance Armstrong. In that case, multiple

instances of sealed and confidential information being leaked to the press were identified.

Mr. Armstrong's attorneys filed a sanctions motion against the government, and its agents,

for the illegal leaks that tainted the grand jury procedures. See Id.

The pattern of illegal leaks in cases handled by the AUSA-CDC has grown more

brazen over the years culminating in the most flagrant and prejudicial violations yet with

respect to Senator Calderon. There is a systematic and systemic pattern of contempt for

secrecy rules in AUSA Miller's cases resulting in the complete corruption of the legal

process and character assassination of his targets. This conduct is deeply disturbing given

that AUSA Miller purports to represent the "public corruption" division within the AUSA's

office.

D. Irreparable Harm to Senator Calderon

The inviolable secrecy of pre-indictment documents is derived from constitutional

norms to preserve the presumptions of innocence. Although the government routinely holds

press conferences and issues press releases to saturate the public with their version of events,

in mostly all cases that conduct occurs after an indictment is issued and an individual is

charged with a crime. Here, the prejudice caused to Senator Calderon is compounded

because not only has Senator Calderon not been charged with a crime, but the illegal leaks

have occurred while the Grand Jury is hearing evidence. The leaks of sealed records in this

case are calculated to fast track and strong-arm a meritless case against Senator Calderon

through the grand jury process and then apparently shame Senator Calderon into accepting a

plea agreement. The release of the sealed records has prejudiced any future grand jury

proceeding and irreparably tainted any future court proceedings involving Senator Calderon.

The illegal leaks have also served to discredit and defame Senator Calderon in the

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public before any proceedings have been held. Senator Steinberg, who was the target of the

government's investigation for his conduct, has stripped Senator Calderon from his

committee positions and, on November 12, 2013 proclaimed he "will be damned" if Senator

Calderon harms the reputation of the California State Senate4. Assemblymember Christina

Garcia and numerous news outlets have publicly called on Senator Calderon to resign.5

Despite the fact that no charges against Senator Calderon have been filed, Senator

Calderon's reputation has been irreparably damaged by the selective and illegal leak of the

fabricated FBI affidavit which was ordered sealed. The presumption of innocence has been

turned on its head.

III. ARGUMENT

A. Leaking Sealed Records Is Illegal

The Ninth Circuit has consistently recognized that "warrant materials during the pre-

indictment phase of an investigation . . . warrant the highest protection." Kamakana v. City

and County of Honolulu, 447 F.3d 1172, 1185, fn. 23 (9th Cir. 2006). Public access to

records, "while important, had to be tempered by the rule of secrecy because of the well-

recognized policies behind that rule." Times Mirror Co. v. U.S., 873 F.2d 1210, 1219 (9th

Cir. 1989). These public policy considerations include preserving the presumption of

innocence of an individual who is targeted, but not yet charged, by the government and

avoiding taint in future grand jury proceedings or in the event charges are filed. Id.

4 Steinberg: 'Ti! Be Damned" If Scandal Taints Senate (November! 0, 2013), http://www.nbc I osange le s .com/new s/loc al/Darrell-ste inberg-senate-pro-tem-news-c onference-c a lderon-231326421.html

5 State Sen. Ron Calderon must resign, right now: Editorial, Long Beach Press Telegram (November

5, 2013), http://www . pre sste legram. c om/opin ion/20131105/state-sen-ron-calderon-m ust-re s ign-right-now-editorial.

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Tampering with pre-indictment procedures, including leaking sealed documents,

raises other concerns rising to the level of serious criminal violations. Specifically, 18

U.S.C.A. § 1509—Obstruction of Court Orders states:

Whoever, by threats or force, willfully prevents, obstructs, impedes, or interferes with, or willfully attempts to prevent, obstruct, impede, or interfere with, the due exercise of rights or the performance of duties under any order, judgment, or decree of a court of the United States, shall be fined under this title or imprisoned not more than one year, or both.

Additionally, the Unites States Code criminalizes acts of retaliation against witnesses

or informants during pre-indictment procedures. 18 U.S.C.A. § 1513—Retaliating against a

witness [or] an informant, provides:

(e) Whoever knowingly, with the intent to retaliate, takes any action harmful to any person, including interference with the lawful employment or livelihood of any person, for providing to a law enforcement officer any truthful information relating to the commission or possible commission of any Federal offense, shall be fined under this title or imprisoned not more than 10 years, or both.

(f) Whoever conspires to commit any offense under this section shall be subject to the same penalties as those prescribed for the offense the commission of which was the object of the conspiracy.

(g) A prosecution under this section may be brought in the district in which the official proceeding (whether pending, about to be instituted, or completed) was intended to be affected, or in which the conduct constituting the alleged offense occurred.

Here, the conduct of leaking sealed records to retaliate against Senator Calderon for

his activity as a witness and informant against Senator Steinberg invokes both 18 U.S.C.A. §

1509—Obstruction of Court Orders and U.S.C.A. § 1513—Retaliating against a witness [or]

an informant.

Individuals responsible for leaking confidential pre-indictment documents and

information have received severe punishments by Courts. For example, in U.S. v. Hall

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2011 WL 6291957 (D.Vt. 2011) a paralegal working for the U.S. Attorney's Office was

caught leaking sealed documents to her boyfriend who was under investigation. The

defendant in that case was charged with obstruction of justice. The defendant accepted a

plea deal for three years of probation. At the sentencing of the defendant, the federal court

explained, "This is an extremely serious offense . . . I've never seen anything like it before in

my 16 years on the bench. . .You understand that what you did goes to the heart of what the

criminal justice systems is about?6"

Leaks of confidential pre-indictment material also violate the Department of Justice's

own rules. The United States Attorney's Manual ("USAM") expressly recognizes the need

for confidentiality and prohibits prosecutors from making public comments regarding the

nature and progress of ongoing investigations; any statements made by a target or the failure

of a target or subject to make a statement; and the identities of prospective targets, subjects,

or witnesses. See USAM §§ 1-7.111, 1-7.500, 1-7.530. The USAM also makes clear that

"[a]t no time shall any component or personnel of the Department of Justice furnish any

statement or information that he or she knows or reasonably should know will have a

substantial likelihood of materially prejudicing an adjudicative proceeding." USAM § 1-

7.500.

Leaking sealed pre-indictment records and affidavits also violates Federal Rules of

Criminal Procedure 49.1 and Local. Rule 141. Both of these rules protect sealed documents

from public disclosure. At a minimum, violating the Court's sealing orders subjects the

violating party to contempt proceedings and sanctions. See In Matter of Respondent X, 1997

WL 90832 (Cal.Bar Ct., 1997) (acknowledging that attorney may be found in criminal

contempt for violating a court's sealing order and imposing discipline on the violating

attorney).

6 Ex-paralegal sentenced for Burlington grand jury leak (May 15, 2012) http://www.burlingtonfreepress.com/article/20120515/NEWS02/120514026/




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In a contempt proceeding, the "moving party has the burden of showing by clear and

convincing evidence that the contemnor violated a specific and definite order of the court."

F.T.C. v. Affordable Media, 179 F.3d1228, 1239 (9th Cir. 1999), (quoting Stone v. City and

County of San Francisco, 968 F.2d 850, 856 n.9 (9th Cir. 1992)); see also In re Crystal

Palace Gambling Hall, Inc., 817 F.2d 1361, 1365 (9th Cir. 1987) ("If a person disobeys a

specific and definite court order, he may be properly adjudged in contempt.") citing Shuffler

v. Heritage Bank, 720 F.2d 1141, 1146 (9th Cir. 1983). If the moving party meets its burden,

the burden is then on the violator to demonstrate why he has not complied with the order.

See Affordable Media, 179 F.3d at 1239.

Here, the Magistrate's Order to seal the FBI affidavit followed the historical and

sacrosanct judicial and constitutional precedent of maintaining strict confidentiality of pre-

indictment documents and records. The FBI affidavit was only possessed by the FBI and the

AUSA-CDC. The FBI investigation was conducted under the auspices of the AUSA-CDC.

Other than referring the investigation over its own misconduct to itself, the government has

provided no explanation why the affidavit was furnished to Al Jazeera America. The leak in

this case follows a history of leaks in high profile cases handled by AUSA Miller.

The fact that the affidavit was leaked, when only the government had access to the

document, inherently implicates the government as the source of the leak and shifts the

burden to the government to answer for its conduct. The Fifth Circuit Court of Appeal' s

analysis regarding leaks is instructive. The Court has held that an inference is made that the

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The violations committed here are thus criminal, contemptible, procedural, and a

violation of the Department of Justice's own rules.

B. The Government Should be Held in Contempt for Violating the Magistrate Judge's Order to Seal the FBI's Affidavit


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government was the source of the leak when some variation of the following information is

published:

(i) the name of "a specific witness...to be called," and "a specific question which the witness will be asked;" (ii) "specific types of criminal conduct which the grand jury was focusing upon;" (iii) "the contents of documents presented to the grand jury;" (iv) "information learned by the grand jury;" and (v) particular entities "whose activities were being investigated.

In re: Grand Jury Investigation (Lance), 610 F.2d 202, 218 n. 12. (5th Cir. 1980). See also

U.S. v. Flemmi, 233 F.Supp.2d 113, 117-18 (D.Mass 2000) (ordering government to submit

affidavits proving it was not the source of the leak where a single news article, citing

"sources familiar with the investigation," was "susceptible to the interpretation that it reports

on evidence that is not part of the public record, but which was presented to the grand jury or

was provided to investigators acting as the grand jury's agents.")

Here, the information released in the Al Jazeera article is precisely the type of

information only the government had access to. Indeed, the leak in this case exceeds the

mere inference that the government leaked the records since the actual affidavit was

delivered to the press.

C. Since The Government Is The Source Of The Leak, The Court Should Impose Sanctions.

This Court has the inherent power to enforce compliance with its lawful orders

through contempt. Shillitani v. United States, 384 U.S. 364, 370 (1966); See also 18 U.S.C. §

401 (1982); Young v. United States, 481 U.S. 787, 793 (1987); In re Crystal Palace, 817

F.2d at 1364; see also Fed R. Civ. P. 70. The court's powers in contempt proceedings are

broad, Spallone v. United States, 493 U.S. 265, 276 (1990), and include the authority to

impose sanctions to coerce compliance with a court order, Int'l Union, United Mine Workers

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GERAG00" .74 S, APC

By: MARK J. OS Attorneys for D fendant RONALD CA DERON

of America v. Bagwell, 512 U.S. 821, 829 (1994), and to compensate affected persons and

entities for losses caused by the contemnor's actions. Transact Technologies, Inc. v. Isource

Worldsite, 406 F.3d 851, 855 (7th Cir. 2005). Sanctions may be imposed to coerce

defendants into compliance with the court's order, or to compensate the party pursuing the

contempt action for losses sustained as a result of the contemptuous behavior, or both.

United States v. United MM Workers, 330 U.S. 258, 303-304 (1947); United States v. Bright,

596 F.3d 683, 696-697 (9th Cir. 2010)

The government has demonstrated contempt for the Court's Order to seal the FBI's

affidavit. Based on the clear and convincing evidence presented in this motion, Senator

Calderon respectfully requests the Court order the government to show cause why it should

not be held in contempt and subject to all appropriate sanctions.

IV. CONCLUSION.

Based on the foregoing, California State Senator Ronald S. Calderon respectfully

requests that the Court issue an Order to Show Cause why the United States, and its agents,

such not be held in contempt for leaking sealed and confidential records and irreparably

prejudicing Senator Calderon.

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DATED: November 13, 2013


EXHIBIT A

Case 2:13-at-01311 Document 1-1 Filed 11/13/13 Page 1 of 2

GERAGOS f GERAGOS A PROFESSIONAL CORPORATION

LAWYERS 644 SOUTH FIGUEROA STREET

LOS ANGELES, CALIFORNIA 90017-341 1 TELEPHONE (2 1 3) 625-3900 FACSIMILE (2 1 3) 625-1600

[email protected]

ACKNOWLEDGMENT

I, the undersigned, acknowledge having received on June 13, 2013, a wireless transmitter identified by a serial number beginning with P235, from Geragos & Geragos, APC.

Received By:

Print name:

Date:


EXHIBIT B


(/)

Watch Part 2 of Al Jazeera's investigation here (/watch/shows/america-tonight/2013/10/capitol-

corruptioninsideanfbistingparttwo.html).

By Trevor Aaronson (http://america.aljazeera.com/profiles/a/trevor-aaronson.html) and Josh Bernstein

(http://america.aljazeera.com/profiles/b/josh-bernstein.html)

LOS ANGELES — Ronald Calderon is a powerful state senator in California who holds sway over the

glamorous Hollywood movie industry. He is also, according to the Federal Bureau of Investigation, a

politician on the take.

Exclusive: Hollywood stingOctober 30, 2013 | 9:00PM ET

FBI investigation of a California political dynasty uncovers alleged bribery and corruption in the

shadows of Tinseltown

View comments


http://america.aljazeera.com/

http://america.aljazeera.com/watch/shows/america-tonight/2013/10/capitol-corruptioninsideanfbistingparttwo.html

http://america.aljazeera.com/profiles/a/trevor-aaronson.html

http://america.aljazeera.com/profiles/b/josh-bernstein.html

A hefty 56-year-old Democrat with salt-and-pepper hair, Calderon has been a red-carpet star in California

politics for more than a decade. As an assemblyman and now a state senator representing suburban Los

Angeles, he has established a well-earned reputation for spending campaign money and taxpayer funds on

himself.

He’s used campaign cash to cover the finer things in life — plush golf outings, lavish trips to Cuba and Las

Vegas, meals at exclusive restaurants and hotels. When California offered to purchase cars for the state’s

elected officials, Calderon chose the most expensive one: a $54,830 Cadillac STS V8 luxury sedan.

(http://america.aljazeera.com/articles/calderon-

dynasty.html)

Click for more on The Calderon Dynasty

But his days as a big spender may soon be over. The

FBI is hot on his trail in an investigation that could

become California’s biggest legislative scandal in more

than two decades and could signal the downfall of a

political dynasty. The FBI employed an undercover sting

for more than a year that ended when agents raided the

senator’s office in Sacramento in June.

Al Jazeera’s Investigative Unit subsequently learned of

the secret operation. This account is based on a 124-

page affidavit, still under seal, filed by the FBI in U.S.

District Court in Sacramento in support of a search

warrant used in the raid.

The names of several other senators, including the Senate president and the chair of the California Latino

Legislative Caucus, have surfaced in the case, although none has been implicated.

The document lays out a sordid tale of alleged bribery and corruption. Undercover FBI agents posed as

independent movie executives interested in taking advantage of a program in which films with budgets of $1

million or more are eligible for special tax credits. The agents, focusing on Calderon, asked the senator to

help lower the budget threshold to $500,000. Calderon, who chairs the Senate Select Committee on

California's Film and Television Industries, agreed to help lower it to $750,000 but wanted financial

assistance provided to his grown children, the affidavit says.

READ THE AFFIDAVIT

FBI affidavit supporting search of Calderon offices (/articles/2013/10/30/sealed-fbi-

affidavitsupportingsearchofcalderonoffices.html)

•


http://america.aljazeera.com/articles/calderon-dynasty.html

http://america.aljazeera.com/articles/2013/10/30/sealed-fbi-affidavitsupportingsearchofcalderonoffices.html

On June 21, 2012, for instance, in a restaurant in Pico Rivera, Calif., outside Los Angeles, Calderon said he

could lower the budget threshold if the movie executive would hire his daughter, Jessica.

“There might be a play, you know, to lower the tax credit.” He went on: “Any help you could do for my kids is

— you know, that’s diamonds for me.”

The agent agreed to hire Calderon’s daughter for $3,000 a month if the senator could help reduce the

movie budget threshold “sooner rather than later.”

They had a deal. Calderon’s wife, Ana, would draw up an employment agreement for Jessica and the movie

executive. That written agreement, Calderon said, was “to keep it legit.” The FBI summarized his thinking in

the court document: “You never take money directly from people and you have to be careful about a tit-for-

tat relationship.”

In reality, the record says, the arrangement was tit-for-tat: There was no work for Jessica, and payments to

her were linked to Calderon’s efforts to sponsor favorable legislation. Over the course of the sting

operation, the affidavit says, the FBI provided $60,000 to Calderon, much of it through his two children.

For the senator, such arrangements weren’t unusual. Separately, the FBI court filing says, Calderon also

used his son, Zachary, to accept kickbacks from a hospital executive, Michael D. Drobot

(/articles/2013/10/30/fbi-california-statesenatoraidedallegedmultimilliondollarfraud.html), whose companies

have received more than $161 million in state insurance payments. The state has sued Drobot, alleging he

was behind “multiple fraudulent schemes.”

RELATED — FBI: California state senator aided alleged multimillion-dollar fraud (/articles/2013/10/30/fbi-

california-statesenatoraidedallegedmultimilliondollarfraud.html)


http://america.aljazeera.com/articles/2013/10/30/fbi-california-statesenatoraidedallegedmultimilliondollarfraud.html


Ronald Calderon is part of a California political dynasty that has controlled powerful state legislative

committees for decades. During that time, the Calderons have been sharply criticized in the California media

for using campaign cash for personal benefit. Indeed, politics and money are the lifeblood of the Calderon

family.

According to the affidavit, Ronald and his older brother Thomas, who previously held a seat in the California

State Assembly, have collected more than $1 million in payments from people who have wanted to shape

California laws to their benefit. In some cases, the Calderons used Californians for Diversity, a nonprofit

organization connected to the Latino caucus, as their personal slush fund.

James J. Wedick, a former FBI special agent, reviewed the court document at the request of Al Jazeera.

Wedick is an expert on undercover sting operations. In 1988, his agents set up a front company in

California and paid bribes in a case that led to the conviction of four elected officials and 10 legislative

aides.

This time around, he said, voters in California can expect to see another shake-up of politics and

government. “It’s going to be an ugly scene when this information comes to light,” Wedick said. “That, in

fact, you have elected officials taking money in exchange for legislation. It undermines our democracy.”

Building a dynasty

The story of the Calderon political dynasty begins in 1982, when Charles “Chuck” Calderon won the District

59 seat in the California State Assembly. In 1988, he led a group of five assemblymen in unsuccessfully

challenging the leadership of powerful Speaker Willie Brown. The speaker stripped the challengers of their

committee chairmanships and removed them from their choice offices.

But Calderon was not deterred. In 1990, he won a seat in the state Senate and would later become Senate

president, the first Latino to hold the position in California. At the same time, he was dogged by ethics

charges. In 1994, the state fined him $15,000 for spending campaign funds on personal expenses.

(/articles/2013/10/30/fbi-california-

statesenatoraidedallegedmultimilliondollarfraud.html)

Pacif ic Hospital of Long Beach, Calif . Al Jazeera's

Investigative Unit

State Sen. Ronald Calderon accepted bribes from a

Southern California hospital executive who ran an

alleged workers’ compensation scheme that brought the

executive tens of millions of dollars, according to a

sealed FBI affidavit obtained by Al Jazeera’s Investigative

Unit.

Read more (/articles/2013/10/30/fbi-california-

statesenatoraidedallegedmultimilliondollarfraud.html)




Inside the FBI sting

The FBI affidavit provides rich details on the sting. It indicates that an unidentified legislative aide introduced

Ronald Calderon to an undercover agent at a lunch event in Los Angeles on Feb. 24, 2012. The agent

presented himself as an independent movie executive with a studio in downtown L.A. Calderon described

the movie tax credit program and also mentioned that his daughter, Jessica, was interested in the film

industry.

Over a subsequent lunch meeting, the legal document says, Calderon and the agent brokered their deal:

The movie studio would hire Jessica, and Calderon would sponsor legislation that would change the movie

budget requirements for a tax credit from $1 million to $750,000.

On July 17, 2012, about a month after that lunch meeting, Calderon visited the agent’s apartment in Los

Angeles. The agent told him that paying Jessica a monthly retainer was “not the industry standard,”

according to the FBI account. The agent said he wasn’t paying to hire Jessica — he was hiring the senator.

The affidavit describes this conversation:

State Sen. Ronald Calderon's district off ice is located in

Montebello, Calif ., outside Los Angeles. Al Jazeera's

Investigative Unit

With his political star rising, Calderon laid the path for his

siblings to join the family business of politics. In 1998,

Thomas won a seat in the Assembly and was handed the

plum chairmanship of the Insurance Committee. In 2002

he ran unsuccessfully for state insurance commissioner.

Meanwhile, Ronald, the youngest brother, ran for and

claimed Thomas’ former Assembly seat.

Ronald moved to the state Senate in 2006, and Charles,

having lost an earlier bid to be state attorney general,

reclaimed the seat in the Assembly.

“What makes the Calderons unique is that they are

passing on a baton within the same family, within the same surname,” said Louis DeSipio, a political science

professor at the University of California, Irvine, who studies California politics. “It’s not at all uncommon for

an elected official who’s leaving office, particularly after a long term of service, to designate a successor …

With the Calderons, though, the desire seems to have been to maintain the influence within the same

family.”

Ronald, the least polished of the three brothers, rose in power and influence after joining the state Senate.

He was appointed to the California Film Commission, which allocates $100 million in annual state tax credits

to various film projects. He also became active in the increasingly powerful Latino caucus and, by 2011, was

appointed its vice chairman.

The next year, Ronald Calderon met an independent movie executive who was eager to see the state tax

credit requirements changed. Calderon did not realize that the friendly movie executive was an FBI

undercover agent.


“Money is not an object,” the undercover agent said. “I mean, I’m ready to write a check for the next year if

that’s what you want —”

“Right, right,” Calderon said, interjecting.

“For everything. That’s not the issue. And it’s never been an issue.”

“Uh, huh,” Calderon said.

“Jessica’s talent, uh, her acumen — that’s not even an issue. That the whole concept behind this was — we

have a relationship. We have a professional relationship. We have a business relationship. And to put it in

very blunt terms, me hiring Jessica was not about her talents, right? It was more about accommodating

something that you needed. And you needed me to take care —”

“Right.”

“Helping your children,” the agent finished.

“Right,” Calderon said.

By August 2012, according to the affidavit, Jessica had not performed any work for the fictitious movie

studio but had received $27,000 in payments. The FBI document says that when a check arrived at

Calderon’s ranch-style house in Montebello, where Jessica also lived, Calderon emailed the agent using

coded language: “Package received.”

Calderon invited the agent to attend the Imagen Awards ceremony, honoring Latino entertainers, with him at

the Beverly Hilton hotel on Aug. 10, 2012, the filing says. Calderon and his wife attended, and the agent

came with a date of his own, another FBI operative who played the part of his girlfriend and an aspiring

model. At the awards dinner, Calderon described how he planned to introduce an amendment in the Senate

(/articles/2013/10/30/fbi-undercover-

stingscatchingpoliticiansredhanded.html)

Rep. Richard Kelly as he w as f ilmed by the FBI in the course

of its 1980s ABSCAM investigation. AP

RELATED — FBI undercover 'stings': Catching politicians

red-handed (/articles/2013/10/30/fbi-undercover-


An all-expenses-paid trip to Napa Valley; a wad of cash,

carefully counted out, laid on a desk and tucked into a

suit pocket; a suitcase filled with money picked up at an

airport hotel. These are just a few ways bribe money has

been handled by politicians in which political favors are

peddled for hard cash.

Read more (/articles/2013/10/30/fbi-undercover-



http://america.aljazeera.com/articles/2013/10/30/fbi-undercover-stingscatchingpoliticiansredhanded.html



to lower the movie tax credit requirements. “Nobody will ever know that the reason this happened is because

of you,” he told the agent, according to the FBI document. “I would not have pushed this hard if it wasn’t for

you.”

But his amendment hit a roadblock. A legislative aide soon informed him that the amendment would require

a two-thirds vote, a near impossibility. “We are screwed!” Calderon wrote to the undercover agent,

according to the affidavit.

“This is bullshit, Ron. We gotta make this work,” the agent replied by email. “Even if the proposed

amendment is shot down, we win. If we don’t even propose the amendment, then I’m done.”

The pair met for dinner in Pico Rivera, Calif., to reassess their situation. The agent got right to the point,

according to the court record: He asked if Calderon would be willing to write a letter for the movie studio’s

investor “stating his commitment to introducing legislation that would lower the threshold for the tax credit

legislation to $750,000.” Calderon agreed, but for the sake of appearances, he suggested writing the letter

to a group, not an individual or company. The next day, on Sept. 11, 2012, he emailed the undercover

agent with several suggestions for names. “So which name do you like?” he wrote.

The agent responded with the name of a fictitious group, “United Pacific Independent Producers of

California.”

In its account, the FBI says that Calderon took the bait. The senator wrote and mailed the letter of support

to the FBI undercover agents, addressed to a group that didn’t exist and whose name a federal agent

simply made up.

A special fund: $50,000

The affidavit describes how Calderon’s cash-for-favors relationship with the undercover agent continued

even after the movie tax credit legislation stalled. Over dinner on Oct. 16, 2012, the undercover agent

asked if Calderon could hire his girlfriend, the aspiring model who was also an undercover federal agent, for

a state job in Sacramento. Trouble was, the undercover agent admitted, his girlfriend didn’t have any skills

or relevant experience for legislative work. The affidavit lays out the following exchange:

“She comes with, you know, issues,” the undercover agent said.

“Yeah,” Calderon said.

“It is not a big thing,” the agent said. “But if you are willing to take that on —”

“Every girl has issues,” Calderon interrupted.

The agent told Calderon he’d make hiring his girlfriend worthwhile. He explained that he had padded his

movie budgets to give him an extra $50,000 to play with — cash he could make available to a helpful

senator.

“Oh, nice,” Calderon said.


The agent and Calderon began to refer to the $50,000 as a “special fund.” On Nov. 2, 2012, Calderon

asked the agent to pay $5,000 to Berklee College of Music in Boston for tuition for his son, Zachary.

“Maybe we can get a $5,000 check to Berklee College of Music and Zach just turns it in,” he said.

The agent agreed to pay the tuition, but said $5,000 would make only a small dent in the $50,000 special

fund. According to the affidavit, Calderon said they could deposit the rest into other accounts, including

Californians for Diversity, a nonprofit organization controlled by Thomas Calderon.

In September, Californians for Diversity, a nonprofit run by

Thomas Calderon, hosted a fundraiser at Pebble Beach

Resorts. Major supporters included Walmart Stores, the

Clorox Co., Shell Oil Co. and Farmers Insurance. Al Jazeera's

Investigative Unit

Ronald and Thomas Calderon used the nonprofit as a

slush fund, the FBI alleges:

“We have this nonprofit. It is called Californians for

Diversity,” Ronald Calderon told the agent. “So, we are

gonna build this thing up and … then, Tom and I down

the road, we build that up, we can pay ourselves. Just

kind of make, you know, part of a living.”

Calderon hired the undercover agent’s girlfriend as a

member of his Senate staff, despite not having an open

position. The hiring required the approval of Senate

President Pro Tem Darrell Steinberg. The Senate leader

declined to comment in a brief interview with Al Jazeera

other than to say, “Let the investigation run its course.’’

The cash and gifts kept flowing, but Calderon failed to

report them on his state ethics disclosure forms, state

records show.

In late October, for example, the undercover agent

reserved a table for Calderon at The Bank, a nightclub

inside the Bellagio in Las Vegas. Calderon and a friend

went to the nightclub and, according to the affidavit,

racked up a $3,939.56 bill at the agent’s expense.

Calderon took a photograph of himself with rappers Nelly and T.I. and emailed it to the agent.

Two months later, the undercover agent purchased a $5,000 ticket for Calderon to attend a fundraiser for

state Sen. Kevin de Leon, who represents a Los Angeles district. The event was held during a Manny

Pacquiao fight in Las Vegas.

More money and perks flowed from the undercover agent, including a $25,000 payment to Californians for

Diversity and $3,200 for Calderon to fly to Miami and meet with the undercover agent and his supposed

investor. Calderon advised the investor — who was also an undercover agent — that he should hire his

brother Thomas as a consultant. The investor then asked if Calderon still supported the tax credit

legislation. “Absolutely,” he said, according to the court document. “You have my support even if you don’t

hire Tom.”


The next day, Calderon called the investor. There was a problem. His plan of having the movie studio pay

$10,000 per month to Californians for Diversity wouldn’t work, he said. State Sen. Ricardo Lara, chair of the

Latino caucus, was taking greater control of nonprofits associated with the caucus.

“Californians for Diversity is tied into the Latino Caucus in terms that it’s being sanctioned by them, and

that’s why I’m able to raise the money for the purpose of promoting numbers in the caucus,” Calderon said,

according to the affidavit. “So the bylaw was changed that he’s (Sen. Lara) got authority on any consultants

that are hired that are paid over $5,000 a month.”

“Wait, who has authority? Tom or you?” the agent asked.

“No, the chair of the caucus. In other words, he has to authorize anything over $5,000. So right now, Tom is

already getting $5,000 a month from the caucus, from our committee. For us to add to that — number one,

it’s going to bring too much attention to us in what we’re doing and right now we’re in fundraising mode. And

number two, then I have to go and get permission from the chair to get more, and I don’t want to do that.”

The good life: Pebble Beach

Calderon’s relationship with the generous movie producer came to an abrupt end in early June when FBI

agents raided his Capitol offices in Sacramento. Soon after, he set up a legal defense fund and issued a

brief statement to reporters.

“My family and I have gone through a lot the last several days,” he said. “It’s been very stressful, very hard

on all of us. We’re all anxious to put this behind us and carry on a normal life.”

In Miami, the FBI says, the undercover agents agreed to pay $10,000 per month — $3,000 purportedly for

Jessica, $5,000 for Thomas and the additional $2,000 to cover taxes Thomas would have to pay on the

income. The investor drove Ronald Calderon to Miami International Airport and handed the senator a white

envelope containing $3,000 in cash. Future payments, Calderon said, should go to Californians for

Diversity.

RELATED STORIES

Members of the Calderon political dynasty (/articles/2013/10/30/members-ofthecalderonpoliticaldynasty.html)•

The Calderon Dynasty: 30 years of political power (/articles/2013/10/30/the-

calderondynasty30yearsofpoliticalpower.html)

•

Despite their troubles, the Calderon money machine continues running on high octane. In September, the

senator attended a two-day fundraising event at Pebble Beach Resorts for Californians for Diversity, the

nonprofit run by his brother Thomas. Major supporters included Walmart Stores, the Clorox Co., Shell Oil

Co., Farmers Insurance and Edelstein Gilbert, a prominent California lobbying firm. Calderon golfed with

industry lobbyists and then shared fireside drinks with them in the cool evening hours.

A few days later, Al Jazeera’s Investigative Unit caught up with him at a luxury golf resort in Orange County.


http://america.aljazeera.com/articles/2013/10/30/members-ofthecalderonpoliticaldynasty.html

http://america.aljazeera.com/articles/2013/10/30/the-calderondynasty30yearsofpoliticalpower.html

State Sen. Ronald Calderon, attending the Californians for

Diversity event in September, enjoys a cigar during an

evening party. Al Jazeera's Investigative Unit

The conversation was abrupt.

Asked about the FBI investigation as he lifted clubs from

the trunk of his Cadillac, Calderon said: “I’m not really

going to discuss any of that.”

He then walked into the pro shop, refusing to answer

additional questions.

Al Jazeera Investigative Unit

2K 2K 7

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RSS (http://comments.us1.gigya.com/comments/rss/6311261/ajam/dcdb5d5d-06ed-4320-9928-b6149a3256a31383153477938) | Subscribe

Michael Boyd 2 days ago

0

MJRydsFast 4 days ago

JOIN THE CONVERSATION

Post a new comment

Shocking!

"Calderon did not realize that the friendly movie executive was an FBI undercover agent." The oxymoron should

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http://comments.us1.gigya.com/comments/rss/6311261/ajam/dcdb5d5d-06ed-4320-9928-b6149a3256a31383153477938

0

Richard Rider 5 days ago

0

Robert DeAlmeida 5 days ago

0

Robert DeAlmeida 5 days ago

0

Almee_eq2 5 days ago

+3

Delbert Lammers 5 days ago

1 reply 0

allison_salnews 5 days ago

have made it obvious- "friendly"? "Movie executive"? In the same breath? Hmmm.... I believe I hear David Geffen

laughing now.

Over the last 40 years, two trends have become apparent in California politicians' criminal corruption cases.

1. The cases USUALLY involve Democrats. But not always.

2. A more consistent trend is for the culprits to be political veterans. In the state legislature, I don't think anyone

charged with crimes since 1970 (and there have been quite a number) had less than 8 years seniority in the

legislature (we instituted generous term limits in the 1990's, I believe).

In my 35+ years dealing with politicians at every level of government, I must say that this seniority correlation

seems to be universal. It's a telling case for term limits.

POLITICAL CORRUPTION, CALDERON STYLE

Itemize the items on the $3,900 dinner in Las Vegas so that us dumb taxpayers can understand how he could

spend that much money for two people in one night. Help me understand.

We have the best government money can buy in America.

I live in Northern, California (Santa Clara County) where the Calderon Brothers own a chain of tire stores that

launder millions of dollars of illegal drug money every year...

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Chenille Matillisse 5 days ago

+1

Roy Rutherford 5 days ago

1 reply +6

Lenny Sita 5 days ago

+1

realBKW 5 days ago

+1

Angela Kolios 5 days ago

What proof can you offer?

http://www.veteranstoday.com/2013/10/29/the-playing-field-is-clear-part-1/

Even more extraordinary was the behavior of the FBI, which (contrary to legal procedure) confiscated evidence that

had been kept by Seal in the trunk of his Cadillac. That evidence consisted of tapes of Seal talking with his han-

dlers, who apparently included elements of the CIA and then Vice-President George Bush. When one of Seal’s

attorneys prodded Seal for more information about whom he was working for, Seal handed him the phone and

told him to call a number that he gave to his counsel. When Unglesby (the lawyer) called the number, he got Vice-

President Bush’s office. When Seal attempted to prevail on Bush to intervene on his behalf with the IRS, Seal was

murdered. Much of the program deals with Seal’s history in the world of covert operations

Sure, that's a great story, well done, important, informative and thorough but.. if you want to learn how to make a

hat out of soybeans or a delicious yogurt desert, there is still CNN :)

@Roy, Good one! I'm still laughing!

How ironic that he sets up a "defense fund" for donations to cover his legal fees. His defense team better make

sure they get paid upfront, with CLEAN money! Politicians like this are scum and the bane of democracies

everywhere. Yet stupid voters keep electing them. I guarantee the Calderon dynasty will continue. Just keep them

in state, please. No national office for them.

I used to live in L.A. I attended Los Angeles High school and was a member of Saint Sophia Greek Orthodox

church on Pico and Normandie. My mother had a duplex on Beachwood and Melrose across from Desilu studios.

That was a very long time ago. I went back only once in 1983 and was so scared walking on Hollywood blvd I

never went back. Nothing surprises me about California politics they were corrupt then as they are now. could not

get a teaching job in LA. district unless you knew a politician. That's why I left.

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Lawrence Dickerson 5 days ago

+1

Michael Boyd 5 days ago

1 reply +1


0

Rafe Husain 5 days ago

0

Richard Columbare 5 days ago

2 replies +1


1 reply 0

Keep up the good work.This is a start and I can only hope that all of the elected officials will take notice and

abandon their quest for personal riches over representing their constituents.I too would like to see these types of

investigations pointed at the very heart of the US government.That's a tough cookies to crumble but I can still

dream per chance.

This is a start. A start comparing the size of a snow cone to an iceberg the size of Greenland.

True, but still a start.

great breaking story

O.K. so you have caught up to just one of our corrupt politicians. Now the justice system has to follow through by

taking away through fines most of his money and most importantly giving him a very long prison sentence and not

in some minimum security prison. Do not do one without the other. Perhaps in America we are not allowed to

give them the death penalty but I do not want them to get a fine and a slap on the wrist . Instead I would like a

strong signal given to the rest of the corruptibles do not do likewise or the same will happen to you!

I agree, a fine, and a slap on the wrist would send a clear signal to most Americans that the whole thing

was just for show. There should be five or six hundred of these guys shackled up doing the perp walk into

a federal court house! Now that would be a good start!

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mksiddiki 5 days ago

+1

Quake Lollerama 5 days ago

+2

Vincent Finelli 5 days ago

+2

Dean Borchert 5 days ago

+4

Stephen Laudig 5 days ago

+4

J.E. King 6 days ago

I'd like to see the real culprits behind "this show." He's probably just a fall guy or he angered

someone much more powerful than him. But we'll never know who the big fish truly are.

Like the report. He is a very small fish, catch the big fishes.

Now write one on the Clinton's, I dare you.

Great article and reporting on political abuse. Keep following through and pressing politicians to be held to a

higher standard. No other major new source is covering this very important issue.

The truly sad part is that this is just ONE politician.

His defense is that he believes it is "not a criminal act" and it is "just normal business practice".

In one sense, he is correct. It IS a normal business practice (among politicians). They have been doing it so long

that they truly believe it is "OK". Everyone else operates that way.

In some ways the Chinese criminal justice system, which allows for, and, indeed, imposes executions as a

penalty for corruption is admirable. Execution for public corruption, what's a few dead politicians, more or less?

Have thought I was following this on LATimes. Clearly you do have the details that haven't yet hit the fan. This is

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+1

Jan gil 6 days ago

3 replies +1

Ali Chami 5 days ago

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Amy Anderson 5 days ago

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+1

Jon York 6 days ago

+2

so sickening, right after the Bell-Robert Rizzo scandal. We don't have enough FBI to conduct stings against all the

bad politicians out there, or even enough honest people in power to do their own true job as public servants.

Thanks for this scoop, I'll be back here for my local news now too.

I would be more impressed with the subject of this article, but the reality is, the Latino political faction is not

known for its members money. However, they are known for their numbers. The Calderons are not that big of

political fishes

It's not that I condone any of their illegal activities, it's just that I know there are bigger, more powerful political fish

out there..

Like Jane Harman conspiring with Haim Saban ?

Maybe this guy is just one more out of the way before they get to the biggies.

One of those big fish is California Senator Diane Feinstein from San Francisco. Who for many years now

has head the committee in Washington that hands out lucrative military contracts, while her husband is

one of those military contractors. This conflict of interest between them, has made them extremely

wealthy.

In this story the FBI is doing the same thing as what they call "lobbying" in Washington

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ron calderon asks for contempt in fbi affidavit leak

Documents

notice of motion

united states government

introduction senator

party senator ronald

authorities request

senator kevin

sanctions case

tbd time