[House Report 107-454]
[From the U.S. Government Printing Office]



                                                 Union Calendar No. 269
107th Congress                                                   Report
                        HOUSE OF REPRESENTATIVES
 2d Session                                                     107-454
_______________________________________________________________________


 
     JUSTICE UNDONE: CLEMENCY DECISIONS IN THE CLINTON WHITE HOUSE

                               __________

                             SECOND REPORT

                                 by the

                     COMMITTEE ON GOVERNMENT REFORM

                             Volume 1 of 3

                             together with

                     MINORITY AND ADDITIONAL VIEWS

Chapter 1--``Take Jack's Word'': The Pardons of International Fugitives 
                       Marc Rich and Pincus Green
   Chapter 2--Roger Clinton's Involvement in Lobbying for Grants of 
                           Executive Clemency

                                     


                                     

  Available via the World Wide Web: http://www.gpo.gov/congress/house
                      http://www.house.gov/reform

  May 14, 2002.--Committed to the Committee of the Whole House on the 
              State of the Union and ordered to be printed

                               __________

                    U.S. GOVERNMENT PRINTING OFFICE
78-264                     WASHINGTON : 2002


                     COMMITTEE ON GOVERNMENT REFORM

                     DAN BURTON, Indiana, Chairman
BENJAMIN A. GILMAN, New York         HENRY A. WAXMAN, California
CONSTANCE A. MORELLA, Maryland       TOM LANTOS, California
CHRISTOPHER SHAYS, Connecticut       MAJOR R. OWENS, New York
ILEANA ROS-LEHTINEN, Florida         EDOLPHUS TOWNS, New York
JOHN M. McHUGH, New York             PAUL E. KANJORSKI, Pennsylvania
STEPHEN HORN, California             PATSY T. MINK, Hawaii
JOHN L. MICA, Florida                CAROLYN B. MALONEY, New York
THOMAS M. DAVIS, Virginia            ELEANOR HOLMES NORTON, Washington, 
MARK E. SOUDER, Indiana                  DC
STEVEN C. LaTOURETTE, Ohio           ELIJAH E. CUMMINGS, Maryland
BOB BARR, Georgia                    DENNIS J. KUCINICH, Ohio
DAN MILLER, Florida                  ROD R. BLAGOJEVICH, Illinois
DOUG OSE, California                 DANNY K. DAVIS, Illinois
RON LEWIS, Kentucky                  JOHN F. TIERNEY, Massachusetts
JO ANN DAVIS, Virginia               JIM TURNER, Texas
TODD RUSSELL PLATTS, Pennsylvania    THOMAS H. ALLEN, Maine
DAVE WELDON, Florida                 JANICE D. SCHAKOWSKY, Illinois
CHRIS CANNON, Utah                   WM. LACY CLAY, Missouri
ADAM H. PUTNAM, Florida              DIANE E. WATSON, California
C.L. ``BUTCH'' OTTER, Idaho          STEPHEN F. LYNCH, Massachusetts
EDWARD L. SCHROCK, Virginia                      ------
JOHN J. DUNCAN, Tennessee            BERNARD SANDERS, Vermont 
------ ------                            (Independent)


                      Kevin Binger, Staff Director
                 Daniel R. Moll, Deputy Staff Director
                     James C. Wilson, Chief Counsel
                     Robert A. Briggs, Chief Clerk
                 Phil Schiliro, Minority Staff Director

                  David A. Kass, Deputy Chief Counsel
                     M. Scott Billingsley, Counsel
                       Pablo E. Carrillo, Counsel
                        Jason A. Foster, Counsel
                        Hilary J. Funk, Counsel
                        Matthew J. Rupp, Counsel

                  Phil Barnett, Minority Chief Counsel
             Michael Yeager, Minority Deputy Chief Counsel
                     Michael Yang, Minority Counsel
?

                         LETTER OF TRANSMITTAL

                              ----------                              

                                  House of Representatives,
                                      Washington, DC, May 14, 2001.
Hon. J. Dennis Hastert,
Speaker of the House of Representatives,
Washington, DC.
    Dear Mr. Speaker: By direction of the Committee on 
Government Reform, I submit herewith the committee's second 
report to the 107th Congress. The committee's report is based 
on a study conducted by the full committee.
                                                Dan Burton,
                                                          Chairman.


                                     


                               DEDICATION

                              ----------                              

    This report is dedicated to the memory of M. Scott 
Billingsley, counsel for the House Committee on Government 
Reform from 1999-2001. Scott died unexpectedly on March 25, 
2002, at the age of 31.
    During his time on the Committee staff, Scott was centrally 
involved in a number of important investigations. Scott made 
immeasurable contributions to the Committee's work, not only 
through his critical thinking and excellent writing, but also 
through his professionalism and cheerful spirit, which made him 
a pleasure to work with.
    Scott devoted two years of his short life to the Committee 
on Government Reform because he wanted to root out waste, 
fraud, and abuse, and promote integrity in the federal 
government. Scott's final, and most important work for the 
Committee was on the investigation of President Clinton's 
eleventh-hour clemency grants. Scott played a key role 
investigating the pardons of Marc Rich and Pincus Green and 
drafted much of the first chapter of this report. Scott's work 
on the Rich and Green pardons was typical of all of his work 
for the Committee: excellent, accurate, and thorough.
    Scott Billingsley certainly has a legacy that goes far 
beyond his work on this Committee. He has left behind many 
individuals who will miss him dearly. His memory will be 
cherished by his parents, sister, fiance, family, and countless 
others whose lives he touched. However, this report should 
serve as a small, but lasting, reminder of Scott Billingsley's 
work and his devotion to the pursuit of truth.


                                     
                            C O N T E N T S

                              ----------                              
                                                                   Page

                                Volume 1

EXECUTIVE SUMMARY................................................     1
INTRODUCTION.....................................................    25

    Chapter One--``Take Jack's Word'': The Pardons of International 
                  Fugitives Marc Rich and Pincus Green

FINDINGS OF THE COMMITTEE........................................    99
INTRODUCTION.....................................................   105
 I. BACKGROUND OF MARC RICH AND PINCUS GREEN........................107
    A. Rich and Green's Business Activities......................   107
        1. How Rich and Green Became Wealthy.....................   107
        2. Marc Rich's History of Illegal and Improper Business 
            Dealings.............................................   108
            a. Iran..............................................   110
            b. South Africa......................................   110
            c. The Soviet Union/Russia...........................   111
            d. Cuba..............................................   113
            e. Libya.............................................   113
            f. Iraq..............................................   113
            g. Angola............................................   114
            h. Romania...........................................   114
            i. Serbia............................................   115
    B. The Criminal Charges Against Marc Rich and Pincus Green...   115
        1. The Investigation of Rich and Green...................   115
        2. The Indictment........................................   120
        3. Rich and Green Flee the Country.......................   121
        4. The Corporate Guilty Pleas............................   122
    C. Attempts to Bring Rich and Green to Justice...............   123
        1. Attempts to Extradite Rich and Green..................   123
        2. Marc Rich and Pincus Green's Attempts to Renounce 
            Their Citizenship....................................   123
        3. U.S. Attempts to Apprehend Rich and Green.............   125
        4. 1992 Congressional Hearings...........................   127
        5. Actions Taken by the U.S. Against Rich's Business 
            Interests............................................   128
            a. U.S. Mint Contract Cancellation...................   128
            b. Suspension of Rich's Grain Dealings...............   129
            c. Cuban Asset Forfeiture............................   130
II. ATTEMPTS TO SETTLE THE MARC RICH AND PINCUS GREEN CASE..........131
    A. Attempts to Settle in the 1980s...........................   131
    B. Marc Rich's Humanitarian Activities in the 1980s and 1990s   133
    C. Rich Hires Jack Quinn.....................................   135
    D. Quinn's Fee Arrangements..................................   137
        1. Was Quinn Expecting Payment for His Work on the 
            Pardon?..............................................   137
        2. Has Quinn Received Payments from Marc Rich Since the 
            Pardon Was Granted?..................................   141
    E. Quinn's Attempts to Settle the Case.......................   145
III.THE MARC RICH AND PINCUS GREEN PARDON PETITION..................149

    A. Rich Contemplated a Pardon Early in 2000..................   149
    B. The Preparation of the Pardon Petition....................   154
    C. The Misleading Legal Arguments in the Petition............   156
        1. The Indictment of Rich Was Not Flawed.................   156
            a. The Department of Energy Regulations Were Fair....   156
            b. Rich and Green Were Not Singled Out...............   157
            c. Rich and Green Did Trade with the Enemy...........   159
            d. Rich and Green Did Evade Federal Taxes............   160
        2. The Prosecutors Were Not ``Overzealous''..............   162
            a. The Prosecutors Negotiated with Rich and Green....   162
            b. The Rich Prosecution Was Not Tainted with Media 
                Attention........................................   164
            c. RICO Charges Were Fairly Brought..................   165
    D. The ``Letters of Support'' in the Petition................   167
        1. Rich Paid a Number of Individuals Who Wrote in His 
            Support..............................................   167
        2. Some Who Wrote Letters Were Misled About the Purpose..   170
        3. Many of the Letters Were Misrepresented to the 
            President............................................   171
IV. LOBBYING FOR THE MARC RICH PARDON...............................173
    A. The Marc Rich Lobbying Team...............................   173
        1. Denise Rich...........................................   173
            a. Denise Rich's Relationship with Marc Rich.........   173
            b. Denise Rich's Relationship with President Clinton.   175
            c. Denise Rich's Role in the Marc Rich Pardon Effort.   176
            d. Denise Rich's Motives.............................   180
        2. Beth Dozoretz.........................................   182
            a. Beth Dozoretz's Relationship with Bill Clinton....   182
            b. Beth Dozoretz's Involvement in the Marc Rich 
                Pardon Campaign..................................   184
            c. Jack Quinn's Attempt to Keep Information About 
                Dozoretz from the Committee......................   187
        3. Israeli Prime Minister Ehud Barak and Other Israeli 
            Leaders..............................................   188
        4. Elie Wiesel...........................................   192
        5. King Juan Carlos......................................   195
        6. Avner Azulay..........................................   196
        7. Michael Steinhardt....................................   196
        8. Gershon Kekst.........................................   197
        9. Robert Fink...........................................   206
        10. Kathleen Behan.......................................   206
        11. Peter Kadzik.........................................   206
    B. Importance of Secrecy to the Marc Rich Team...............   207
    C. Jack Quinn and Eric Holder Cut the Justice Department Out 
        of the Process...........................................   208
    D. The Filing of the Pardon Petition.........................   214
        1. December 11, 2000, Call from Ehud Barak...............   215
        2. Quinn Was Likely Legally Prohibited from Lobbying the 
            White House..........................................   216
    E. The Lobbying Effort.......................................   218
        1. Quinn's Contacts with Bruce Lindsey in Belfast........   219
        2. Peter Kadzik's Lobbying Contacts with John Podesta....   220
        3. Further Contacts Between Jack Quinn and White House 
            Staff................................................   223
        4. Initial Discussions Between the White House and 
            Justice Department...................................   225
        5. January 8, 2001, Call Between President Clinton and 
            Ehud Barak...........................................   226
        6. ``The HRC Option''....................................   227
    F. The Final Days of the Marc Rich Lobbying Effort...........   230
        1. Communications Between Peter Kadzik and John Podesta..   230
        2. The January 16, 2001, White House Meeting Regarding 
            Rich.................................................   231
        3. The Justice Department Receives Jack Quinn's January 
            10 Letter............................................   233
        4. Final Lobbying Contacts Leading up to January 19, 2001   233
            a. Jack Quinn's January 18, 2001, Letter to the 
                President........................................   235
            b. Bruce Lindsey's Contacts with SEC Chairman Arthur 
                Levitt...........................................   236
    G. January 19-20, 2001.......................................   238
        1. The Call Between Prime Minister Barak and President 
            Clinton..............................................   238
        2. Eric Holder Weighs In.................................   240
        3. The January 19 Meeting Between White House Staff and 
            President Clinton....................................   245
        4. The President's Call to Jack Quinn....................   247
        5. The White House Informs the Justice Department of the 
            Decision.............................................   250
    H. Aftermath of the Rich and Green Pardons...................   254
        1. Eric Holder's Congratulatory Remarks..................   254
        2. The Rich Team's Effort to Deal with the Press.........   255
        3. President Clinton's Column in The New York Times......   258
 V. FAILURE OF KEY PARTIES TO COOPERATE IN THE MARC RICH AND PINCUS 
    GREEN INVESTIGATION.............................................262
    A. Marc Rich.................................................   262
    B. Pincus Green..............................................   263
    C. Jack Quinn................................................   263
    D. Denise Rich...............................................   264
    E. Beth Dozoretz.............................................   264
    F. Avner Azulay..............................................   265
    G. Peter Kadzik..............................................   265
    H. Terry McAuliffe...........................................   266

  Chapter Two--Roger Clinton's Involvement in Lobbying For Executive 
                                Clemency

FINDINGS OF THE COMMITTEE........................................   709
INTRODUCTION.....................................................   715
 I. ROGER CLINTON'S PATTERN OF TRADING ON HIS BROTHER'S NAME........717
    A. Roger Clinton's Foreign Travelers Checks and Other 
        Questionable Sources of Income...........................   719
    B. Roger Clinton's Lobbying Regarding Cuban Travel 
        Restrictions.............................................   723
    C. The Shakedown of John Katopodis...........................   725
II. THE GAMBINO PAROLE AND PARDON EFFORTS...........................731
    A. Rosario Gambino's Involvement with Organized Crime........   731
    B. The U.S. Parole Commission's Handling of Rosario Gambino's 
        Case.....................................................   735
    C. Roger Clinton's Involvement with the Gambino Family.......   739
        1. Clinton's Contacts with the Parole Commission.........   743
            a. Clinton's Initial Approach to the Parole 
                Commission.......................................   743
            b. Clinton's Meetings with Parole Commission Staff...   747
                i. December 1997 Meeting.........................   747
                ii. Spring 1998 Contacts.........................   751
                iii. July 1998 Meeting...........................   753
        2. The FBI Investigation of Clinton's Contacts with the 
            Parole Commission....................................   753
            a. Clinton's Continued Attempts to Contact the 
                Commission.......................................   755
            b. The FBI's Request to Have an Agent Pose Undercover   758
            c. The FBI's Recording of Clinton's Conversations 
                with Thomas Kowalski.............................   760
        3. Roger Clinton's Apparent Attempt to Involve the White 
            House in the Parole Decision.........................   764
    D. Roger Clinton's Financial Relationship with the Gambinos..   765
    E. The FBI's Interview of Roger Clinton......................   766
        1. Roger Clinton's Statements Regarding His Brother's 
            Knowledge............................................   767
        2. Roger Clinton's Statements Regarding Payment from the 
            Gambinos.............................................   768
        3. Roger Clinton's Statements Regarding the Rolex Watch..   771
    F. The Efforts to Obtain Executive Clemency for Rosario 
        Gambino..................................................   773
III.THE LINCECUM PARDON OFFER.......................................777

    A. Garland Lincecum's Account................................   778
        1. The Initial $35,000 Payment...........................   778
        2. The First Dallas Meeting..............................   779
        3. Lincecum's Attempts to Raise the Remaining Money......   782
        4. Lincecum's Payment of $200,000........................   785
        5. The Division of Lincecum's Money Among Clinton, Locke, 
            and Morton...........................................   786
        6. Lincecum's Attempts to Receive the Pardon.............   787
    B. Roger Clinton's Reaction to the Allegations...............   790
    C. Dickey Morton's and George Locke's Reactions to the 
        Allegations..............................................   792
    D. Analysis..................................................   795
IV. OTHER PARDON CANDIDATES.........................................799
    A. Dan Lasater and George Locke..............................   799
    B. J.T. Lundy................................................   802
    C. Blume Loe.................................................   807
    D. Rita Lavelle..............................................   809
    E. John Ballis...............................................   811
    F. Stephen Griggs............................................   815
    G. Phillip Young.............................................   819
    H. Joseph ``Jay'' McKernan...................................   822
    I. Mitchell Wood.............................................   823
    J. Mark St. Pe...............................................   825
    K. William D. McCord.........................................   826
 V. FAILURE OF KEY PARTIES TO COOPERATE IN THE ROGER CLINTON 
    INVESTIGATION...................................................827
    A. Roger Clinton.............................................   827
    B. Tommaso Gambino...........................................   828
    C. Lisa Gambino..............................................   828
    D. Victor Crawford and Kathy Vieth...........................   828
    E. George Locke..............................................   829
    F. Dickey Morton.............................................   829
    G. Richard Cayce.............................................   829
    H. J.T. Lundy................................................   829
    I. Robert Lundy..............................................   829
    J. Chief Carl Griggs.........................................   830
    K. Blume Loe and Cynthia Goosen..............................   830
    L. Bruce Lindsey.............................................   830
    M. Meridith Cabe.............................................   830
    N. Department of Justice.....................................   831
    O. The White House...........................................   831

                                Volume 2
 Chapter Three--Hugh Rodham's Role in Lobbying for Grants of Executive 
                                Clemency

FINDINGS OF THE COMMITTEE........................................  1261
INTRODUCTION.....................................................  1267
 I. THE CARLOS VIGNALI COMMUTATION.................................1267
    A. The Case Against Carlos Vignali...........................  1267
    B. Vignali's Efforts to Obtain Executive Clemency............  1276
        1. Initial Efforts to Reduce Vignali's Sentence..........  1276
            a. Contacts with Prosecutors in Minnesota............  1276
            b. Vignali's Appeal..................................  1277
            c. Letters to the White House and Justice Department.  1277
        2. Vignali's Clemency Petition...........................  1280
        3. Supporters of Vignali's Clemency Petition.............  1283
            a. Letters of Support from Prominent California 
                Politicians......................................  1284
                i. Congressman Xavier Becerra....................  1284
                ii. Congressman Esteban Torres...................  1286
                iii. State Senator Richard Polanco...............  1286
                iv. Los Angeles County Supervisor Gloria Molina..  1287
                v. Los Angeles City Councilmember Mike Hernandez.  1288
                vi. Cardinal Roger Mahony........................  1289
            b. Support from Los Angeles County Sheriff Lee Baca..  1290
                i. Sheriff Baca's Relationship with the Vignalis.  1290
                ii. Sheriff Baca's Involvement in the Vignali 
                    Clemency Effort..............................  1292
                iii. Conclusion..................................  1293
            c. Support from U.S. Attorney Alejandro Mayorkas.....  1295
                i. Mayorkas' Initial Exposure to the Vignali 
                    Matter.......................................  1296
                ii. Mayorkas Calls the White House...............  1297
                iii. Conclusion..................................  1299
        4. California Law Enforcement and Political Officials 
            Supported Vignali's Clemency Petition Despite Serious 
            Allegations Against Horacio and Carlos Vignali.......  1301
            a. There Were Extensive Allegations of Drug 
                Trafficking Against Both Horacio and Carlos 
                Vignali..........................................  1301
            b. The Extensive Allegations Against Horacio and 
                Carlos Vignali Were Never Considered by Sheriff 
                Baca, U.S. Attorney Mayorkas, or the Clinton 
                White House......................................  1304
    C. The White House's Review of the Vignali Clemency Request..  1307
        1. Hugh Rodham's Hiring..................................  1307
        2. Hugh Rodham's Initial Approach to the White House.....  1309
        3. The Justice Department's Input on the Vignali Case....  1311
        4. The Final Decision on the Vignali Commutation.........  1314
            a. Contacts Between the White House and Interested 
                Parties..........................................  1314
            b. Contacts Between the White House and Hugh Rodham..  1317
            c. Hugh Rodham's Invocation of First Lady Hillary 
                Clinton..........................................  1318
            d. The President's Decision to Grant the Commutation.  1319
        5. The White House Has No Justification for the Vignali 
            Commutation..........................................  1320
    D. The Aftermath of the Vignali Commutation..................  1324
        1. The Response of Hugh Rodham...........................  1324
        2. The Florida Bar's ``Investigation'' of Hugh Rodham....  1325
        3. The Message Sent by the Vignali Commutation...........  1327
II. THE PARDON OF A. GLENN BRASWELL................................1328
    A. Braswell's History of Misconduct..........................  1329
    B. Consideration of the Braswell Pardon by the Clinton White 
        House....................................................  1332
III.HUGH RODHAM'S EFFORTS TO OBTAIN CLEMENCY FOR THE LUMS..........1336

    A. Background on Gene and Nora Lum...........................  1336
    B. Hugh Rodham Approaches the White House About the 
        Possibility of a Pardon for the Lums.....................  1337
IV. FAILURE OF KEY PARTIES TO COOPERATE IN THE HUGH RODHAM 
    INVESTIGATION..................................................1339
    A. Hugh Rodham...............................................  1339
    B. Horacio and Carlos Vignali................................  1340
    C. James Casso...............................................  1340
    D. Glenn Braswell............................................  1341
    E. Kendall Coffey............................................  1341
    F. Gene and Nora Lum.........................................  1341
    G. Nicole Lum................................................  1341

 Chapter Four--Tony Rodham's Role in Lobbying for Grants of Executive 
                                Clemency

FINDINGS OF THE COMMITTEE........................................  1589
INTRODUCTION.....................................................  1590
 I. EDGAR AND VONNA JO GREGORY.....................................1591
    A. Background................................................  1591
    B. Tony Rodham's Relationship with the Gregorys..............  1592
    C. Tony Rodham's Efforts to Help the Gregorys Obtain Pardons.  1595
    D. Deliberations by the Administration.......................  1598
    E. Conclusion................................................  1600
II. FERNANDO FUENTES COBA..........................................1602
    A. Background on Fernando Fuentes Coba.......................  1602
    B. The Pardon Attorney Refuses to Process Fuentes' Clemency 
        Petition.................................................  1604
    C. Tony Rodham's Attempt to Become Involved in the Fuentes' 
        Clemency Effort..........................................  1605
    D. Tony Rodham's Representations to Mannerud Were Fraudulent.  1608

  Chapter Five--The Grant of Clemency to Drug Money Launderer Harvey 
                                 Weinig

FINDINGS OF THE COMMITTEE........................................  1709
 I. BACKGROUND.....................................................1712
    A. Weinig and His Co-Conspirators............................  1712
    B. The Money Laundering Operation............................  1713
    C. Weinig and His Co-Conspirators Run Afoul of the Colombian 
        Cocaine Cartel...........................................  1714
    D. Weinig's Prosecution and Sentencing.......................  1718
II. WEINIG'S EFFORTS TO OBTAIN EXECUTIVE CLEMENCY..................1722
    A. Weinig Hires Reid Weingarten to Lobby for Clemency........  1722
    B. Weinig's Wife Seeks Support for His Clemency Petition.....  1725
    C. Weinig's Wife Obtains Support from Individuals with Ties 
        to the Administration....................................  1726
III.THE WHITE HOUSE'S REVIEW OF WEINIG'S COMMUTATION REQUEST.......1729

    A. The Justice Department's Input in the Weinig Clemency 
        Matter...................................................  1729
        1. The U.S. Attorney Strongly Objected to Commuting 
            Weinig's Sentence....................................  1729
        2. The Pardon Attorney Objected to Commuting Weinig's 
            Sentence.............................................  1730
    B. The White House's Deliberations...........................  1732
    C. The White House Had No Justification for the Weinig 
        Commutation..............................................  1733
    D. Aftermath of the Weinig Commutation.......................  1736

                                Volume 3
                               Appendices

Appendix I.--Committee correspondence............................  2079
Appendix II.--Committee subpoenas................................  2577
Appendix III.--Marc Rich and Pincus Green pardon petition........  2967

                                 Views

Minority views of Hon. Henry A. Waxman, Hon. Tom Lantos, Hon. 
  Major R. Owens, Hon. Edolphus Towns, Hon. Paul E. Kanjorski, 
  Hon. Patsy T. Mink, Hon. Bernard Sanders, Hon. Eleanor Holmes 
  Norton, Hon. Elijah E. Cummings, Hon. Dennis J. Kucinich, Hon. 
  Danny K. Davis, Hon. Thomas H. Allen, Hon. Janice D. 
  Schakowsky, and Hon. Diane E. Watson...........................  3292
Additional views of Hon. Dan Burton..............................  3389

                                                 Union Calendar No. 269
107th Congress                                                   Report
                        HOUSE OF REPRESENTATIVES
 2d Session                                                     107-454

======================================================================


     JUSTICE UNDONE: CLEMENCY DECISIONS IN THE CLINTON WHITE HOUSE

                                _______
                                

  May 14, 2002.--Committed to the Committee of the Whole House on the 
              State of the Union and ordered to be printed

                                _______
                                

   Mr. Burton, from the Committee on Government Reform submitted the 
                               following

                             SECOND REPORT

    On March 14, 2002, the Committee on Government Reform 
approved and adopted a report entitled ``Justice Undone: 
Clemency Decisions in the Clinton White House.'' The chairman 
was directed to transmit a copy to the Speaker of the House.

                           EXECUTIVE SUMMARY

THE PARDONS OF MARC RICH AND PINCUS GREEN

Marc Rich and Pincus Green have a history of illegal and 
corrupt business dealings contrary to the security interests of 
the United States.

 Rich and Green have had extensive trade with 
terrorist states and other enemies of the United States. 
Despite clear legal restrictions on such trade, Rich and Green 
have engaged in commodities trading with Iraq, Iran, Cuba, and 
other rogue states which have sponsored terrorist acts. By 
engaging in these activities, Marc Rich and Pincus Green 
demonstrated contempt for American laws, as well as the well-
being of Americans who were harmed or threatened by these 
states.

 The Central Intelligence Agency provided the 
following declassified information about Marc Rich to the 
Committee:

        If President Clinton had checked with the CIA, he would 
        have learned that Marc Rich had been the subject of 
        inquiries by various foreign government liaison 
        services and domestic government agencies regarding 
        their ongoing investigations of criminal activity.

        In addition, President Clinton would have received 
        information worthy of his consideration in making his 
        decision on the pardon. This information cannot be 
        declassified.

Marc Rich and Pincus Green were guilty of serious crimes and 
showed contempt for the American justice system.

 Marc Rich and Pincus Green attempted to obstruct the 
criminal investigation of them in every way imaginable, 
including attempting to smuggle subpoenaed documents out of the 
country. Rich and Green's tactics resulted in a record-setting 
contempt fine against them, totaling $21 million. Despite these 
tactics, the U.S. Attorney for the Southern District of New 
York was able to indict Marc Rich and Pincus Green on 51 counts 
of illegal activity, including tax evasion, mail fraud, wire 
fraud, and racketeering. The evidence against them was 
overwhelming.

 Because of the strength of the case against them, 
Marc Rich and Pincus Green fled the country rather than face 
trial. Rich's own lawyer told him that by fleeing the country, 
Rich had ``spit on the American flag'' and that ``whatever you 
get, you deserve.'' For the 17 years leading up to his pardon, 
Marc Rich was one of America's 10 most wanted international 
fugitives. Although Jack Quinn, Rich's attorney, argued that 
Rich did not flee the United States to avoid prosecution, 
Rich's ex-wife refuted this view, stating that Rich told her 
that ``I'm having tax problems with the government . . . and I 
think that we are going to have to leave.''

 In order to avoid extradition or apprehension by 
United States law enforcement, Marc Rich and Pincus Green 
attempted to renounce their United States citizenship. While 
this attempt was rejected by the United States, it demonstrated 
that Rich and Green had no loyalty to the United States and 
viewed their citizenship as a liability to be discarded at 
will.

Rich and Green's crimes were so serious that for seventeen 
years, the U.S. government devoted considerable resources to 
apprehending them and closing down their business activities.

 Rich and Green were such high-profile fugitives that 
on a number of occasions in the 1980s and 1990s, the United 
States Marshals Service attempted to arrest them in various 
foreign countries. A number of countries from the United 
Kingdom to Russia attempted to assist the United States in 
these efforts. The pardons of Rich and Green have sent a 
message that individuals can go from the FBI's most wanted list 
to a Presidential pardon if they spend money and have the 
proper connections. This message undermines U.S. efforts to 
apprehend fugitives abroad.

 Rich and Green were such high-profile fugitives that 
in 1991, the Government Reform Committee, under Democratic 
leadership, held a number of hearings, and issued two reports 
about the government's efforts to apprehend Rich and Green. At 
that time, Democrats and Republicans in Congress took the Bush 
Administration to task for not being aggressive enough in 
hunting down Rich and Green, or shutting down their business 
interests in the U.S.

 While Rich and Green were fugitives from justice, 
the American government took a number of actions against their 
interests in the U.S. The federal government seized Rich's 
assets and shut down his trade in metals and grain with the 
government.

The United States government repeatedly tried to reach a plea 
agreement with Rich and Green.

 For a number of years after Rich and Green fled the 
country, the U.S. government attempted to negotiate a plea 
bargain to settle the case. The government made a number of 
concessions in an attempt to reach a deal, but all offers were 
rebuffed by Rich and Green, who would not agree to any deal 
that resulted in jail time. While lobbying for a pardon, Jack 
Quinn and Rich's other lawyers claimed that the Justice 
Department had not even negotiated with Rich, and therefore, 
that a pardon was justified. Quinn and the other lawyers were 
misleading the White House when they made these claims.

Jack Quinn misled the White House about the Rich case and 
attempted to mislead the Committee and the public regarding his 
work for Marc Rich.

 Marc Rich hired Jack Quinn after a recommendation 
from Eric Holder. After numerous failed attempts to have his 
case settled, Marc Rich hired Jack Quinn to represent him. 
Quinn was hired after a recommendation from Deputy Attorney 
General Eric Holder. Gershon Kekst, who worked for Marc Rich on 
the pardon matter, asked Holder for a recommendation of how to 
settle a criminal matter with the Justice Department. Holder 
recommended that he hire a Washington lawyer ``who knows the 
process, he comes to me, and we work it out.'' Holder then 
explicitly recommended the hiring of Jack Quinn. While Holder 
did not know that Kekst was referring to Marc Rich, it suggests 
that Holder was favorably disposed to Jack Quinn, and would be 
very receptive to arguments made by Quinn, no matter how 
baseless they were.

 Marc Rich was going to pay Jack Quinn for his work 
on the pardon. After the Marc Rich pardon was granted, Jack 
Quinn claimed that he was not being paid by Rich for his work 
on the pardon and that he expected no future payment for his 
work on the pardon. However, the Committee has uncovered 
evidence that Robert Fink, a lawyer close to Marc Rich, had 
discussions with Rich and Quinn about paying Quinn for his work 
on the Rich pardon. Documents which Quinn and Fink withheld 
from the Committee for over a year, and which were produced 
only after a federal judge ordered them produced to a grand 
jury, shed further light on the contemplated payment of Quinn. 
These documents indicate that Quinn raised the question of his 
``status'' with Rich and asked that Rich pay him a $50,000 per 
month retainer. The Committee attempted to interview Quinn 
about these documents, but Quinn refused to meet with Committee 
staff.

 Jack Quinn may have been attempting to receive money 
from Marc Rich after the pardons were granted. At the 
Committee's February 8, 2001, hearing, Quinn pledged that ``I 
will not bill [Rich], and I will not accept any further 
compensation for work done on the pardon.'' This pledge 
surprised Rich's lawyer, who expected that Rich would be paying 
Quinn for his work. Indeed, records just produced to the 
Committee indicate that Quinn may have been attempting to 
negotiate some payment from Marc Rich shortly after he pledged 
that he would not take additional money for his work. A March 
5, 2001, e-mail from Quinn to Rich states, ``If you are 
agreeable, and I hope you are, I need to fax to you in the next 
few days a new retainer agreement.'' This e-mail raises the 
possibility that Quinn has been attempting to obtain payments 
from Rich, in possible violation of his pledge to the 
Committee. The Committee attempted to interview Quinn about 
this matter, but he refused.

 Jack Quinn's work on the Rich pardon was in apparent 
violation of Executive Order 12834. That executive order was 
enacted as part of President Clinton's promise to create ``the 
most ethical administration in history,'' and it prohibited 
former executive branch employees from lobbying their former 
executive branch agencies within five years of their departure. 
Quinn has claimed that his work on the Rich pardon came within 
an exception for ``communicating . . . with regard to a . . . 
criminal . . . law enforcement inquiry, investigation or 
proceeding[.]'' However, this exception was clearly intended to 
apply to appearances before courts, not lobbying the White 
House for a pardon. The ``revolving door'' lobbying ban was 
intended to apply exactly to cases like this, where a former 
White House Counsel could come back and lobby the President to 
take an action that had no constitutional limits on it, largely 
based on the President's personal trust for that former 
staffer.

 The pardon petition compiled by Jack Quinn and the 
other Marc Rich lawyers was highly misleading. Most of the 
arguments used by Jack Quinn to justify the Rich and Green 
pardons were false and misleading. These arguments could have 
been completely refuted if anyone in the White House had sought 
out any of the prosecutors familiar with the Rich case.

 The ``letters of support'' in the pardon petition 
were used in a misleading manner. Another key element of the 
Rich pardon petition was a number of letters of support for 
Rich and Green from prominent Americans and Israelis. Rich and 
Green used these letters to try to show that their humanitarian 
activities justified their pardons. However, many of these 
letters were obtained under false pretenses, and the writers of 
the letters were not told that they were being used to obtain a 
Presidential pardon. In addition, a number of individuals who 
wrote in support of Rich and Green received large amounts of 
money from them.

Marc Rich and Pincus Green used a number of different 
individuals with close personal relationships with President 
Clinton and his staff to lobby regarding the pardon.

 The role of Denise Rich. Denise Rich played a key 
role in obtaining the Rich and Green pardons. Denise Rich had a 
close relationship with President Clinton, which was based in 
part on her role as a large-scale contributor to Democratic 
causes and the Clinton library, and in part on her extensive 
personal contacts with President Clinton. The $450,000 given by 
Denise Rich to the Clinton Library was an early and large 
contribution. Denise Rich used her relationship with President 
Clinton to lobby for the Marc Rich pardon on a number of 
occasions. She has refused to cooperate with the Committee, 
invoking her Fifth Amendment rights rather than answer 
questions about her role in the pardon.

 The role of Beth Dozoretz. Beth Dozoretz, another 
close friend of President Clinton, played a key role in 
obtaining the Rich pardon. Like Denise Rich, Beth Dozoretz had 
a relationship with President Clinton built on personal ties 
and political fundraising. Dozoretz has raised and contributed 
millions of dollars for the Democratic party and has pledged to 
raise an additional million dollars for the Clinton library. 
Beth Dozoretz also has close relationships with Denise Rich and 
Jack Quinn. Dozoretz used her close relationship with President 
Clinton to lobby for the Rich pardon. Because Dozoretz has 
invoked her Fifth Amendment rights against self-incrimination, 
the Committee is unable to conclude whether or not Dozoretz 
made any linkage between contributions to the DNC or the 
Clinton library and the granting of the Rich pardon.

 The role of Prime Minister Ehud Barak. Israeli Prime 
Minister Ehud Barak spoke to President Clinton three times 
about the Rich pardon. In his public statements about the Rich 
pardon, President Clinton has pointed to these conversations 
with Prime Minister Barak as one of the primary reasons he 
granted the pardon. However an examination of the transcripts 
of the calls shows that Barak did not make a particularly 
impassioned plea for Rich. Therefore, it appears that the 
President may be attempting to use Prime Minister Barak's 
interest in the Rich matter as a cover for his own motivations 
for granting the Rich pardon.

 Barak had met with Rich personally and told Clinton 
that the Rich pardon ``could be important . . . not just 
financially, but he helped Mossad on more than one case.'' 
Barak's statement raises the possibility that either Barak or 
Clinton acted on the Rich matter because of some promise of 
future financial return.

Eric Holder and Jack Quinn worked together to cut the Justice 
Department out of the decisionmaking process. Holder's decision 
to support the pardon had a critical impact.

 Jack Quinn and Deputy Attorney General Eric Holder 
worked together to ensure that the Justice Department, 
especially the prosecutors of the Southern District of New 
York, did not have an opportunity to express an opinion on the 
Rich pardon before it was granted. The evidence amassed by the 
Committee indicates that Holder advised Quinn to file the Rich 
pardon petition with the White House, and leave the Justice 
Department out of the process. One e-mail produced to the 
Committee suggests that Holder told Quinn to ``go straight to 
wh'' and that the ``timing is good.'' The evidence also 
indicates that Holder failed to inform the prosecutors under 
him that the Rich pardon was under consideration, despite the 
fact that he was aware of the pardon effort for almost two 
months before it was granted.

 Eric Holder's support of the Rich pardon played a 
critical role in the success of the pardon effort. Holder 
informed the White House that he was ``neutral, leaning towards 
favorable'' on the Rich pardon, even though he knew that Rich 
was a fugitive from justice and that Justice Department 
prosecutors viewed Rich with such contempt that they would no 
longer meet with his lawyers. Holder has failed to offer any 
credible justification for his support of the Rich pardon, 
leading the Committee to believe that Holder had other 
motivations for his decision, which he has failed to share with 
the Committee.

 Eric Holder was seeking Jack Quinn's support to be 
appointed as Attorney General in a potential Gore 
Administration, and this may have affected Holder's judgment in 
the Rich matter. On several occasions, Holder sought out 
Quinn's endorsement to be appointed as Attorney General if Al 
Gore were to win the November 2000 election. Quinn was a Gore 
confidant whose endorsement would carry great weight. Holder's 
initial help to Quinn in the Rich matter predated the Supreme 
Court's decision in Bush v. Gore, and accordingly, Holder had 
some legitimate prospect of being appointed Attorney General 
when he was helping Quinn keep the Rich matter from the Justice 
Department's scrutiny. While Holder denies that his desire to 
be appointed Attorney General had anything to do with his 
actions in the Rich matter, it provides a much clearer and more 
believable motivation than any offered by Holder to date.

President Clinton made his decision knowing almost nothing 
about the Rich case, making a number of mistaken assumptions, 
and reaching false conclusions.

 The White House never consulted with the prosecutors 
in the Southern District of New York regarding the Rich case. 
As a result, the White House staff was never able to refute the 
false and misleading arguments made in the Marc Rich pardon 
petition.

 Every White House staff member who was working on 
the Rich pardon opposed it. However, because they failed to do 
the necessary background research on the Rich case, they were 
unable to refute the arguments made by Jack Quinn.

 President Clinton was misled by Jack Quinn in their 
negotiations regarding the Rich pardon. Late in the evening of 
January 19, 2001, President Clinton and Jack Quinn had a 
telephone discussion regarding the Rich pardon. During this 
conversation, Quinn repeated his usual misleading arguments 
about the Rich case. Quinn also offered to make his clients 
subject to civil liability for their actions. In furtherance of 
this offer, Quinn agreed to waive all statute of limitations 
and other defenses, which Rich and Green would have as a result 
of their fugitivity. President Clinton has cited this waiver as 
a key factor in his decision to grant the pardons. However, if 
President Clinton or his staff had done even cursory legal 
research, they would have understood that this was a hollow, 
meaningless deal. First, Quinn agreed to waive defenses that 
Rich and Green did not have. It is basic legal doctrine that 
fugitivity tolls the statute of limitations. Second, Rich and 
Green likely do not face any civil liability for their crimes, 
since those fines were already paid by their companies. Third, 
Rich and Green had been willing to pay $100 million to settle 
their case for years. A fine, even a large one, would have had 
no impact on Rich and Green, and it would merely stand for the 
proposition that the U.S. justice system is for sale.

 When the White House did finally provide the names 
of Marc Rich and Pincus Green for a Justice Department 
background check in the middle of the night on January 19, 
2001, the check turned up new, troubling information which was 
disregarded by President Clinton. When the White House 
requested the Justice Department to perform a computer 
background check on Rich and Green prior to granting the 
pardons, the check came back with information that they were 
wanted for ``arms trading.'' This was new information for all 
of the White House staff, and it raised serious questions among 
them as to whether the pardons should be granted. However, the 
only step the White House took to check on this allegation was 
to call Jack Quinn. Quinn predictably denied that his clients 
were involved in arms trading. Faced with this conflicting 
information about Rich and Green, President Clinton instructed 
his staff to ``take Jack's word'' and issue the pardons.

President Clinton has failed to offer a full accounting for his 
decision to issue the Marc Rich and Pincus Green pardons.

 President Clinton has failed to answer any questions 
about the Rich and Green pardons. The few statements that he 
has issued have been misleading, incomplete, and raised more 
questions than they answered. Given his complete failure to 
explain the pardons, the Committee is left with serious 
unanswered questions regarding President Clinton's motives.

ROGER CLINTON'S EFFORTS TO LOBBY FOR EXECUTIVE CLEMENCY

Roger Clinton engaged in a systematic effort to trade on his 
brother's name during the Clinton Administration.

 President Clinton encouraged Roger Clinton to 
capitalize on their relationship. At the beginning of his 
second term, President Clinton instructed Roger Clinton to use 
his connections to the Administration to gain financial 
advantage. According to the lawyer for former Arkansas State 
Senator George Locke: ``Roger related that Bill Clinton had 
instructed him that since this was his last term in office, 
Roger should find a way to make a living and use his 
relationship with the President to his advantage.'' By 
suggesting that Roger Clinton exploit his name, Bill Clinton 
encouraged the conduct described in this chapter. Roger Clinton 
apparently took this advice to heart, telling one person from 
whom he solicited money that he and the President ``had only 
four years to get things done'' and that they did not care 
``about ethics or what appearances were.''

 Roger Clinton received substantial sums of money 
from foreign governments solely because he was the President's 
brother. When the FBI interviewed him, Roger Clinton admitted 
that since the beginning of the Clinton Administration, he had 
received substantial sums of money from foreign governments. 
Clinton told the FBI that ``he knows he receives these 
invitations [to make paid appearances in foreign countries] 
strictly because he is the First Brother of the President of 
the United States.'' Clinton also informed the FBI that in 
addition to receiving hundreds of thousands of dollars for 
musical performances from foreign governments, he also received 
money for President Clinton from foreign governments. Roger 
Clinton told the FBI that he had to be instructed repeatedly by 
the President or White House staff that the President was not 
permitted to receive cash from foreign governments.

 Roger Clinton received at least $335,000 in 
unexplained travelers checks, many of which were purchased 
overseas and likely imported illegally. The Committee uncovered 
at least $335,000 in travelers checks deposited in Roger 
Clinton's bank account. Most of these travelers checks 
originated overseas, largely from Taiwan, South Korea, and 
Venezuela. The travelers checks were not restrictively endorsed 
by the purchaser but were instead given to Roger Clinton blank. 
This method of transferring large sums of money to Roger 
Clinton appears designed to conceal the fact that the funds 
originated overseas and probably violated criminal statutes 
requiring reports of the importation of monetary instruments. 
Roger Clinton has refused to provide the Committee with any 
explanation of why he received these funds. These suspicious 
transactions require a complete and thorough investigation by 
law enforcement authorities, especially in light of his 
admissions to the FBI about receiving money from foreign 
governments.

 Roger Clinton likely violated federal law by failing 
to register as required under the Lobbying Disclosure Act. One 
company paid Roger Clinton $30,000 to lobby President Clinton 
and others to loosen government restrictions on travel to Cuba. 
Although his activity appears to meet the criteria outlined in 
the statute for those required to disclose their contacts with 
covered executive branch officials, Roger Clinton did not 
register as a lobbyist and did not disclose his paid lobbying 
contacts with his brother. His failure to register, therefore, 
needs to be investigated carefully and completely by the 
Department of Justice.

 Roger Clinton participated in a plot to obtain a 
$35,000 per month contract in exchange for delivering a cabinet 
secretary to a speaking event. The FBI briefly investigated 
Roger Clinton's involvement in a scheme with Arkansas lawyer 
Larry Wallace to pressure John Katopodis, promoter of an 
Alabama airport project. Clinton and Wallace attempted to 
obtain a $35,000 per month contract in exchange for Clinton's 
promise to ensure that Secretary of Transportation Rodney 
Slater would speak at a conference sponsored by Katopodis' 
organization of local governments. When Katopodis refused to 
pay and Slater subsequently refused to acknowledge the 
invitation, Katopodis suspected that Clinton and Wallace were 
to blame. Wallace had told him that his project would remain at 
a standstill until Katopodis ``showed him the money.''

Roger Clinton lobbied for the release from prison of Rosario 
Gambino, a notorious heroin dealer and organized crime figure.

 Rosario Gambino was a major drug trafficker. Rosario 
Gambino has been convicted in the United States and Italy of 
heroin trafficking. Before being sentenced to 45 years in 
federal prison, Gambino associated with known members of 
organized crime both in Italy and the United States. His 
associates have described him as a member of the Sicilian 
Mafia. When his brothers were convicted of racketeering, 
murder, illegal gambling, loan sharking, and heroin trafficking 
in 1994, witnesses described them as ``the main link between 
Mafia heroin traffickers in Sicily and the American Mafia.''

 Roger Clinton received at least $50,000 from the 
Gambino family, and he expected to receive more if he succeeded 
in getting Rosario Gambino out of prison. Tommaso ``Tommy'' 
Gambino, the son of Rosario Gambino, approached Roger Clinton 
to help win the release of Rosario Gambino from prison. Tommy 
Gambino promised Roger Clinton a substantial financial reward 
if he was successful. Even though he never was successful, 
Tommy Gambino provided Roger Clinton with $50,000, a gold Rolex 
watch, and an undisclosed amount of ``expense money.''

 Roger Clinton attempted to use his relationship to 
the President to influence the decisionmaking of the United 
States Parole Commission (``USPC''). Roger Clinton lobbied the 
Parole Commission to grant parole to Gambino. While lobbying 
Parole Commission staff, Roger Clinton informed them that 
President Clinton was aware of his efforts on behalf of Rosario 
Gambino and that the President had suggested that he contact 
the Parole Commission members directly. Although the Commission 
staff tried to insulate the Commissioners from undue influence, 
Roger Clinton clearly attempted to use his relationship to the 
President to influence the Commission improperly and win 
Gambino's release.

 The Chief of Staff of the Parole Commission hindered 
the FBI's investigation. In 1998, the FBI began investigating 
Roger Clinton's contacts with the Parole Commission. However, 
it met resistance from Marie Ragghianti, the Chief of Staff of 
the Parole Commission. Ragghianti, who had participated in 
meetings with Roger Clinton on the Gambino case, objected to 
the FBI investigation and successfully halted an FBI plan to 
have an undercover agent meet with Clinton posing as a Parole 
Commission staffer. She also attempted to keep the FBI from 
recording a meeting between Roger Clinton and a Parole 
Commission staffer. Ragghianti's efforts may have kept the FBI 
from reaching a full understanding of Roger Clinton's 
involvement in the Gambino case.

 Roger Clinton lied to FBI agents investigating his 
contacts with the Parole Commission and his relationship with 
the Gambino family. When interviewed by the FBI in 1999, Roger 
Clinton said that he had never represented to anyone at the 
Parole Commission that the President was aware of his contacts 
with the Commission on behalf of Rosario Gambino. This self-
serving claim is contradicted by contemporaneous, written 
memoranda detailing Clinton's contacts as well as by the vivid 
and credible recollections of Parole Commission staff. Clinton 
also lied about the purpose of a $50,000 check from the 
Gambinos, which he deposited on the day of the FBI's interview. 
While it is unclear whether he deposited the check before or 
after the interview, Clinton told the agents that Tommy Gambino 
had offered to loan him money for a down payment on his house. 
He repeated this explanation to the media when news of the 
money became public in 2001. However, after reviewing both 
Clinton's and Gambino's bank records, the Committee has found 
no evidence that Clinton used the $50,000 for a down payment or 
that he ever repaid any of the money. Accordingly, his claim to 
the FBI that the money was merely a loan is false. During his 
interview, Clinton also told the FBI agents three separate and 
contradictory stories in response to questions about his 
receipt of a Rolex watch from Tommy Gambino before finally 
producing a Rolex to the agents and claiming he had bought it 
in Tijuana, Mexico.

 Roger Clinton apparently lobbied the White House to 
grant a commutation to Rosario Gambino. In the last days of the 
Clinton Administration--after Roger Clinton had failed to win 
parole for Rosario Gambino and after he had received a Rolex 
watch and $50,000 from the Gambino family--the White House 
received a petition for commutation for Rosario Gambino. 
Documents indicate that the White House lawyer responsible for 
clemency matters requested a criminal background check on 
Gambino, which is normally done when some serious consideration 
is being given to a grant of clemency. The obvious and logical 
inference that explains how the Gambino petition garnered that 
level of attention at the White House is that Roger Clinton was 
pushing for it. Because key Clinton White House staff have 
refused to answer questions about this matter, it is unknown 
whether Roger Clinton hand-delivered the Gambino petition as he 
did with others or whether he brought it to the attention of 
the White House some other way. Although the President did not 
ultimately grant clemency to Gambino, the circumstances 
surrounding the consideration of his petition are nevertheless 
suspect. The fact that granting clemency to a mobster and 
confirmed criminal like Gambino was considered at all is 
disturbing enough, but the reason it was considered is even 
more offensive. The Gambino family was apparently able to 
purchase access to the parole and clemency processes with cash 
payments and expensive gifts to the brother of the President of 
the United States. Moreover, despite an FBI investigation of 
the matter, the Justice Department has, to date, been unwilling 
or unable to prosecute Clinton for any of his activities.

Roger Clinton received a substantial portion of $225,000 that 
was swindled from the Lincecum family in Clinton's name with 
the promise of a pardon that never came.

 The Lincecum family paid $225,000 to obtain a pardon 
for Garland Lincecum. In 1998, Garland Lincecum, a convicted 
felon, was informed that he could purchase a presidential 
pardon for $300,000. Lincecum was told that Arkansas 
businessmen Dickey Morton and George Locke, who had a close 
relationship with Roger Clinton, could obtain the pardon. 
Lincecum borrowed $225,000 from his mother and brother and 
claims that a business associate paid another $70,000 to Morton 
and Locke for his pardon. The money he borrowed from his family 
constituted their life savings and means of support in 
retirement.

 Roger Clinton received at least $43,500 in proceeds 
from the Lincecums' payments to Morton and Locke. Dickey 
Morton, George Locke, and Roger Clinton divided the funds among 
themselves with Roger Clinton receiving a total of $25,500 in 
checks and $18,000 in cash. The Lincecums paid the checks to a 
company called CLM, which they were told stands for Clinton, 
Locke, and Morton. Dickey Morton then disbursed the funds from 
the company's bank account to Clinton, Locke, and himself. 
Roger Clinton has falsely denied any relationship with CLM 
while offering no explanation of why he received this 
substantial share of an elderly woman's retirement savings 
through CLM.

 Roger Clinton may have been involved in a scheme to 
defraud the Lincecums. Garland Lincecum never received a 
pardon, and there is no evidence that Dickey Morton, George 
Locke, or Roger Clinton ever submitted Lincecum's name to the 
Justice Department or White House for consideration for a 
pardon. Therefore, it appears that the Lincecums were the 
victims of a scam perpetrated by Morton, Locke, and perhaps 
Roger Clinton as well.

Roger Clinton may have been involved in lobbying for as many as 
13 other pardons and commutations.

 Roger Clinton publicly admitted involvement in six 
clemency efforts, but the evidence connects him to many more. 
Roger Clinton told the media that he had asked for pardons for 
approximately six close friends and that he did so because of 
concern for them and not for any personal gain. For example, 
Roger Clinton lobbied for pardons for George Locke and Dan 
Lasater, two associates from Arkansas who were convicted of 
drug offenses together with Clinton himself in the 1980s. 
However, the Committee has obtained evidence connecting Clinton 
to many more pardon seekers. Some of the cases involve people 
who were not his personal friends and some involve 
solicitations or offers of money and lucrative business 
opportunities in exchange for his ability to place a clemency 
petition in front of the President.

 Roger Clinton was asked to lobby for a pardon for 
horse breeder J.T. Lundy in exchange for secretly sharing 
profits in a lucrative business venture. Lundy promised Clinton 
a share of a the profits from a Venezuelan coal deal in 
exchange for Clinton's help in obtaining a pardon for him. 
Lundy suggested a scheme whereby the payments to Clinton could 
be concealed by placing his share of the profits in Dan 
Lasater's name. Lasater, who owned a 20 percent interest in the 
venture, discussed the possibility of a pardon for Lundy with 
Roger Clinton.

 Roger Clinton delivered the pardon petition of 
former Reagan EPA official Rita Lavelle to the White House. 
According to Lavelle, an intermediary for Roger Clinton asked 
her for a $30,000 fee for him to hand-carry her petition to the 
President. Lavelle responded that she could not afford to pay 
any money, but she said Clinton agreed to deliver the petition 
anyway. On the last night of the Clinton presidency, Roger 
Clinton asked Lavelle, ``do you have $100,000 to get this 
through?'' Being bankrupt, however, Lavelle laughed at the 
question. She did not pay Clinton any money and did not receive 
a pardon.

 Roger Clinton was asked to lobby for a pardon for 
Houston real estate developer John Ballis, and Ballis' petition 
was seriously considered at the White House. After being 
convicted of S&L fraud, Ballis married a former employee of Dan 
Lasater and friend of Roger Clinton. Through his wife's 
connection, Ballis sought Roger Clinton's help. Clinton first 
lobbied for Ballis before the U.S. Parole Commission, sometimes 
during the same meetings in which he lobbied for mobster 
Rosario Gambino. Ballis credited Clinton with helping him 
obtain early release and sought his help in obtaining a 
presidential pardon to eliminate his parole supervision and 
restitution payments. While he was not granted any form of 
clemency, the President reviewed his petition, and a White 
House lawyer called Ballis' lawyer two nights before 
inauguration day to ask if Ballis would accept a grant of 
clemency that left intact his obligation to pay restitution.

 Roger Clinton lobbied his brother to grant clemency 
to Steven Griggs, the son of the chief of an unrecognized 
American Indian tribe, who was in prison on drug charges. Like 
Ballis, Steven Griggs was not a close friend of Roger Clinton's 
but merely someone who knew someone who knew him. Griggs also 
did not receive clemency, but Roger Clinton helped ensure that 
Griggs' petition was brought to the attention of the President 
even though Griggs had been a fugitive for a year before being 
sentenced. Griggs argued in his petition that he had received 
an unusually harsh sentence but failed to mention that he had 
fled after his conviction. It is not clear what motivated Roger 
Clinton to assist Griggs, but some evidence suggests that the 
tribe may have planned to open a casino when and if it were to 
become recognized by the federal government.

 According to his former lawyer, Arkansas restaurant 
operator Phillip Young was approached with an offer to obtain a 
pardon through Roger Clinton for $30,000. While Young denied to 
Committee staff that he was actually approached by anyone with 
such a proposal, his denial is not as credible as his former 
attorney's version of events.

Both the White House and the Justice Department hindered the 
Committee's investigation of Roger Clinton by improperly 
refusing to produce key documents.

 For months, the Bush White House prevented the 
National Archives from producing even non-deliberative, 
clemency-related records from the Clinton administration. The 
Committee did not learn that President Clinton had been 
considering a clemency petition from notorious mobster Rosario 
Gambino until after Archives personnel ``inadvertently'' 
produced documents that President Bush's Counsel had sought to 
withhold. The accidental production also included documents 
relating to three other previously unknown individuals who had 
sought clemency through Roger Clinton. The Bush Administration 
did manage to retain four additional deliberative Gambino 
documents from the files of the Clinton White House, refusing 
to produce the records even though they were not subject to any 
executive privilege claim.

 The Ashcroft Justice Department produced certain 
Gambino-related records, but inexplicably withheld others. 
After producing sensitive documents such as U.S. Parole 
Commission files related to Rosario Gambino and a summary of an 
FBI interview with Roger Clinton, the Justice Department ceased 
producing additional documents, claiming they were related to 
an ongoing criminal investigation, even though the Clinton-
Gambino matter had reportedly been closed in 2000.

HUGH RODHAM'S INVOLVEMENT IN THE VIGNALI COMMUTATION

Vignali's clemency petition was false and misleading.

 Carlos Vignali lied in his clemency petition. First, 
he continued to maintain his innocence, despite overwhelming 
evidence of his involvement in selling a substantial amount of 
cocaine across state lines and a specific finding by the 
sentencing judge that he lied at trial about his involvement in 
a large drug distribution network. Second, Vignali claimed that 
he was a first-time offender, despite the fact that he had a 
prior criminal record. By not accepting responsibility for his 
crime and lying about his background, he should not have been 
eligible for executive clemency.

Vignali's supporters provided letters of support which were 
false and misleading.

 A key element of the campaign by Carlos Vignali and 
his father Horacio Vignali, was a series of letters on Carlos' 
behalf from prominent Los Angeles politicians. A number of 
these letters contained misleading statements calculated to 
create the impression that Carlos Vignali was innocent. The 
officials who submitted letters included Representative Xavier 
Becerra, Representative Esteban Torres, State Assembly Speaker 
Robert Hertzberg, State Assembly member Antonio Villaraigosa, 
State Senator Richard Polanco, Los Angeles County Supervisor 
Gloria Molina, Los Angeles City Councilmember Mike Hernandez, 
and Cardinal Roger Mahony, Archbishop of Los Angeles.

Los Angeles County Sheriff Lee Baca provided critical support 
for the Vignali commutation, which was inappropriate, given his 
position.

 Sheriff Baca had a close relationship with Horacio 
Vignali which was based on Vignali's political and financial 
support for Baca. Sheriff Baca has known Horacio Vignali since 
1991, and Vignali has been a key political supporter of Baca, 
giving him at least $11,000 in contributions and raising 
between $60,000-$70,000 more.

 Sheriff Baca spoke with the White House in support 
of the Vignali commutation. In January 2001, Baca received a 
telephone call from Hugh Rodham in which Rodham told Baca that 
he would get a call from the White House about Horacio Vignali. 
Shortly thereafter, Baca received a call from White House staff 
and spoke in support of Horacio Vignali. Based on Baca's 
statements in this telephone call, White House staff clearly 
and justifiably concluded that Baca supported the commutation 
of Carlos Vignali's sentence.

 Sheriff Baca continues to claim, without any basis, 
that he did not support the Vignali commutation. Rather than 
express regret for his role in the Vignali commutation, Sheriff 
Baca maintains that he opposed the Vignali commutation and did 
nothing that could have been interpreted as support for the 
commutation. However, Sheriff Baca's supposed opposition to the 
Vignali commutation does not square with the fact that: (1) he 
drafted a letter which he believed Horacio Vignali would use in 
the clemency effort; and (2) when he was asked squarely by the 
White House if the President should commute Vignali's prison 
sentence, he stated that it was ``the President's decision to 
make,'' rather than express his opposition. These facts, and 
others outlined in this report, indicate that Sheriff Baca 
wanted to support the Vignali commutation, but was afraid of 
creating a paper record which would clearly indicate his 
support.

 Sheriff Baca's efforts on behalf of the Vignalis are 
even more inappropriate given that there were extensive 
allegations that Horacio Vignali, Carlos' father, was also 
involved in illegal drug trafficking. It is inappropriate 
enough for a senior law enforcement official like Baca to 
support a grant of clemency for an unrepentant, large-scale 
drug dealer like Carlos Vignali. However, when coupled with 
credible allegations indicating that Horacio Vignali was a drug 
dealer, and in fact was the source of cocaine supply for his 
son, Baca's support of Horacio and Carlos Vignali is even more 
inappropriate.

U.S. Attorney Alejandro Mayorkas provided critical support for 
the Vignali commutation, which was inappropriate, given his 
position.

 U.S. Attorney Alejandro Mayorkas called the White 
House in support of the Vignali commutation. Mayorkas, the top 
federal prosecutor in Los Angeles, was asked by Horacio Vignali 
to call the White House in support of his son's clemency 
petition. Mayorkas then called the White House about the 
Vignali commutation. While Mayorkas does not recall the details 
of his conversation, he now concedes that his call conveyed 
support for the Vignali commutation.

 Mayorkas supported the Vignali commutation despite 
his ignorance of the facts of the case and his knowledge that 
the prosecutors responsible for the Vignali case opposed 
clemency. Before he called the White House, Mayorkas had spoken 
twice with Todd Jones, the U.S. Attorney responsible for the 
Vignali case. Jones told Mayorkas that Vignali was a ``major 
player'' in drug trafficking, that he was ``bad news'' and that 
Mayorkas should not ``go there'' when it came to Vignali. 
Despite these warnings from a prosecutor who was intimately 
familiar with the Vignali case, Mayorkas still called the White 
House in support of the Vignali commutation.

 Mayorkas' support for the Vignali commutation was 
inappropriate. Mayorkas knew little about the Vignali case. 
What he did know indicated that Carlos Vignali was an 
unrepentant large-scale criminal. These facts alone make his 
support for the commutation, as a senior federal prosecutor, 
totally inappropriate.

There are a number of allegations that both Horacio and Carlos 
Vignali were involved in illegal drug trafficking.

 There are allegations that, in addition to his son, 
Horacio Vignali was involved in illegal drug trafficking and 
that Carlos Vignali was involved in drug trafficking far beyond 
the conduct which led to his conviction in Minnesota. DEA 
reports documenting these allegations include the following 
statements:

        ``[Horacio Vignali] negotiated with ATF agents to sell 
        a machine gun and stated to them that he had also 
        smuggled heroin into the United States utilizing 
        automobiles.''

        ``[Redacted] has also purchased cocaine from Carlos 
        Vignali Jr. of Los Angeles . . . Vignali's father 
        Carlos Vignali aka ``pops'' owns a body shop, at 1260 
        Figueroa and is the source of supply for his son.''

        ``Carlos Horatio Vignali's role in [George Torres' drug 
        dealing] organization is relatively unknown at this 
        time. It is believed that Vignali functions as a 
        financial partner in the organization.''

 These DEA reports are corroborated by law 
enforcement personnel who indicate that they had received 
information indicating that both Horacio and Carlos Vignali 
were involved in large-scale drug trafficking. These charges 
have never been formally made in court, or substantiated by 
physical evidence. However, the mere existence of such 
allegations should have precluded senior law enforcement and 
political officials from supporting a commutation for Carlos 
Vignali on the strength of his father's reputation. However, it 
appears that no one checked with the DEA prior to granting the 
commutation.

Hugh Rodham provided false and misleading information to the 
White House in support of the Vignali commutation.

 Hugh Rodham was paid $204,200 for his work on the 
Vignali commutation. It appears that in return for this money, 
he worked part-time for two months gathering materials in 
support of Vignali's case and making telephone calls to White 
House staff. It appears that Rodham's payment in the Vignali 
matter was contingent upon his success, as he received the 
$200,000 payment on January 24, 2001, after President Clinton 
granted clemency to Vignali.

 Rodham repeatedly provided false information during 
his communications with the White House. First, and most 
importantly, Rodham told Bruce Lindsey that the trial attorney 
who prosecuted Vignali supported the commutation. This was 
completely false. Second, Rodham told Lindsey that Vignali was 
a first-time offender, when in fact, he had two prior 
convictions and two other arrests. Rodham also told Lindsey 
that Vignali ``did not play a major role in the offense,'' when 
in fact, Vignali was a major source of cocaine for the 
Minnesota drug-dealing ring at issue in his case.

Hugh Rodham told the White House that First Lady Hillary Rodham 
Clinton was aware of his lobbying efforts and that the Vignali 
commutation was ``very important'' to her.

 Hugh Rodham told White House staff that the Vignali 
commutation was ``very important to him and the First Lady as 
well as others.'' This statement is confirmed by the 
independent recollection of the White House staffer who spoke 
to Rodham as well as the note which she took contemporaneously. 
Rodham's statement raises two possibilities: first, that the 
First Lady was aware of, and approved of, Hugh Rodham's 
lobbying efforts; or second, that Hugh Rodham was lying to 
White House staff regarding the First Lady's knowledge of his 
efforts.

The White House sought the opinion of powerful Los Angeles 
political figures, but failed to consult with the prosecutors 
or judge who understood the Vignali case.

 White House staff engaged in telephone conversations 
with a number of outside individuals regarding the Vignali 
case--Hugh Rodham, Lee Baca, and Alejandro Mayorkas, none of 
whom knew very much about the Vignali case. It appears that key 
White House staff gave great weight to the input provided by 
Rodham, Baca, and Mayorkas, even though they knew little about 
the case and had mixed motives.

 White House staff failed to reach out to the 
prosecutors who had convicted Vignali, or the judge who 
sentenced him. White House staff justified their failure to 
take this simple action by concluding that they knew that the 
prosecutors and judge would object, so there was no need to 
speak to them. However, if the White House had spoken to Todd 
Jones, Denise Reilly, Andrew Dunne, or Judge David Doty, they 
would have learned that Carlos Vignali: (1) was not a small-
time drug dealer; (2) was unrepentant about his criminal 
activity; and (3) never cooperated with law enforcement by 
telling them who supplied him cocaine.

The White House ignored the strenuous objections to the Vignali 
commutation which were lodged by the Pardon Attorney.

 The Pardon Attorney provided the White House with a 
report that contained his recommendation against granting the 
Vignali commutation. This report contained a number of powerful 
arguments against the commutation, which were apparently 
ignored by the White House. The existence of the Pardon 
Attorney's report means that the White House cannot claim that 
it was totally unaware that Vignali's arguments were completely 
false. The White House knew that the Vignali clemency petition 
had no merit, yet decided to grant the commutation anyway. 
President Clinton's decision raises questions about why the 
Vignali commutation was granted.

Rodham has apparently misled the public about returning to the 
Vignalis those fees he received in connection with the clemency 
and ignored former President and Senator Clinton's request that 
he do so.

 On February 21, 2001, at the request of former 
President Clinton and Senator Hillary Rodham Clinton, Rodham 
promised to return to Horacio Vignali the legal fees he 
received in connection with the Vignali clemency. But, as of 
June 2001, Rodham had apparently returned only about $50,000 of 
the money that Horacio Vignali paid him. Rodham's attorney has 
confirmed to Committee staff that Rodham has not returned any 
additional amounts and has no plans to return the remaining 
$154,000.

HUGH RODHAM'S INVOLVEMENT IN THE BRASWELL PARDON

Glenn Braswell was under investigation by multiple federal 
agencies and several state attorneys general when the pardon 
was granted.

 Over the past two decades, Braswell has created a 
dietary supplement empire using false advertising to mislead 
consumers. After serving time in prison for mail fraud and tax 
evasion in 1983, Braswell has continued to defraud consumers 
about the benefits of his herbal remedies. In addition to 
facing numerous lawsuits, Braswell's companies have been 
investigated by the Internal Revenue Service, Federal Trade 
Commission, Food and Drug Administration, and Better Business 
Bureau.

 Unsurprisingly, Braswell was under another criminal 
investigation by federal prosecutors for a massive tax evasion 
and money-laundering scheme when he was pardoned. Braswell's 
petition bypassed the traditional route through the Justice 
Department and went directly to the White House. If the FBI had 
conducted a background investigation instead of the White 
House, Braswell's petition would have been rejected quickly.

Braswell paid Hugh Rodham $230,000 for successfully obtaining 
the pardon.

 Braswell hired Rodham to support his pardon petition 
for $230,000. For this price, Rodham claims he forwarded a 
letter of support for Braswell to the White House Counsel's 
Office, and he made a follow-up inquiry. According to Rodham, 
these two actions were the extent of his role in the Braswell 
pardon. Rodham refunded the $230,000 to Braswell after facing 
widespread criticism from the media and members of both 
political parties.
HUGH RODHAM'S EFFORTS TO LOBBY FOR CLEMENCY FOR THE LUMS

Gene and Nora Lum, prominent Democratic contributors and 
fundraisers, were convicted of making illegal conduit 
contributions and tax offenses.

 In 1997, the Lums pleaded guilty to making $50,000 
in illegal conduit contributions to the DNC. They were 
sentenced to home detention, confinement in a halfway house and 
a $30,000 fine. In August 1998, Gene Lum pleaded guilty to tax 
fraud for filing tax returns claiming more than $7.1 million in 
false deductions and was sentenced to two years imprisonment.

The Lums attempted to obtain executive clemency through Hugh 
Rodham.

 Hugh Rodham lobbied the White House as part of the 
Lums' efforts but failed to secure them a grant of clemency. In 
December 2000, Nora Lum called one of her husband's criminal 
attorneys and asked him to send various documents to Hugh 
Rodham at the White House. He did so. In early January 2001, 
Rodham called Gene Lum's attorney again and asked him to resend 
those documents directly to, among others, Meredith Cabe, an 
associate White House counsel responsible for clemency matters. 
Subsequently, Rodham telephoned Cabe and discussed the merits 
of the Lums' pardon request. Cabe then told White House Counsel 
Beth Nolan and Deputy White House Counsel Bruce Lindsey about 
her discussion with Rodham. Both told Cabe that the Lums were 
not going to receive clemency.

The Lums and Hugh Rodham have refused to cooperate with the 
Committee's investigation.

 Gene and Nora Lum have refused to cooperate with the 
Committee's investigation. The Lums' daughter, Nicole (with 
whom Hugh Rodham apparently had some sort of business 
relationship), has likewise declined to be interviewed by the 
Committee. Hugh Rodham has also refused to cooperate with the 
Committee's request for an interview. Therefore, the Committee 
is unable to obtain a full understanding of the Lums' efforts 
to obtain executive clemency and Rodham's role in those 
efforts.

TONY RODHAM'S EFFORTS TO LOBBY FOR EXECUTIVE CLEMENCY

Tony Rodham's Role in the Case of Edgar and Vonna Jo Gregory

 Tony Rodham lobbied President Clinton to grant 
pardons to Edgar and Vonna Jo Gregory while he was receiving 
substantial sums of money from the Gregorys. Rodham received 
$244,769 in salary from the Gregorys over two and a half years 
and also received another $79,000 in loans from the Gregorys. 
The Gregorys claim that they paid Rodham this large sum of 
money for various consulting services that Rodham provided to 
the Gregorys. However, the Gregorys do not have any 
documentation reflecting work performed for them by Rodham.

 Given the fact that the Gregorys do not have any 
documentary evidence reflecting the $244,769 of work performed 
for them by Rodham, substantial questions are raised as to what 
Rodham actually did for the Gregorys that was so valuable. The 
most valuable thing that Rodham did for the Gregorys was to 
obtain presidential pardons. Therefore, there is a substantial 
question as to whether the Gregorys paid Rodham for his efforts 
to obtain presidential pardons for them.

 If Rodham was paid to obtain presidential pardons 
for the Gregorys, it creates the strong appearance of 
impropriety. The prospect of financial benefit for Rodham would 
taint Rodham's actions in lobbying for the pardon. Also, if 
President Clinton knew about Rodham's financial arrangement, it 
would taint his actions in granting the pardons.

 Compounding the appearance of impropriety in the 
Gregory case is the fact that the pardons were opposed by the 
Justice Department, the prosecutors responsible for the case, 
and also the Gregorys' sentencing judge. Apparently, the only 
people in the Clinton Administration who felt that the Gregorys 
deserved pardons were President Clinton and Deputy White House 
Counsel Bruce Lindsey, both of whom knew of Tony Rodham's 
involvement in the matter.

Tony Rodham's Role in the Case of Fernando Fuentes Coba

 Tony Rodham offered to help Vivian Mannerud obtain a 
pardon for her father, Fernando Fuentes Coba, in exchange for 
$50,000. When Rodham learned in late 2000 that Mannerud was 
seeking a pardon for her elderly father, he met with Mannerud 
and told her that he could help obtain the pardon if she paid 
him a $50,000 consulting fee. Rodham told Mannerud that he had 
successfully obtained pardons before and showed her the 
Gregorys' pardon petition to support his claim.

 Rodham attempted to convince Mannerud to hire him by 
making a number of false representations to her. Rodham told 
Mannerud that he was close personal friends with the Pardon 
Attorney, Roger Adams. Rodham also told Mannerud that he would 
use the $50,000 to hire a law firm to handle her case and that 
Roger Adams' wife worked at the law firm, which would help her 
case be treated favorably. All of these representations were 
completely false and were apparently made to mislead Mannerud 
as to the purpose of the payment to Rodham.

 Mannerud rejected Rodham's offer. Mannerud was 
concerned that Rodham could not guarantee that he could obtain 
a pardon in exchange for the $50,000. She was also concerned 
about becoming embroiled in a scandal. Therefore, she rejected 
Rodham's offer.

 After Mannerud rejected Rodham's offer, an associate 
of Rodham came back to Mannerud with another offer. According 
to Mannerud, a month after she rejected Tony Rodham's proposal, 
Marilyn Parker, a mutual friend of Rodham's and Mannerud's who 
attended the initial meeting between them, came back to 
Mannerud and told her that Rodham now wanted only $30,000 to 
help her obtain a pardon for her father. Mannerud was still 
concerned about the nature of Rodham's proposal and rejected 
it.

 The actions taken by Rodham and Parker may have been 
illegal. Rodham, and maybe Parker as well, engaged in an effort 
to defraud Mannerud. While the effort was unsuccessful, it may 
have constituted criminal conduct. The Committee recommends 
that the Justice Department investigate these allegations.

PRESIDENT CLINTON'S GRANT OF CLEMENCY TO DRUG MONEY LAUNDERER 
HARVEY WEINIG

Weinig was properly imprisoned for conspiring to launder 
millions of dollars in drug money and concealing and furthering 
an extortion-by-kidnapping scheme.

 Weinig, a former Manhattan attorney, conspired to 
launder about $19 million in drug proceeds through a Swiss bank 
for the Cali cartel. Members of the money laundering 
organization, of which Weinig was a part, boasted that they 
successfully laundered more than $70 million for the cartel. In 
addition to conducting banking transactions for the 
organization, Weinig consulted with co-conspirators in 
furtherance of the organization's activities and stored the 
drug proceeds in his New York City apartment.

 Weinig and other co-conspirators at his law firm 
stole from the Cali cartel about $2.5 million they were 
supposed to have laundered. This theft exposed Weinig's family 
to a risk of being harmed by those drug dealers. In the course 
of investigating the organization's money laundering 
activities, authorities intervened when they learned that the 
drug dealers sent a hit man to kill one of Weinig's co-
conspirators.

 Weinig learned that one of his co-conspirators 
kidnapped an individual as part of a scheme to extort money 
from the victim's family. Rather than report the kidnapping, 
Weinig made his office available as a meeting place where the 
ransom could be delivered and directed his associates at the 
firm to execute transfer agreements.

Weinig's lawyer, a prominent Washington attorney with close 
connections to the Clinton Administration, lobbied the White 
House in support of Weinig's clemency petition.

 Weinig's wife, Alice Morey, retained Reid 
Weingarten, who was close to the Clinton White House, to lobby 
for the commutation. In April 2000, Weingarten filed a clemency 
petition on Weinig's behalf with the Justice Department and the 
White House. Knowing that the Justice Department would advise 
the President to reject the Weinig commutation petition, 
Weingarten lobbied the White House directly, approaching White 
House Counsel Beth Nolan, Deputy White House Counsel Bruce 
Lindsey and Chief of Staff John Podesta.

 Weingarten chose not to familiarize himself with the 
facts of Weinig's underlying conviction. Accordingly, he was 
unable to convey to those he lobbied a full, accurate factual 
basis of the merits of Weinig's petition.

Two former Clinton Administration officials, David Dreyer and 
Harold Ickes, lobbied the White House on Weinig's behalf.

 Alice Morey enlisted the assistance of her cousin, 
former White House Deputy Communications Director David Dreyer. 
Dreyer repeatedly raised the Weinig commutation with John 
Podesta. Ultimately, Podesta recommended that the President 
grant the Weinig commutation. Dreyer has invoked his Fifth 
Amendment rights rather than cooperate with the Committee's 
investigation.

 Morey also obtained support for Weinig's commutation 
from former Deputy Chief of Staff Harold Ickes, whose children 
attended the same school as did her sons. Ickes discussed the 
Weinig case with President Clinton twice and recommended the 
commutation of Weinig's sentence.

The Justice Department repeatedly and adamantly recommended 
against the commutation of Weinig's sentence.

 On several occasions, U.S. Attorney Mary Jo White, 
whose office convicted Weinig, objected to any reduction of 
Weinig's sentence. Ultimately, in a report to President 
Clinton, the Pardon Attorney and Deputy Attorney General Eric 
Holder voiced their strong opposition to a commutation of 
Weinig's sentence.

 Pardon Attorney Roger Adams submitted a report to 
the President advising against the Weinig commutation. Adams 
pointed out that Weinig ``was a well-respected lawyer who used 
his professional skills to assist in laundering millions of 
dollars that he knew constituted the proceeds of a huge 
narcotics trafficking enterprise. He was involved in this 
activity for an extended period of time, and he admits that he 
engaged in it purely out of greed.'' Adams also informed the 
President that Weinig ``aided and abetted the extortion of 
money from an individual he knew had been kidnapped at the 
direction of a co-defendant in order to coerce the production 
of a ransom.''

After an apparently cursory review, the White House set aside 
the Justice Department's negative recommendation and granted 
Weinig clemency.

 Support for Weinig's petition from John Podesta and 
Beth Nolan appears to have been critical. The Associate White 
House counsels responsible for clemency matters did not support 
the petition. However, setting aside the negative 
recommendations of not only the Justice Department but also 
staff at the White House Counsel's Office, Nolan and Lindsey, 
who were lobbied by Weingarten, recommended Weinig's clemency 
to President Clinton. John Podesta, who was lobbied by 
Weingarten and Dreyer, also recommended to the President that 
Weinig's sentence be commuted.

The White House was unjustified in commuting Weinig's sentence.

 None of the arguments made by Weinig entitle him to 
executive clemency. In his petition, Weinig stated three main 
reasons why his sentence should have been commuted: (1) his 
sentence was disproportionate and excessive; (2) his 
contributions to society justified his early release from 
prison; and (3) one of his children was suffering emotional 
difficulties as a result of his imprisonment and needed him to 
return home. The first reason is simply not true. Weinig's 
sentence was comparable to those received by other co-
conspirators who were directly responsible for laundering large 
amounts of drug money and declined to cooperate with 
authorities. Weinig's sentence was also comparable to those 
received by co-defendants who participated in the extortion-by-
kidnapping scheme, which Weinig concealed and facilitated. The 
other two reasons fail to distinguish Weinig from the vast 
number of other similarly situated felons, who were properly 
sentenced but whose families have suffered because of their 
imprisonment.

President Clinton's commutation of Weinig's sentence has sent 
out the wrong message about the United States' commitment to 
fighting drug trafficking.

 President Clinton's decision conveyed an appearance 
of granting special consideration to wealthy, politically well-
connected criminals and their relatives. Pardon Attorney Roger 
Adams foresaw the message sent by the Weinig commutation, 
warning President Clinton that ``[t]o commute [Weinig's] prison 
term to the five years he proposes would denigrate the 
seriousness of his criminal misconduct, undermine the 
government's legitimate interest in encouraging prompt guilty 
pleas and truthful cooperation from criminal defendants, and 
could give the appearance of granting special consideration to 
economically advantaged, white-collar offenders.''

 The Weinig commutation undermines the nation's 
efforts to fight the illegal drug trade. Complaints are 
frequently made that U.S. drug laws punish low-level drug 
criminals too severely, yet do not punish high-level drug 
distributors enough. When a large-scale drug money launderer 
like Harvey Weinig receives executive clemency after serving 
five years of an eleven-year sentence, it sends the message 
that the U.S. is not serious about prosecuting the high-level 
criminals who make the drug trade possible.

 The Weinig commutation has eroded the United States' 
moral authority to press other countries to fight the drug 
trade within their own borders. The Weinig commutation could 
harm the efforts of the U.S. government to extradite drug 
traffickers and money launderers from Latin America. Newspapers 
in Latin American countries have accused the U.S. of hypocrisy 
in the Weinig case. For example, in Colombia's leading daily, 
former Colombian attorney general Gustavo De Greiff, in an op-
ed entitled ``The Morality of the Strongest,'' labeled 
President Clinton's clemency decision ``monstrous.''

                              INTRODUCTION

A. Why the Committee Investigated These Matters
    Unlike most other powers granted to the President by the 
Constitution, the power to grant executive clemency is 
virtually unchecked. Some have argued that because the power to 
grant clemency is unlimited, Congress has no oversight role 
over grants of executive clemency. The opposite is true. 
Because the President can grant clemency to whomever he wants 
for whatever reasons, it is critically important that certain 
grants of clemency be subject to Congressional and public 
scrutiny. If this scrutiny were not applied to grants of 
clemency, the power could easily be abused. As James Madison 
observed:

        A popular Government, without popular information, or 
        the means of acquiring it, is but a prologue to a Farce 
        or a Tragedy; or perhaps both. Knowledge will forever 
        govern ignorance: And a people who mean to be their own 
        Governors, must arm themselves with the power which 
        knowledge gives.\1\
---------------------------------------------------------------------------
    \1\ James Madison, The Writings of James Madison 103 (Gaillard Hunt 
ed., 9th ed. 1910).

While the grants of clemency issued by President Clinton will 
not, and cannot, be overturned by the Committee's 
investigation, this report can serve a valuable purpose to 
inform the public about President Clinton's abuse of power in 
issuing grants of clemency to so many undeserving individuals. 
The report can also serve as a reminder to future Presidents 
not to exercise their pardon power in such a reckless and 
corrupting fashion.
    Before President Clinton, when a President made 
controversial grants of clemency, he often provided a full 
accounting of his reasons for the decision. For example, when 
President Ford pardoned former President Nixon in 1974, 
President Ford made an unprecedented appearance before the 
House Judiciary Committee to explain his decision.\2\ When 
President George H.W. Bush pardoned Caspar Weinberger for his 
involvement in the Iran-Contra matter, he provided a full 
accounting of his decision in a public statement and released a 
number of documents dispelling any concerns that President 
Bush's pardon was meant to cover up his own involvement in the 
Iran-Contra matter.\3\ President Bush even consulted with 
prominent Democratic Members of Congress before issuing the 
Weinberger pardon to see if they would object.\4\ However, 
President Clinton issued a number of controversial pardons and 
commutations and failed to ever provide a satisfactory 
accounting for his decisions. Not only did he avoid 
consultation with Members of Congress, but President Clinton 
also avoided consultation with his own Justice Department and 
other knowledgeable agencies. Moreover, President Clinton has 
declined to answer any questions about his decisions, choosing 
instead to make occasional self-serving statements to friendly 
reporters.\5\
---------------------------------------------------------------------------
    \2\ ``Pardon of Richard M. Nixon and Related Matters,'' Hearing 
Before the House Comm. on the Judiciary, 93rd Cong. (Oct. 17, 1974).
    \3\ 57 Fed. Reg. 62,145 (1992).
    \4\ According to news reports, House Speaker Tom Foley, Chairman 
Les Aspin, and Senator Daniel Patrick Moynihan told President Bush that 
they would not object to the Weinberger pardon. Senator Moynihan even 
urged President Bush to grant a pardon to Iran-Contra figure Elliot 
Abrams, a former Moynihan aide. See Marjorie Williams, Burden of Proof, 
Wash. Post Mag., Apr. 11, 1993, at 6; Rowland Evans and Robert Novak, 
Bush Faces Fallout on Iran-Contra Pardons, Chi. Sun-Times, Dec. 30, 
1992, at 25.
    \5\ See, e.g., Rivera Live (CNBC television broadcast, Feb. 15, 
2001).
---------------------------------------------------------------------------
    President Clinton's abuse of the clemency power began with 
the August 11, 1999, grants of clemency to 16 terrorists who 
were part of the FALN and Macheteros terrorist network. When 
the Committee and the public understandably raised questions 
regarding these grants of clemency, President Clinton did 
nothing to answer those questions. Rather, he invoked executive 
privilege over 2,800 pages of documents which would have showed 
why he made his decision.\6\ When President Clinton did attempt 
to offer an explanation for the FALN clemency, it was factually 
inaccurate. Indeed, some documents indicated that the President 
made his decision for political benefit.\7\ For example, one 
document said that the release of the 16 terrorists would 
``have a positive impact among strategic Puerto Rican 
communities in the U.S. (read, voters).'' Another document 
stated: ``[t]he Vice President's Puerto Rican position would be 
helped.'' \8\
---------------------------------------------------------------------------
    \6\ Log of Documents Subject to Executive Privilege, noted in ``The 
FALN and Macheteros Clemency: Misleading Explanations, A Reckless 
Decision, A Dangerous Message,'' Hearing Before the Comm. on Govt. 
Reform, 106th Cong. 325-68 (Dec. 10, 1999).
    \7\ See generally ``The FALN and Macheteros Clemency: Misleading 
Explanations, A Reckless Decision, A Dangerous Message,'' Hearing 
Before the Comm. on Govt. Reform, 106th Cong. (Dec. 10, 1999).
    \8\ Id.
---------------------------------------------------------------------------
    In the final hours of his term, President Clinton issued 
141 pardons and 36 commutations.\9\ While other Presidents had 
issued controversial pardons and commutations, never before had 
a President made so many grants of clemency with so little 
justification. To understand the wholesale nature of the 
President's questionable clemency grants, it is useful to 
recall that he granted clemency to 13 individuals convicted in 
connection with independent counsel investigations of the 
Clinton Administration.\10\ Strong arguments could be made 
against all of these grants of clemency. The individuals who 
received these grants of clemency were convicted of serious 
crimes, and many of them played significant roles in major 
political scandals. For example, Susan McDougal was convicted 
of mail fraud, misapplication of funds, and false statements, 
and then was jailed on contempt of court charges for refusing 
to tell a grand jury whether President Clinton had testified 
truthfully at her trial. If Susan McDougal were not a close 
friend of the President, her pardon would be troubling enough. 
She was a convicted felon who defrauded a bank and defied the 
right of a grand jury to receive honest testimony. Considering 
that McDougal was a close friend of the President, who was 
jailed for contempt rather than testify against him, there is 
the indelible appearance that the pardon was a reward for 
McDougal's silence. Yet the Committee did not investigate the 
McDougal pardon or any of the other 12 pardons and commutations 
relating to independent counsel investigations. Neither did the 
Committee investigate the pardons and commutations granted to 
former Congressman Mel Reynolds,\11\ William Borders,\12\ or 
CIA Director John Deutch,\13\ all of which were subject to 
widespread criticism. Rather, the Committee limited its 
investigation to pardons and commutations where there was no 
credible explanation for the grant of clemency, and where there 
was an appearance of impropriety relating to inappropriate 
access or corruption. The fact that the Committee did not 
investigate pardons like Susan McDougal's speaks volumes about 
both the Committee's exercise of restraint and the severity of 
the abuses in those cases the Committee did investigate.
---------------------------------------------------------------------------
    \9\ Department of Justice Document Production DJ/PAO-MR-00009-23 
(List of Pardon and Commutation Grants, Jan. 20, 2001) (Exhibit 1).
    \10\ Individuals convicted in the Whitewater investigation and 
receiving pardons on January 20, 2001, were: Susan H. McDougal; Robert 
W. Palmer; Stephen A. Smith; and Christopher V. Wade. Individuals 
convicted in the investigation of former Agriculture Secretary Mike 
Espy and receiving pardons on January 20, 2001, were: Richard Douglas; 
Alvarez Ferrouillet; John Hemmingson; James H. Lake; Brook K. Mitchell, 
Sr.; and Jack L. Williams. Receiving a commutation for a conviction in 
the Espy case was Ronald Blackley. Individuals convicted in the 
Cisneros investigation and receiving pardons on January 20, 2001, were: 
Henry Cisneros and Linda Jones. In addition, Archibald Schaffer, a key 
defendant in the Espy investigation, received a pardon shortly before 
the end of the Clinton Administration, on December 22, 2000.
    \11\ Reynolds received a commutation for his federal convictions 
for bank fraud, wire fraud, false statements, and conspiracy to 
defraud. He also served time in prison for state convictions for sexual 
misconduct, obstruction of justice, and solicitation of child 
pornography. He is currently a registered sex offender in the state of 
Illinois. See Illinois Sex Offender Information (visited Mar. 4, 2002) 
 (listing Reynolds' registration as a 
sex offender).
    \12\ Borders was convicted for participating in a conspiracy to 
bribe federal judge Alcee Hastings. Borders refused to testify at 
Hastings' criminal trial or his impeachment hearings, which resulted in 
Borders' imprisonment for both contempt of court and contempt of 
Congress. By granting clemency to Borders, President Clinton violated 
his own standards as drafted by then-White House Counsel Jack Quinn. 
Quinn wrote that ``offenses involving central involvement in political 
corruption'' were among those President Clinton would not consider 
``under almost any circumstances.'' Arnold & Porter Document Production 
A0556-57 (Executive Clemency Policy, Jan. 26, 1996) (Exhibit 2).
    \13\ Deutch was accused of mishandling hundreds of highly 
classified documents, including information relating to covert actions, 
storing many on a home computer used to surf ``high risk'' sites on the 
internet, making the documents easily accessible to a hacker. Jerry 
Seper, Deutch Planned Guilty Plea Before Clinton Pardoned Him, Wash. 
Times, Jan. 25, 2001, at A3. Less than a day before receiving the 
pardon, Deutch had signed a plea agreement wherein he admitted a 
misdemeanor and agreed to pay a $5,000 fine. Vernon Loeb, Senate 
Committee Questions Clinton's Pardon of Deutch, Wash. Post, Feb. 16, 
2001, at A2.
---------------------------------------------------------------------------
    The Committee investigated two types of clemency grants. 
First was the case of Marc Rich and Pincus Green, which raised 
substantial questions of direct corruption, primarily whether 
pardons were issued in exchange for political and other 
financial contributions. The second group of cases involved 
indirect corruption, where close relatives of the President--
namely Roger Clinton, Hugh Rodham, and Tony Rodham--apparently 
traded on their relationships with the President to lobby for 
pardons and commutations. These cases raised serious concerns 
that Roger Clinton and the Rodhams used their access to the 
White House to lobby for pardons, in some cases successfully, 
and received large payments for their lobbying efforts.
    The Committee had three main purposes in its clemency 
investigation. First, as discussed above, the Committee sought 
to let the public know whether President Clinton had abused the 
clemency power. By subjecting the President's exercise of 
clemency to public scrutiny, the Committee hopes to make it 
clear to future Presidents that history will hold them 
accountable for clemency grants that are abusive. Second, the 
Committee sought to determine whether there are adequate 
safeguards in place to prevent individuals with close 
relationships with the President from trading on their access 
to win pardons. A number of the most troubling pardons granted 
by President Clinton were the result of lobbying from former 
White House staff like Jack Quinn or close relatives like Hugh 
Rodham. Third, the Committee examined whether there are 
adequate procedures in the pardon process to protect against 
abuse by the President. While the Justice Department has 
regulations governing its handling of applications for 
clemency, the President is free to ignore those regulations, 
and President Clinton did ignore them in the last month he was 
in office. The key lesson to be learned from the facts detailed 
in this report is that more disclosure is likely to remedy the 
problems in each of these three areas of concern. Public 
scrutiny after-the-fact may provide some deterrence, but a more 
open process before a grant of clemency is likely to be more 
effective. That is why the Committee moved legislation to 
require public disclosure of contributions to entities like the 
Clinton Library, given the potential effect of such 
contributions on policymaking decisions.\14\ Another example of 
potential legislation would be a clarification of the 
definition of ``lobbying'' under the Lobbying Disclosure 
Act.\15\ It could be amended to explicitly cover those who are 
paid to contact executive branch officials on behalf of 
clemency seekers.\16\ If Jack Quinn and Hugh Rodham had been 
required to disclose their status publicly as paid lobbyists 
seeking clemency for their clients, then Marc Rich and Carlos 
Vignali may not have been pardoned. The public outcry could 
have occurred beforehand and possibly prevented the damage done 
by these grants of clemency to public confidence in the 
integrity of government. Even if such a measure would not have 
prevented these particular grants of clemency, knowing who is 
paid to lobby for clemency would certainly assist future 
presidents in making appropriate decisions.
---------------------------------------------------------------------------
    \14\ As a result of the Committee's investigation into the Marc 
Rich and Pincus Green pardons, the Committee voted out H.R. 577, the 
Presidential Library Disclosure Act, a bill which ensures that 
contributions to presidential libraries are publicly disclosed. This 
bill was approved by the House of Representatives in a 392 to 3 vote on 
February 5, 2002, and is awaiting action in the Senate.
    \15\ 2 U.S.C. Sec. 1602(8)(a) currently defines a ``lobbying 
contact'' as:
---------------------------------------------------------------------------
        G. . any oral or written communication . . . to a covered 
      executve branch official . . . that is made on behalf of a 
      client with regard to--
          G(i) the formulation, modification, or adoption of 
      Federal legislation (including legislative proposals);
          G(ii) the formulation, modification, or adoption of a 
      Federal rule, regulation, Executive order, or any other 
      program, policy, or position of the United States 
      Government;
          G(iii) the administration or execution of a Federal 
      program or policy (including the negotiation, award, or 
      administration of a Federal contract, grant, loan, permit, 
      or license);
          Gor (iv) the nomination or confirmation of a person for 
      a position subject to confirmation by the Senate.
---------------------------------------------------------------------------
    \16\ 2 U.S.C. Sec. 1602(8)(b)(xii) currently contains an exception 
for ``a communication that is . . . made to an official in an agency 
with regard to . . . a judicial proceeding or a criminal or civil law 
enforcement inquiry, investigation, or proceeding.'' This exception 
could arguably exclude lobbying for clemency from the statute's 
disclosure requirements. But see In re Grand Jury Subpoenas, 179 F. 
Supp. 270 (S.D.N.Y., Mar. 9, 2001) (holding that ``the pardon process 
was not adversarial'' in the Marc Rich case, that his lawyers were 
``acting principally as lobbyists,'' and that they were, therefore, not 
entitled to withhold certain documents under the attorney-client 
privilege).
---------------------------------------------------------------------------
B. President Clinton Deviated From All Applicable Standards
    In his rush to grant pardons and commutations in the waning 
hours of his presidency, Bill Clinton ignored almost every 
applicable standard governing the exercise of the clemency 
power. There were three obvious sources of guidance regarding 
the exercise of the power. First, the Justice Department had 
published guidelines regarding its handling of clemency 
petitions. While these guidelines were not binding upon the 
President, they should have provided guidance to the Justice 
Department and the President. At a minimum, they provide a 
mechanism to provide the President with relevant information. 
The Justice Department guidelines state first that pardon 
petitions should not be filed until five years after the 
petitioner is released from prison, or, if no prison time is 
served, five years after the date of conviction.\17\ The 
guidelines also state that commutation petitions should not be 
filed while there are other forms of judicial or administrative 
relief, like appeals, still available.\18\
---------------------------------------------------------------------------
    \17\ 28 C.F.R. Sec. 1.2 (2002).
    \18\ 28 C.F.R. Sec. 1.3 (2002).
---------------------------------------------------------------------------
    The U.S. Attorney's Manual also contains detailed standards 
applied to clemency petitions by the Pardon Attorney's Office. 
The Manual lists five standards applicable to the review of 
pardon petitions:

        1. Post-conviction conduct, character, and reputation.

        An individual's demonstrated ability to lead a 
        responsible and productive life for a significant 
        period after conviction or release from confinement is 
        strong evidence of rehabilitation and worthiness for 
        pardon.

                                *  *  *

        2. Seriousness and relative recentness of the offense.

        When an offense is very serious (e.g., a violent crime, 
        major drug trafficking, breach of public trust, or 
        white collar crime involving substantial sums of 
        money), a suitable length of time should have elapsed 
        in order to avoid denigrating the seriousness of the 
        offense or undermining the deterrent effect of the 
        conviction. In the case of a prominent individual or 
        notorious crime, the likely effect of a pardon on law 
        enforcement interests or upon the general public should 
        be taken into account.

                                *  *  *

        3. Acceptance of responsibility, remorse, and 
        atonement.

        The extent to which a petitioner has accepted 
        responsibility for his or her criminal conduct and made 
        restitution to its victims are important 
        considerations. A petitioner should be genuinely 
        desirous of forgiveness rather than vindication. While 
        the absence of expressions of remorse should not 
        preclude favorable consideration, a petitioner's 
        attempts to minimize or rationalize culpability does 
        not advance the case for pardon.

                                *  *  *

        4. The need for relief.

        The purpose for which a pardon is sought may influence 
        disposition of the petition. A felony conviction may 
        result in a wide variety of legal disabilities under 
        state or federal law, some of which can provide 
        persuasive grounds for recommending a pardon.

                                *  *  *

        5. Official recommendations and reports.

        The comments and recommendations of concerned and 
        knowledgeable officials, particularly the United States 
        Attorney whose office prosecuted the case and the 
        sentencing judge, are carefully considered. The likely 
        impact of favorable action in the district or 
        nationally, particularly on current law enforcement 
        priorities, will always be relevant to the President's 
        decision.\19\
---------------------------------------------------------------------------
    \19\ U.S. Attorney's Manual 1-2.112.

The U.S. Attorney's manual also contains standards for the 
---------------------------------------------------------------------------
consideration of commutation petitions:

        Generally, commutation of sentence is an extraordinary 
        remedy that is rarely granted. Appropriate grounds for 
        considering commutation have traditionally included 
        disparity or undue severity of sentence, critical 
        illness or old age, and meritorious service rendered to 
        the government by the petitioner, e.g., cooperation 
        with investigative or prosecutive efforts that has not 
        been adequately rewarded by other official action.\20\
---------------------------------------------------------------------------
    \20\ U.S. Attorney's Manual 1-2.113.

    A second source of guidance comes from a 1996 memorandum 
from then-White House Counsel Jack Quinn to Deputy Attorney 
General Jamie Gorelick and Pardon Attorney Margaret Colgate 
Love. In this memorandum, Quinn issued a number of directives 
from President Clinton regarding the exercise of his clemency 
authority. Quinn first stated that the ``President intends to 
continue to rely greatly on your joint recommendations 
regarding clemency applications.'' Quinn also stated that 
President Clinton had identified a number of factors in 
addition to those listed in the U.S. Attorney's Manual, which 
he wanted considered as part of the review of clemency 
petitions:
    The following circumstances would weigh in favor of 
granting clemency:

        1. Indications that the crime for which clemency is 
        sought was truly abberational, i.e., a lone instance of 
        criminal behavior in an otherwise exemplary life.

        2. Cases committed long ago when the individual was 
        very young and which do not involve major crimes.

        3. Cases not involving major crimes in which the 
        individual has clearly turned his or her life around by 
        making sustained and significant contributions to the 
        community since being released from prison.

        By contrast, in certain cases, even extraordinarily 
        exemplary actions post-conviction may not merit the 
        remedy of executive clemency. These cases might 
        include:

        1. The commission of major crimes: There are categories 
        of crimes which are so serious that the President will 
        not consider granting a pardon for them under almost 
        any circumstances. Such crimes would include large-
        scale drug trafficking, sex offenses involving minors, 
        offenses involving central involvement in political 
        corruption, or violent crimes such as murder or rape.

        2. An extensive criminal history: Three or more 
        separate convictions should raise a substantial 
        presumption against granting a pardon with respect to 
        any one of them. This presumption would only be 
        overcome by a truly exceptional rehabilitative history 
        involving exemplary service to the individual's 
        community or country.\21\
---------------------------------------------------------------------------
    \21\ Arnold & Porter Document Production A0556-57 (Memorandum from 
Jack Quinn to Jamie Gorelick (Jan. 26, 1996)) (Exhibit 2).

    The final source of guidance regarding the exercise of the 
President's clemency power is, of course, the President's own 
personal views. In 1996, President Clinton was asked if he was 
considering a pardon for Susan McDougal and other Whitewater 
---------------------------------------------------------------------------
defendants. He responded:

        [M]y position would be that their cases should be 
        handled like others . . . there's a regular process for 
        that, and I have regular meetings on that. And I review 
        those cases as they come up and after there's an 
        evaluation done by the Justice Department, and that's 
        how I think it should be handled.\22\
---------------------------------------------------------------------------
    \22\ The NewsHour with Jim Lehrer (PBS television broadcast, Sept. 
23, 1996).

    Therefore, the President suggested that the McDougal case, 
and all others, would be handled according to the ``regular 
process,'' including screening by the Justice Department.
    As to the President's claim that he would follow the 
``regular process,'' he granted clemency to 30 individuals who 
had not even filed clemency petitions with the Justice 
Department,\23\ and some who had not filed any petition at all, 
not even with the White House.\24\ The President also granted 
clemency to 14 individuals who had their petitions previously 
denied and thus were not pending with the Justice 
Department.\25\ Even more important, in a number of cases, 
President Clinton dramatically deviated from the ``regular 
process'' of seeking the Justice Department's input.
---------------------------------------------------------------------------
    \23\ Letter from Sheryl Walter, Office of Legislative Affairs, 
Department of Justice, to the Honorable Dan Burton, Chairman, Comm. on 
Govt. Reform (Feb. 6, 2001) (Exhibit 3).
    \24\ The Committee has not attempted to discover every single case 
where clemency was granted without a clemency petition being filed. 
However, it has been reported that a number of individuals who were 
convicted in connection with independent counsel investigations, for 
example, Richard Douglas, Alvarez Ferrouillet, John Hemmingson, James 
H. Lake, Brook K. Mitchell, Sr., Jack L. Williams, Ronald Blackley, 
Henry Cisneros, and Linda Jones all received grants of clemency without 
having filed a petition with either the White House or the Justice 
Department. See Weston Kosova, Running on Fumes: Pulling All-Nighters, 
Bill Clinton Spent His Last Days Obsessing Over Details and Pardons, 
Newsweek, Feb. 26, 2001, at 30.
    \25\ Letter from Sheryl Walter, Office of Legislative Affairs, 
Department of Justice, to the Honorable Dan Burton, Chairman, Comm. on 
Govt. Reform (Feb. 6, 2001) (Exhibit 3).
---------------------------------------------------------------------------
    Many of the President's last-minute grants of clemency 
violated all of these standards. Marc Rich and Pincus Green, 
for example, fail all five Justice Department criteria for 
pardons. They did not demonstrate responsible behavior after 
their indictment. Rather, by all accounts, they have remained 
fugitives from justice and continued to engage in business 
relations with the enemies of the United States. Their offenses 
were serious and notorious crimes for which, according to the 
Justice Department, a suitable length of time should pass 
between conviction and pardon. Yet Rich and Green never even 
stood trial. Rich and Green did not demonstrate any 
responsibility, remorse, or atonement for their crimes. Rather, 
they maintained that they were ``singled out'' and unfairly 
prosecuted. Rich and Green had no real need for relief. They 
lived in luxury and apparently sought the pardons only so that 
they could travel freely around the world, without the fear of 
being apprehended by the U.S. Marshals Service in countries 
that were cooperating with U.S. efforts to apprehend them. 
Finally, there were no official recommendations or reports 
regarding the Rich and Green pardons, since the White House 
circumvented the normal pardon review process. If there had 
been such reports, however, it is safe to assume that the U.S. 
Attorney's office would have strongly objected to the Rich and 
Green pardons.
    The other grants of clemency reviewed in this report also 
fail to meet the applicable standards. Carlos Vignali satisfies 
none of the appropriate grounds for commutation identified in 
Justice Department regulations, as his sentence was not 
disparate or unfair, and he did not cooperate with law 
enforcement. As a large-scale drug dealer, Vignali also was not 
eligible for clemency under the President's own guidelines of 
1996. Harvey Weinig similarly failed all relevant standards, 
having been sentenced fairly and having never cooperated with 
law enforcement. Weinig, as a large-scale money launderer for 
the Cali Cartel, also was ineligible for clemency under the 
President's guidelines. Glenn Braswell clearly failed to meet 
the standards for a pardon, as he was under active 
investigation for new criminal acts at the time he received a 
pardon. Edgar and Vonna Jo Gregory similarly fell short of the 
applicable standard, having committed one of the largest bank 
frauds in Alabama history. Moreover, prosecutors objected to 
the Gregory pardons.
C. Individuals Close to President Clinton Used Their Influence to Lobby 
        for Undeserved Grants of Clemency
    One of the most disturbing aspects of the closing month of 
President Clinton's term in office is that a number of people 
close to the President used their relationship with him to 
lobby for clemency grants which ordinarily would not have been 
considered. While there are certainly individuals who would 
seek to abuse their access in any administration, never have 
they been so successful as in the Clinton Administration. Jack 
Quinn abused his relationship with the President to lobby for 
the pardons of Marc Rich and Pincus Green. There can be little 
doubt that these pardons would not have been issued if Jack 
Quinn had not exploited his position as former White House 
Counsel. Hugh Rodham successfully lobbied the President for 
grants of clemency to Carlos Vignali and Glenn Braswell. Tony 
Rodham successfully lobbied the President to grant pardons to 
Edgar and Vonna Jo Gregory. David Dreyer, a former White House 
staffer, lobbied the President to grant a commutation to his 
cousin, Cali cartel money launderer Harvey Weinig.
    It is clear that none of these grants of clemency would 
have been issued on the merits. Marc Rich and Pincus Green were 
fugitives from justice, indicted for the largest tax evasion 
scheme in U.S. history and for selling oil to Iran while 
Americans were being held hostage. Carlos Vignali was the 
source of cocaine for a major drug dealing ring. Glenn Braswell 
was an extremely successful con artist who was actually under 
criminal investigation at the time he received his pardon from 
President Clinton. Edgar and Vonna Jo Gregory had been 
convicted for the largest bank fraud in Alabama history. Harvey 
Weinig laundered millions of dollars for the Cali cartel and 
participated in a kidnapping, and was only caught when he began 
to steal money from the Cali cartel. Only by capitalizing on 
relationships between President Clinton and individuals close 
to him were these petitioners able to obtain grants of 
clemency.
D. A Number of Potential Violations of Law Have Been Discovered by the 
        Committee
    In the course of its investigation, the Committee has 
learned of a number of potential violations of law by Roger 
Clinton and Tony Rodham. The Committee recommends that the 
Department of Justice review these matters in conjunction with 
the ongoing criminal investigation being conducted by the U.S. 
Attorney for the Southern District of New York.
    The Committee has uncovered a number of potential criminal 
acts by Roger Clinton. First, Roger Clinton may have imported 
more than $10,000 in monetary instruments into the United 
States without properly disclosing it to the Customs Service. 
Clinton received substantial sums of money originating from 
overseas between 1998 and 2000. If Clinton imported this money 
into the United States, then he was required to report it to 
proper authorities and apparently did not do so. Second, Roger 
Clinton appears to have violated the Lobbying Disclosure Act. 
There is evidence that Roger Clinton lobbied the President 
regarding travel restrictions to Cuba. Clinton did not register 
as a lobbyist, despite the fact that he was likely required to 
do so. Third, Clinton lied to FBI agents who interviewed him 
regarding his lobbying for Rosario Gambino in 1999. When they 
interviewed Roger Clinton, he claimed that ``he did not 
represent to anyone on the Parole Commission that his brother 
was aware of his efforts to assist the Gambino family.'' \26\ 
However, when Clinton lobbied the U.S. Parole Commission, he 
had explicitly stated that his brother was ``completely aware'' 
of his involvement.\27\ Roger Clinton also lied to the FBI 
about a $50,000 payment from the Gambino family.\28\ Although 
he deposited the payment the same day as the FBI interview, he 
did not disclose it to the agents explicitly or truthfully. 
Rather he claimed that Rosario Gambino's son had offered to 
loan him money for a down payment on a house.\29\ Despite this 
claim to the FBI, which Clinton repeated to the media in the 
summer of 2001, bank records indicate that Clinton neither used 
the $50,000 for a down payment nor did he ever repay any of the 
money. During the interview, Clinton also told three separate 
and contradictory stories when questioned about a Rolex watch 
he received from the Gambinos.\30\
---------------------------------------------------------------------------
    \26\ Department of Justice Document Production FBI-RC-00003 
(Summary of Interview with Roger Clinton, Oct. 1, 1999) (Exhibit 4).
    \27\ USPC Document Production 00894 (Memorandum from Michael A. 
Stover, General Counsel, U.S. Parole Commission, to File (Jan. 31, 
1996)) (Exhibit--5); Telephone Interview with Thomas Kowalski, Case 
Operations Manager, U.S. Parole Commission (July 27, 2001). Roger 
Clinton made it clear to Parole Commission staff on multiple occasions 
that President Clinton had specific knowledge that he was contacting 
the Parole Commission regarding Rosario Gambino. See generally, Chapter 
Two: Roger Clinton's Involvement in Lobbying for Executive Clemency, 
Section II.E.1., ``Roger Clinton's Statements Regarding his Brother's 
Knowledge.''
    \28\ See generally, Chapter Two: Roger Clinton's Involvement in 
Lobbying for Executive Clemency, Section II.E.2., ``Roger Clinton's 
Statements Regarding Payment from the Gambinos.''
    \29\ Department of Justice Document Production FBI-RC-00005-06 
(Summary of Interview with Roger Clinton, Oct. 1, 1999) (Exhibit 4).
    \30\ The interviewing FBI agents apparently were not satisfied with 
Roger Clinton's candor during the interview, as they took the unusual 
step of explaining to Clinton the penalties for making false statements 
during the course of the interview. Id. at FBI-RC-00006. See generally, 
Chapter Two: Roger Clinton's Involvement in Lobbying for Executive 
Clemency, Section II.E.3., ``Roger Clinton's Statements Regarding the 
Rolex Watch.''
---------------------------------------------------------------------------
    The Committee has also learned about Tony Rodham's 
participation in a scheme to defraud Vivian Mannerud in 
connection with Mannerud's effort to obtain a commutation for 
her father, Fernando Fuentes Coba. Tony Rodham was introduced 
to Mannerud by his business partner, Marilyn J. Parker. 
Together, Rodham and Parker attempted to convince Mannerud to 
hire Rodham to help her obtain a commutation for her father. In 
making his pitch to Mannerud, Rodham made a number of false 
statements to Mannerud, including the assertion that he was 
friendly with Pardon Attorney Roger Adams, and that he would 
hire a law firm at which Adams' wife was a partner. Rodham then 
asked Mannerud to pay him $50,000 to help with the Fernando 
Fuentes Coba commutation effort. After Mannerud refused, 
Marilyn Parker called Mannerud to tell her that Rodham now only 
wanted $30,000 to help with the Fuentes commutation. Mannerud 
declined both offers for fear of being involved in some 
improper activity. The activity by Rodham and Parker may amount 
to a criminal conspiracy to defraud Vivian Mannerud. Whether or 
not the conduct by Rodham and Parker amounts to criminal 
activity depends greatly upon the specific evidence that can be 
gathered by the Justice Department. However, it is clear that 
this matter deserves thorough investigation by the Department 
of Justice.
E. The Message Sent by President Clinton's Grants of Clemency
    The way in which a President exercises the clemency power 
speaks volumes about that President's priorities. The clemency 
grants reviewed in this report send a clear message, one that 
does not speak well of President Clinton. While the clemency 
power is vitally important and should be used by the President, 
it should not be debased, particularly where large sums of 
money are flowing to relatives of the President or to 
foundations in which he has a significant interest.
    First, President Clinton granted pardons and commutations 
to individuals who never would have received clemency but for 
the fact that they hired individuals close to the President to 
represent them. Marc Rich, Pincus Green, Carlos Vignali, Glenn 
Braswell, Edgar Gregory, and Vonna Jo Gregory were all 
extremely wealthy and were able to hire Jack Quinn, Tony 
Rodham, and Hugh Rodham to lobby the White House and short-
circuit the normal clemency review procedures. The average low-
income criminal defendant does not have the money necessary to 
hire a White House insider to lobby for his pardon. At best, he 
can fill out his clemency application and watch it proceed 
through the normal Justice Department review process. By 
listening to the advice of highly-paid White House insiders 
like Jack Quinn, Hugh Rodham, and Tony Rodham, and by granting 
clemency to their clients, President Clinton has sent the 
message that he had two standards of justice--one for the rich, 
and one for the poor. Representative Elijah Cummings described 
some of his concerns about this issue at the Committee's 
February 8, 2001, hearing:

        One of the things that concerns me about [the Rich] 
        pardon is that I think anybody who is sitting in this 
        audience or anybody who is watching this at home, you 
        know, when the little guy, when the Department of 
        Justice comes after the little guy, the guys that I 
        used to represent, they tear their lives apart, I mean 
        rip them apart. They can't afford the Mr. diGenovas, 
        the great lawyers, as he is and others. They do the 
        best they can. They spend all of their money. Their 
        reputations are tarnished. Even if they're found not 
        guilty, friends are brought in, FBI goes into their 
        homes, subpoenas are issued.

        And when people look at Mr. Rich and others who 
        apparently goes off to another country, they've got the 
        money to do so, and it appears as if they're evading 
        the process. The little guys that I represent and the 
        women, you know, they really have a problem with that, 
        because they sit here and they say, wait a minute, you 
        know, I'm sitting in jail for 20 years. And it does not 
        even compare. I mean, I may have done one-millionth of 
        what was allegedly done here, but I'm sitting in jail. 
        And I didn't have the money to go off somewhere else. I 
        didn't have the money to do that. I didn't have the 
        money to hire the big-time lawyers. So it does concern 
        me.

                                *  *  *

        And it's one thing to go to trial. It's one thing to 
        stay here and face the music. It's one thing to be 
        found not guilty. It's a whole other thing, in my 
        opinion, when somebody, because they have the money, 
        can go outside the country and evade the system. I tell 
        you it really concerns me because my constituents have 
        a major problem with that, and I do, too.\31\
---------------------------------------------------------------------------
    \31\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 164-65 
(Feb. 8, 2001) (statement of the Honorable Elijah Cummings).

These concerns are shared by many on the Committee.
    President Clinton's pardons did not just send the message 
that he believes in two standards of justice. By pardoning 
fugitives from justice, President Clinton undermined the 
efforts of law enforcement officers everywhere. Since 1983, 
Assistant United States Attorneys and agents of the United 
States Marshals Service have been trying to apprehend Marc Rich 
and Pincus Green. They listed Rich as one of the most wanted 
fugitives in the world. They set up sting operations to arrest 
Rich overseas. They have submitted arrest requests and 
extradition requests to a number of foreign countries. 
President Clinton's pardon of wanted fugitives is a direct slap 
in the face to the U.S. law enforcement officers who spent 
almost two decades trying to apprehend Rich. The pardons also 
could serve to undermine U.S. efforts to extradite fugitives in 
the future.
    By commuting the sentences of Carlos Vignali and Harvey 
Weinig, President Clinton undermined U.S. efforts to fight the 
flow of illegal drugs into the country. Neither was a minor 
participant in drug trafficking. Vignali supplied cocaine to 
the largest drug-dealing ring in Minnesota history. Moreover, 
he never cooperated with law enforcement and failed to reveal 
where he obtained his cocaine. Harvey Weinig laundered millions 
of dollars for the Cali cartel. Without individuals like Harvey 
Weinig, drug traffickers would not be able to enjoy the 
proceeds from their drug sales. Despite the seriousness of 
their crimes, President Clinton commuted the sentences of both 
Vignali and Weinig.
    The message of these commutations was loud and clear. Tony 
Adams, a narcotics detective in Minnesota, spoke eloquently to 
the meaning of the Vignali commutation. Adams stated that he 
was stunned to learn of the commutation: ``It's like, 
basically, you've just been told that this kid, he's 
untouchable.'' \32\ Adams observed that the Vignali case ``more 
or less tells us that America's system has been bought if you 
have money.'' \33\ He also observed that ``politicians always 
get in front of this camera and say ``We're trying to take dope 
off the streets. We're trying to put dope dealers in jail.'' 
Well, you just let one out, a big one.'' \34\ Finally, Adams 
suggested that ``the politicians in L.A. or Washington, D.C., 
should finish the nine years that [Vignali] has left on his 
time, and I'm standing right by that.'' \35\ Adams is certainly 
not alone in his criticism of the Vignali commutation, but his 
comments are particularly noteworthy, coming from a detective 
who investigated the case, and who routinely places his life on 
the line to protect the public from drug traffickers.\36\
---------------------------------------------------------------------------
    \32\ Richard A. Serrano and Stephen Braun, Working the American 
System, L.A. Times, Apr. 29, 2001, at 10.
    \33\ Fox Special Report with Brit Hume (Fox News television 
broadcast, Feb. 27, 2001).
    \34\ Nightline (ABC News television broadcast, Feb. 23, 2001).
    \35\ Fox Special Report with Brit Hume (Fox News television 
broadcast, Feb. 23, 2001).
    \36\ While conducting plainclothes surveillance in April 2001, 
Adams was shot at by a suspect and escaped uninjured. David Chanen, Man 
Fires at Officer, But Nobody is Hurt, Star Trib. (Minneapolis, MN), 
Apr. 20, 2001, at 9B.
---------------------------------------------------------------------------
    The Weinig case has sent no less a destructive message to 
U.S. law enforcement. In fact, the Weinig commutation has 
created a great deal of consternation in Latin American nations 
from which the U.S. is attempting to extradite drug kingpins. 
Many individuals in these nations have argued that they should 
not extradite their citizens to the U.S. for narcotics offenses 
because the U.S. clearly is not serious about enforcing its 
narcotics laws, pointing specifically to the Weinig 
commutation.\37\ By pardoning a major money launderer for the 
Cali cartel, President Clinton has made it harder for the U.S. 
to extradite drug traffickers to the U.S. and harder to fight 
the war on drugs.
---------------------------------------------------------------------------
    \37\ See Colombian General Hits Clinton Commutation, Wash. Times, 
Mar. 6, 2001, at A13; Russell Crandall, The Americas: In the War on 
Drugs, Colombians Die, Americans Are Pardoned, Wall St. J., Apr. 20, 
2001, at A15.
---------------------------------------------------------------------------
F. Obstacles Faced by the Committee
    The Committee conducted a thorough investigation, 
interviewing dozens of witnesses. The majority of parties 
contacted by the Committee cooperated with the investigation. 
However, a number of key individuals refused to cooperate, 
which in turn seriously hampered the Committee's investigation.
            1. Witnesses Who Have Not Cooperated with the Investigation
    The Committee has faced a number of obstacles that have 
prevented it from discovering the full truth regarding the 
pardon and commutations which it investigated. The greatest 
problem faced by the Committee was that a number of key 
witnesses invoked their Fifth Amendment rights or otherwise 
refused to cooperate with the Committee's investigation. A 
total of 26 witnesses either invoked their Fifth Amendment 
rights or refused to be interviewed in the course of the 
Committee's investigation. Some of these witnesses, like Marc 
Rich, Denise Rich, Beth Dozoretz, and Roger Clinton, were 
critically important. The impact of the refusal of key 
witnesses to cooperate is discussed below in the relevant 
chapters regarding each part of the investigation.
    Another significant problem the Committee has faced is the 
refusal of a number of parties to produce records subpoenaed or 
requested by the Committee. A number of document requests 
issued by the Committee have not been complied with by their 
recipients, either because of an invocation of Fifth Amendment 
rights or an invocation of attorney-client privilege. In some 
cases, the invocation of privilege has been spurious. For 
example, Hugh Rodham refused to produce any records regarding 
the Vignali matter because of the attorney-client privilege. 
Obviously, Rodham possesses records which are not privileged, 
which he could provide to the Committee, however, he simply 
declined to do so.\38\ This refusal adversely impacted the 
ability of the Committee to develop a full understanding of 
Rodham's work on the Vignali matter. The specific problems 
faced by the Committee in each aspect of the pardon 
investigation are discussed below in the relevant chapters 
regarding each pardon and commutation.
---------------------------------------------------------------------------
    \38\ Such records would include records provided to Rodham by third 
parties and documents which Rodham provided to third parties.
---------------------------------------------------------------------------
            2. The White House
    It is a matter of some concern that the Bush White House 
and Justice Department failed to cooperate fully with the 
Committee's investigation. Early in its investigation of the 
Marc Rich pardon, the Chairman requested that former President 
Clinton waive any claim of executive privilege he might have 
over testimony and documents relating to the pardons and 
commutations he granted.\39\ On February 27, 2001, former 
President Clinton's attorney, David Kendall, sent the Chairman 
a letter in which he informed the Committee that ``he will 
interpose no Executive Privilege objections to the testimony of 
his former staff concerning these pardons, or to other pardons 
and commutations he granted.'' \40\ Despite former President 
Clinton's decision to waive executive privilege, the Committee 
faced a number of problems receiving records relating to the 
pardons and commutations, both from the White House and the 
Justice Department.
---------------------------------------------------------------------------
    \39\ Letter from the Honorable Dan Burton, Chairman, Comm. on Govt. 
Reform, to former President William J. Clinton (Feb. 15, 2001) (Exhibit 
6).
    \40\ Letter from David E. Kendall, Counsel for President Clinton, 
Williams & Connolly, to the Honorable Dan Burton, Chairman, Comm. on 
Govt. Reform (Feb. 27, 2001) (Exhibit 7). In addition to waiving any 
claim of privilege with respect to the testimony of his former staff, 
President Clinton has not raised executive privilege with respect to 
any of the records the Committee has requested from the National 
Archives.
---------------------------------------------------------------------------
    Beginning on January 25, 2001, the Committee issued a 
series of document requests to the National Archives and 
Records Administration (``NARA''), seeking records relating to 
pardons and commutations issued or considered by former 
President Clinton. Under the Presidential Records Act, once the 
responsive records were located by NARA staff, they were 
provided to staff for former President Clinton to be reviewed 
for executive privilege concerns.\41\ After President Clinton's 
staff had reviewed them, the records were reviewed by staff for 
President Bush, who independently has the right to assert 
executive privilege over the records. The Committee's first 
requests to NARA for records relating to Marc Rich and Pincus 
Green were satisfied. However, shortly thereafter, the 
Committee began to have significant problems receiving the 
records it had requested from NARA.
---------------------------------------------------------------------------
    \41\ See 44 U.S.C. Sec. 2204 (2002).
---------------------------------------------------------------------------
    On March 8, 2001, the Committee issued a request to NARA 
for records relating to the pardons and commutations of a 
number of individuals--including Glenn Braswell, Carlos 
Vignali, Edgar and Vonna Jo Gregory, and Eugene and Nora Lum--
as well as records relating to Roger Clinton's involvement in 
lobbying for pardons. The Committee's request called for the 
records to be provided to the Committee by March 22, 2001. At 
some point in April 2001, NARA had gathered all of the 
responsive documents, and they had been reviewed and cleared by 
the office of former President Clinton. However, they had not 
been provided to the Committee because of objections from the 
Bush White House Counsel's Office.\42\
---------------------------------------------------------------------------
    \42\ Notes of Telephone Conversation with Amy Krupsky, Associate 
General Counsel, National Archives and Records Administration (May 1, 
2001).
---------------------------------------------------------------------------
    Committee staff spent the next month engaged in fruitless 
negotiations with the Bush White House regarding the production 
of the requested records. Staff from the Bush White House 
explained that they had concerns about producing the requested 
records, because the records went to the heart of the clemency 
review process, which was part of a core Presidential power. 
During these negotiations, Committee staff pointed out that the 
White House had been delaying the production of a wide variety 
of records from NARA, including documents sent into the White 
House from individuals seeking pardons, and that these records 
could not possibly raise any privilege concerns. The White 
House agreed to provide these types of non-deliberative records 
to the Committee.\43\
---------------------------------------------------------------------------
    \43\ The White House did not agree to provide records provided to 
the White House from third parties until June 6, 2001. It is unclear 
why these types of records, which were clearly not privileged, were 
withheld from the Committee for so long. The delay in the production of 
these records--which did not occur until three months after they were 
requested--imposed a substantial delay on the Committee's 
investigation.
---------------------------------------------------------------------------
    However, the White House was not nearly so accommodating 
with respect to deliberative documents about the clemency 
process that were generated inside of the Clinton 
Administration. White House staff informed the Committee staff 
that the White House did not plan to assert executive privilege 
over these records but would simply decline to produce them and 
hope that the Committee understood the reasons why. Committee 
staff attempted to explain that a number of these records were 
critically important to the Committee's investigation. For 
example, the report prepared by Pardon Attorney Roger Adams 
regarding the Vignali commutation was central to the 
Committee's understanding of the Vignali matter. Committee 
staff also offered to reach a number of compromise 
accommodations, which would satisfy the Committee's needs to 
review the Adams memo, while still protecting the White House's 
interests. All of these offers were rejected. The White House's 
refusal to reach any accommodation meant that the Committee was 
unable to obtain a number of key documents regarding pardons 
and commutations issued by President Clinton.
    On June 7, 2001, shortly after the Committee's offers to 
the White House were rejected, the Committee received a 
production of records from NARA. This production apparently 
included both deliberative and non-deliberative records 
responsive to the Committee's March 8, 2001, request. 
Approximately two weeks later, Committee staff informed the 
White House that NARA had provided the Committee with a number 
of records that the White House may have intended to withhold 
from the Committee. Shortly thereafter, the Committee received 
a telephone call and then a letter from the NARA General 
Counsel, Gary Stern, requesting the return of the documents. In 
his letter, Stern stated that ``some of the records that were 
provided to the Committee were inadvertently produced. 
Accordingly, we now request the return of these records, and 
any copies made thereof.'' \44\
---------------------------------------------------------------------------
    \44\ Letter from Gary Stern, General Counsel, NARA, to Jim Wilson, 
General Counsel, Comm. on Govt. Reform (June 21, 2001) (Exhibit 8).
---------------------------------------------------------------------------
    However, for several reasons, the Committee decided not to 
return the records in response to Stern's request. First, the 
records were responsive to the Committee's request and, 
therefore, should have been produced in any event. Second, 
neither President Bush nor President Clinton asserted any 
privilege over the documents. In the absence of a valid claim 
of privilege, the Committee has a right to receive documents 
responsive to its request. Third, even if President Bush or 
President Clinton had asserted executive privilege, the 
Committee might have determined to keep certain essential 
records produced by NARA on June 7, 2001. A number of these 
records were critical to the Committee's investigation and did 
not raise legitimate executive privilege concerns. However, 
since neither the current nor the former President raised any 
such privilege, the Committee used these documents in its 
investigation and in this report.
    The documents that were ``inadvertently'' produced to the 
Committee were of central importance to the Committee's 
investigation. The following is a brief description of some of 
the records included in that production:

 All White House records regarding the Vignali 
commutation: These records included the report by Pardon 
Attorney Roger Adams objecting to the Vignali commutation.\45\ 
This report was of critical importance to the Committee, as it 
showed the extent to which the Clinton White House was aware of 
Carlos Vignali's criminal activities. These records also 
included one White House document indicating that Hugh Rodham 
had informed the White House staff that the Vignali commutation 
was ``very important'' to First Lady Hillary Clinton.\46\
---------------------------------------------------------------------------
    \45\ See NARA Document Production (Report to the President on 
Proposed Denial of Executive Clemency for Carlos Anibal Vignali, Jr., 
Jan. 12, 2001) (Exhibit 9).
    \46\ See NARA Document Production (Note from Dawn Woolen, 
Administrative Assistant, to Bruce Lindsey, Deputy Chief of Staff, the 
White House) (Exhibit 10).

 Documents that led the Committee to uncover Roger 
Clinton's efforts to obtain a commutation for organized crime 
figure Rosario Gambino: Before receiving these records from 
NARA, the Committee was aware only of a payment of $50,000 from 
Anna Gambino to Roger Clinton. Only after receiving these 
documents did the Committee have reason to believe this payment 
might be related to an effort to free Rosario Gambino from 
prison.\47\
---------------------------------------------------------------------------
    \47\ Committee staff had been unable to reach Mrs. Gambino or 
determine the purpose of her payment. The key document in the NARA 
production was a note apparently drafted by White House staffer 
Meredith Cabe which referenced the fact that she was requesting an NCIC 
check on Rosario Gambino. Given the fact that Rosario Gambino was a 
well-known organized crime figure who was an exceedingly unlikely 
candidate for a legitimate grant of clemency, the Committee 
investigated this matter and determined that Anna Gambino was Rosario 
Gambino's daughter, and that the payment of $50,000 from Anna Gambino 
to Roger Clinton was part of the Gambinos' efforts to obtain a 
commutation for Rosario Gambino.

 Documents showing three additional pardons that 
Roger Clinton attempted to obtain: These documents indicated 
that representatives of Mark St. Pe and Steven Griggs sent 
materials requesting pardons to Roger Clinton at the White 
House, and that these materials were forwarded to the White 
House Counsel's office. Another document indicating that 
William McCord had sent a petition was produced in the midst of 
---------------------------------------------------------------------------
other Roger Clinton-related material.

 Pardon Attorney Roger Adams' report on the 
commutation of drug money launderer Harvey Weinig: This report 
demonstrated that the White House was fully aware of the extent 
of Weinig's criminal activities, including his role in a 
kidnapping.\48\
---------------------------------------------------------------------------
    \48\ See NARA Document Production (Report to the President on 
Proposed Denial of Executive Clemency for Harvey Weinig) (Exhibit 11).

    Given the importance of these records to the Committee's 
investigation, and the absence of any claim of privilege over 
the documents, the Committee decided to use the records in its 
investigation and in this report. Given the apparent 
sensitivity of the records to the White House, the Committee is 
using only those records which are directly relevant to 
necessary subject matter covered in this report.
    The Committee must emphasize that it is disappointed with 
the way the Administration handled its requests for documents 
relating to the pardon matter. It is clear that if a large 
number of documents relating to the pardon had not been 
``inadvertently'' produced by NARA personnel on June 7, the 
Committee would never have received those records. 
Consequently, Members of Congress, historians, and the public 
might never have known about many of the significant abuses of 
public trust detailed in this report. Developments since June 
2001 have made it clear that the Administration is engaged in a 
wide-ranging effort to expand executive privilege beyond its 
traditional boundaries and reduce Congressional oversight of 
the White House and Justice Department. It is disappointing 
that the Bush Administration would attempt to withhold key 
documents from the Committee in an investigation like this, 
where the Committee is looking into allegations of malfeasance 
at the highest levels of government. That the Bush 
Administration attempted to withhold these records even though 
former President Clinton approved their release is especially 
discouraging.
            3. The Justice Department
    The recalcitrance of the Bush Administration in refusing to 
turn over records in the pardon investigation also extended to 
the Justice Department. The Justice Department refused to 
provide a number of records requested by the Committee in the 
course of its investigation. Most of these documents related to 
the Committee's investigation of Roger Clinton, specifically 
relating to Roger Clinton's efforts to obtain a commutation for 
Rosario Gambino. The Committee requested from the Justice 
Department all records relating to any consideration of a grant 
of clemency for Rosario Gambino, as well as all records 
relating to the Justice Department's investigation of Roger 
Clinton's efforts to obtain a grant of clemency for Gambino. 
The Justice Department refused to comply fully with either 
request.
    With respect to the Committee's request for records 
relating to the Justice Department's work on the Gambino 
commutation request, the Department refused to turn over any 
records or even specify which records it was withholding. 
Apparently, the Justice Department based its refusal on 
privilege concerns, presumably executive privilege, although 
Justice Department staff did not identify any specific 
privileges in explaining their decision.
    With respect to the Committee's request for records 
relating to the investigation of Roger Clinton's involvement in 
the Gambino matter, the Justice Department initially provided 
records but then abruptly stopped doing so. The Justice 
Department claimed that it was entitled to withhold records 
because of its ongoing investigation of Roger Clinton. However, 
the records that the Committee sought related to the Justice 
Department's investigation of Roger Clinton, which was 
conducted in 1998 and 1999, and then closed, not its ongoing 
investigation from the Southern District of New York. The 
Justice Department's decision to withhold these records 
significantly hindered the Committee's investigation of the 
Gambino matter. The withheld documents likely contain the 
Justice Department's rationale for failing to pursue criminal 
charges against Roger Clinton, as well as the answers to key 
factual questions such as whether the FBI was even aware of the 
$50,000 payment from the Gambinos before the Committee 
uncovered it in the summer of 2001. Without a complete 
understanding of facts and reasoning underlying the Justice 
Department's decision to close the Clinton-Gambino 
investigation, the Committee is unable to determine whether 
that decision was made in good faith or may have been tainted 
by political considerations.
    [Exhibits referred to follow:]
    
    
                              CHAPTER ONE

``TAKE JACK'S WORD'': THE PARDONS OF INTERNATIONAL FUGITIVES MARC RICH 
                            AND PINCUS GREEN

                       FINDINGS OF THE COMMITTEE

Marc Rich and Pincus Green have a history of illegal and 
corrupt business dealings contrary to the security interests of 
the United States.

 Rich and Green have had extensive trade with 
terrorist states and other enemies of the United States. 
Despite clear legal restrictions on such trade, Rich and Green 
have engaged in commodities trading with Iraq, Iran, Cuba, and 
other rogue states that have sponsored terrorist acts. By 
engaging in these activities, Marc Rich and Pincus Green 
demonstrated contempt for American laws, as well as the well-
being of Americans who were harmed or threatened by these 
states.

 The Central Intelligence Agency provided the 
following declassified information about Marc Rich to the 
Committee:

        If President Clinton had checked with the CIA, he would 
        have learned that Marc Rich had been the subject of 
        inquiries by various foreign government liaison 
        services and domestic government agencies regarding 
        their ongoing investigations of criminal activity.

        In addition, President Clinton would have received 
        information worthy of his consideration in making his 
        decision on the pardon. This information cannot be 
        declassified.

Marc Rich and Pincus Green were guilty of serious crimes and 
showed contempt for the American justice system.

 Marc Rich and Pincus Green attempted to obstruct the 
criminal investigation of them in every way imaginable, 
including attempting to smuggle subpoenaed documents out of the 
country. Rich and Green's tactics resulted in a record-setting 
contempt fine against them, totaling $21 million. Despite these 
tactics, the U.S. Attorney for the Southern District of New 
York was able to indict Marc Rich and Pincus Green on 51 counts 
of illegal activity, including tax evasion, mail fraud, wire 
fraud, and racketeering. The evidence against them was 
overwhelming.

 Because of the strength of the case against them, 
Marc Rich and Pincus Green fled the country rather than face 
trial. Rich's own lawyer told him that by fleeing the country, 
Rich had ``spit on the American flag'' and that ``whatever you 
get, you deserve.'' For the 17 years leading up to his pardon, 
Marc Rich was one of America's 10 most wanted international 
fugitives. Although Jack Quinn, Rich's attorney, argued that 
Rich did not flee the United States to avoid prosecution, 
Rich's ex-wife refuted this view, stating that Rich told her 
that ``I'm having tax problems with the government . . . and I 
think that we are going to have to leave.''

 In order to avoid extradition or apprehension by 
United States law enforcement, Marc Rich and Pincus Green 
attempted to renounce their United States citizenship. While 
this attempt was rejected by the United States, it demonstrated 
that Rich and Green had no loyalty to the United States, and 
viewed their citizenship as a liability to be discarded at 
will.

Rich and Green's crimes were so serious that for seventeen 
years, the U.S. government devoted considerable resources to 
apprehending them and closing down their business activities.

 Rich and Green were such high-profile fugitives that 
on a number of occasions in the 1980s and 1990s, the United 
States Marshals Service attempted to arrest them in various 
foreign countries. A number of countries from the United 
Kingdom to Russia attempted to assist the United States in 
these efforts. The pardons of Rich and Green have sent a 
message that individuals can go from the FBI's most wanted list 
to a Presidential pardon if they spend money and have the 
proper connections. This message undermines U.S. efforts to 
apprehend fugitives abroad.

 Rich and Green were such high-profile fugitives that 
in 1991 the Government Reform Committee, under Democratic 
leadership, held a number of hearings and issued two reports 
about the government's efforts to apprehend Rich and Green. At 
that time, Democrats and Republicans in Congress took the Bush 
Administration to task for not being aggressive enough in 
hunting down Rich and Green, or shutting down their business 
interests in the U.S.

 While Rich and Green were fugitives from justice, 
the American government took a number of actions against their 
interests in the U.S. The federal government seized Rich's 
assets and shut down his trade in metals and grain with the 
government.

The United States government repeatedly tried to reach a plea 
agreement with Rich and Green.

 For a number of years after Rich and Green fled the 
country, the U.S. government attempted to negotiate a plea 
bargain to settle the case. The government made a number of 
concessions in an attempt to reach a deal, but all offers were 
rebuffed by Rich and Green, who would not agree to any deal 
that resulted in jail time. While lobbying for a pardon, Jack 
Quinn and Rich's other lawyers claimed that the Justice 
Department had not even negotiated with Rich, and therefore, 
that a pardon was justified. Quinn and the other lawyers were 
misleading the White House when they made these claims.

Jack Quinn misled the White House about the Rich case and 
attempted to mislead the Committee and the public regarding his 
work for Marc Rich.

 Marc Rich hired Jack Quinn after a recommendation 
from Eric Holder. After numerous failed attempts to have his 
case settled, Marc Rich hired Jack Quinn to represent him. 
Quinn was hired after a recommendation from Deputy Attorney 
General Eric Holder. Gershon Kekst, who worked for Marc Rich on 
the pardon matter, asked Holder for a recommendation of how to 
settle a criminal matter with the Justice Department. Holder 
recommended that he hire a Washington lawyer ``who knows the 
process, he comes to me, and we work it out.'' Holder then 
explicitly recommended the hiring of Jack Quinn. While Holder 
did not know that Kekst was referring to Marc Rich, it suggests 
that Holder was favorably disposed to Jack Quinn, and would be 
very receptive to arguments made by Quinn, no matter how 
baseless they were.

 Marc Rich was going to pay Jack Quinn for his work 
on the pardon. After the Marc Rich pardon was granted, Jack 
Quinn claimed that he was not being paid by Rich for his work 
on the pardon, and that he expected no future payment for his 
work on the pardon. However, the Committee has uncovered 
evidence that Robert Fink, a lawyer close to Marc Rich, had 
discussions with Rich and Quinn about paying Quinn for his work 
on the Rich pardon. Documents which Quinn and Fink withheld 
from the Committee for over a year, and which were produced 
only after a federal judge ordered them produced to a grand 
jury, shed further light on the contemplated payment of Quinn. 
These documents indicate that Quinn raised the question of his 
``status'' with Rich and asked that Rich pay him a $50,000 per 
month retainer. The Committee attempted to interview Quinn 
about these documents, but Quinn refused to meet with Committee 
staff.

 Jack Quinn may have been attempting to receive money 
from Marc Rich after the pardons were granted. At the 
Committee's February 8, 2001, hearing, Quinn pledged that ``I 
will not bill [Rich], and I will not accept any further 
compensation for work done on the pardon.'' This pledge 
surprised Rich's lawyer, who expected that Rich would be paying 
Quinn for his work. Indeed, records just produced to the 
Committee indicate that Quinn may have been attempting to 
negotiate some payment from Marc Rich shortly after he pledged 
that he would not take additional money for his work. A March 
5, 2001, e-mail from Quinn to Rich states ``If you are 
agreeable, and I hope you are, I need to fax to you in the next 
few days a new retainer agreement.'' This e-mail raises the 
possibility that Quinn has been attempting to obtain payments 
from Rich, in possible violation of his pledge to the 
Committee. The Committee attempted to interview Quinn about 
this matter, but he refused.

 Jack Quinn's work on the Rich pardon was in apparent 
violation of Executive Order 12834. That executive order was 
enacted as part of President Clinton's promise to create ``the 
most ethical administration in history,'' and it prohibited 
former executive branch employees from lobbying their former 
executive branch agencies within five years of their departure. 
Quinn has claimed that his work on the Rich pardon came within 
an exception for ``communicating . . . with regard to a . . . 
criminal . . . law enforcement inquiry, investigation or 
proceeding[.]'' However, this exception was clearly intended to 
apply to appearances before courts, not lobbying the White 
House for a pardon. The ``revolving door'' lobbying ban was 
intended to apply exactly to cases like this, where a former 
White House Counsel could come back and lobby the President to 
take an action that had no constitutional limits on it, largely 
based on the President's personal trust for that former 
staffer.

 The pardon petition compiled by Jack Quinn and the 
other Marc Rich lawyers was highly misleading. Most of the 
arguments used by Jack Quinn to justify the Rich and Green 
pardons were false and misleading. These arguments could have 
been completely refuted if anyone in the White House had sought 
out any of the prosecutors familiar with the Rich case.

 The ``letters of support'' in the pardon petition 
were used in a misleading manner. Another key element of the 
Rich pardon petition was a number of letters of support for 
Rich and Green from prominent Americans and Israelis. Rich and 
Green used these letters to try to show that their humanitarian 
activities justified their pardons. However, many of these 
letters were obtained under false pretenses, and the writers of 
the letters were not told that they were being used to obtain a 
Presidential pardon. In addition, a number of individuals who 
wrote in support of Rich and Green received large amounts of 
money from them.

Marc Rich and Pincus Green used a number of different 
individuals with close personal relationships with President 
Clinton and his staff to lobby regarding the pardon.

 The role of Denise Rich. Denise Rich played a key 
role in obtaining the Rich and Green pardons. Denise Rich had a 
close relationship with President Clinton, which was based in 
part on her role as a large-scale contributor to Democratic 
causes and the Clinton library, and in part on her extensive 
personal contacts with President Clinton. Denise Rich used this 
relationship with President Clinton to lobby for the Marc Rich 
pardon on a number of occasions. Denise Rich has refused to 
cooperate with the Committee, invoking her Fifth Amendment 
rights rather than answer questions about her role in the 
pardon.

 The role of Beth Dozoretz. Beth Dozoretz, another 
close friend of President Clinton, played a key role in 
obtaining the Rich pardon. Like Denise Rich, Beth Dozoretz had 
a relationship with President Clinton built on personal ties 
and political fundraising. Dozoretz has raised and contributed 
millions of dollars for the Democratic party, and has pledged 
to raise an additional million dollars for the Clinton library. 
Beth Dozoretz also has close relationships with Denise Rich and 
Jack Quinn. Dozoretz used her close relationship with President 
Clinton to lobby for the Rich pardon. Because Dozoretz has 
invoked her Fifth Amendment rights against self-incrimination, 
the Committee is unable to conclude whether or not Dozoretz 
made any linkage between contributions to the DNC or the 
Clinton library and the granting of the Rich pardon.

 The role of Prime Minister Ehud Barak. Israeli Prime 
Minister Ehud Barak spoke to President Clinton three times 
about the Rich pardon. In his public statements about the Rich 
pardon, President Clinton has pointed to these conversations 
with Prime Minister Barak as one of the primary reasons he 
granted the pardon. However an examination of the transcripts 
of the calls shows that Barak did not make a particularly 
impassioned plea for Rich. Therefore, it appears that the 
President may be attempting to use Prime Minister Barak's 
interest in the Rich matter as a cover for his own motivations 
for granting the Rich pardon.

 Barak had met with Rich personally and told Clinton 
that the Rich pardon ``could be important . . . not just 
financially, but he helped Mossad on more than one case.'' 
Barak's statement raises the possibility that either Barak or 
Clinton acted on the Rich matter because of some promise of 
future financial return.

Eric Holder and Jack Quinn worked together to cut the Justice 
Department out of the decisionmaking process. Holder's decision 
to support the pardon had a critical impact.

 Jack Quinn and Deputy Attorney General Eric Holder 
worked together to ensure that the Justice Department, 
especially the prosecutors of the Southern District of New 
York, did not have an opportunity to express an opinion on the 
Rich pardon before it was granted. The evidence amassed by the 
Committee indicates that Holder advised Quinn to file the Rich 
pardon petition with the White House and leave the Justice 
Department out of the process. One e-mail produced to the 
Committee suggests that Holder told Quinn to ``go straight to 
wh,'' and that the ``timing is good.'' The evidence also 
indicates that Holder failed to inform the prosecutors under 
him that the Rich pardon was under consideration, despite the 
fact that he was aware of the pardon effort for almost two 
months before it was granted.

 Eric Holder's support of the Rich pardon played a 
critical role in the success of the pardon effort. Holder 
informed the White House that he was ``neutral, leaning towards 
favorable'' on the Rich pardon, even though he knew that Rich 
was a fugitive from justice, and that Justice Department 
prosecutors viewed Rich with such contempt that they would no 
longer meet with his lawyers. Holder has failed to offer any 
credible justification for his support of the Rich pardon, 
leading the Committee to believe that Holder had other 
motivations for his decision, which he has failed to share with 
the Committee.

 Eric Holder was seeking Jack Quinn's support to be 
appointed as Attorney General in a potential Gore 
Administration, and this may have affected Holder's judgment in 
the Rich matter. On several occasions, Holder sought out 
Quinn's endorsement to be appointed as Attorney General if Al 
Gore were to win the November 2000 election. Quinn was a Gore 
confidant whose endorsement would carry great weight. Holder's 
initial help to Quinn in the Rich matter predated the Supreme 
Court's decision in Bush v. Gore, and accordingly, Holder had 
some legitimate prospect of being appointed Attorney General 
when he was helping Quinn keep the Rich matter from the Justice 
Department's scrutiny. While Holder denies that his desire to 
be appointed Attorney General had anything to do with his 
actions in the Rich matter, it provides a much clearer and more 
believable motivation than any offered by Holder to date.

President Clinton made his decision knowing almost nothing 
about the Rich case, making a number of mistaken assumptions 
and reaching false conclusions.

 The White House never consulted with the prosecutors 
in the Southern District of New York regarding the Rich case. 
As a result, the White House staff was never able to refute the 
false and misleading arguments made in the Marc Rich pardon 
petition.

 Every White House staff member who was working on 
the Rich pardon opposed it. However, because they failed to do 
the necessary background research on the Rich case, they were 
unable to refute the arguments made by Jack Quinn.

 President Clinton was misled by Jack Quinn in their 
negotiations regarding the Rich pardon. Late in the evening of 
January 19, 2001, President Clinton and Jack Quinn had a 
telephone discussion regarding the Rich pardon. During this 
conversation, Quinn repeated his usual misleading arguments 
about the Rich case. Quinn also offered to make his clients 
subject to civil liability for their actions. In furtherance of 
this offer, Quinn agreed to waive all statute of limitations 
and other defenses, which Rich and Green would have as a result 
of their fugitivity. President Clinton has cited this waiver as 
a key factor in his decision to grant the pardons. However, if 
President Clinton or his staff had done even cursory legal 
research, they would have understood that this was a hollow, 
meaningless deal. First, Quinn agreed to waive defenses that 
Rich and Green did not have. It is basic legal doctrine that 
fugitivity tolls the statute of limitations. Second, Rich and 
Green likely do not face any civil liability for their crimes, 
since those fines were already paid by their companies. Third, 
Rich and Green had been willing to pay $100 million to settle 
their case for years. A fine, even a large one, would have had 
no impact on Rich and Green, and it would merely stand for the 
proposition that the U.S. justice system is for sale.

 When the White House did finally provide the names 
of Marc Rich and Pincus Green for a Justice Department 
background check in the middle of the night on January 19, 
2001, the check turned up new, troubling information which was 
disregarded by President Clinton. When the White House 
requested the Justice Department to perform a computer 
background check on Rich and Green prior to granting the 
pardons, the check came back with information that they were 
wanted for ``arms trading.'' This was new information for all 
of the White House staff, and it raised serious questions among 
them as to whether the pardons should be granted. However, the 
only step the White House took to check on this allegation was 
to call Jack Quinn. Quinn predictably denied that his clients 
were involved in arms trading. Faced with this conflicting 
information about Rich and Green, President Clinton instructed 
his staff to ``take Jack's word,'' and issue the pardons.

President Clinton has failed to offer a full accounting for his 
decision to issue the Marc Rich and Pincus Green pardons.

 President Clinton has failed to answer any questions 
about the Rich and Green pardons. The few statements that he 
has issued have been misleading, incomplete, and raised more 
questions than they answered. Given his complete failure to 
explain the pardons, the Committee is left with serious 
unanswered questions regarding President Clinton's motives.

INTRODUCTION

    The pardons of Marc Rich and Pincus Green were the most 
controversial and most outrageous pardons issued by President 
Clinton, and likely, by any President. Rich and Green were 
fugitives from justice, and were two of the largest tax cheats 
in U.S. history. In addition, they had a long and disgraceful 
record of trading with America's enemies, helping prop up the 
Ayatollah Khomeini, Saddam Hussein, Muammar Qaddafi, and the 
Russian mafia, among others. This track record has led even 
Marc Rich's lawyers to call him a ``traitor'' and observe that 
he has ``spit on the American flag.''
    It is beyond any dispute that Marc Rich and Pincus Green 
did not deserve pardons. Therefore, the inevitable question is 
why the President granted them. Some believe that the Rich and 
Green pardons were the product of a pardon process that 
completely broke down at the end of the Clinton Administration. 
These individuals would argue that in his rush to create a 
legacy at the end of his term, President Clinton short-
circuited the normal clemency review process, and granted 
pardons without conducting the due diligence that was required. 
While this is hardly a charitable view of President Clinton, it 
is the most innocuous explanation that can be presented for the 
Rich and Green pardons.
    There are a number of reasons to believe that the pardons 
were not just the product of a sloppy process. After all, even 
though they did not fully understand the scope of Rich and 
Green's crimes, the President and White House staff grasped the 
essentials of the Rich case: Rich and Green were massive tax 
cheats, fugitives from justice, and had traded with the enemy. 
Yet, they received the pardons despite these damning facts. 
Therefore, the Committee has looked at the motives of the key 
players in the Marc Rich and Pincus Green pardon effort.
    The evidence raises many questions regarding the motives of 
the key players.

 Jack Quinn, for example, used his influence as a 
former White House Counsel to lobby the President on Rich's 
behalf. Quinn repeatedly provided misinformation to the White 
House. At the height of the public's outcry about the Rich 
case, Quinn claimed that he was representing Rich on a pro bono 
basis. However, the evidence obtained by the Committee shows 
that Quinn was attempting to secure a lucrative payment from 
Rich, and may still be trying to obtain payment from Rich.

 Deputy Attorney General Eric Holder provided 
critical support for the Rich pardon. While Holder should have 
ensured that the Justice Department's views were represented in 
the pardon process, Holder instead advised Jack Quinn on how to 
cut the Justice Department out of the process. While all of the 
White House staff was opposing the Rich and Green pardons, Eric 
Holder provided critical support for it at the eleventh hour. 
Holder may claim that his actions were the result of 
misjudgment, but Holder himself admitted that he was seeking 
Quinn's support to be nominated as Attorney General if Al Gore 
was elected President. This created a conflict of interest for 
Holder.

 Denise Rich and Beth Dozoretz were both close 
friends of President Clinton and major contributors to the 
Democratic Party. In addition, Denise Rich contributed $450,000 
to the Clinton Library, and Dozoretz pledged to raise $1 
million for the Clinton Library. Both lobbied the President on 
the Rich pardon. Both have also invoked their Fifth Amendment 
rights rather than testify about their discussions with the 
President.

 President Clinton is ultimately responsible for the 
pardons, and must ultimately provide an explanation of why he 
granted them. He has, however, failed to provide any 
satisfactory rationale for his actions. He has failed to answer 
any serious questions, and instead, has offered only one self-
serving, factually inaccurate newspaper column to justify the 
pardons. President Clinton's attempted explanations have raised 
more questions than answers about his motivations for granting 
two of the most unjustified pardons in U.S. history.

    Regardless of the motivations for the Rich and Green 
pardons, the nation must live with the consequences of them. 
The pardons have sent two equally destructive messages. First, 
by granting the pardons, President Clinton undermined the 
efforts of U.S. law enforcement to apprehend fugitives abroad. 
By pardoning a man who evaded capture by the U.S. Marshals 
Service for almost two decades, President Clinton sent the 
message that indeed, crime can pay, and that it may be 
worthwhile to remain a fugitive rather than face charges. The 
pardon also could undermine U.S. efforts to obtain extradition 
of fugitives from foreign countries. When a man like Rich can 
go from the Justice Department's most wanted to a free man with 
a stroke of the pen, it is difficult for the U.S. to credibly 
demand the extradition of wanted fugitives. Finally, the 
pardons send the message that President Clinton did believe 
that different rules applied to wealthy criminals. If he did 
not have the money to hire Jack Quinn and his White House 
access, Marc Rich never would have obtained a pardon. The 
President abused one of his most important powers, meant to 
free the unjustly convicted or provide forgiveness to those who 
have served their time and changed their lives. Instead, he 
offered it up to wealthy fugitives whose money had already 
enabled them to permanently escape American justice. Few other 
abuses could so thoroughly undermine public trust in 
government.

I. BACKGROUND OF MARC RICH AND PINCUS GREEN

A. Rich and Green's Business Activities
            1. How Rich and Green Became Wealthy
    Marc Rich is one of the wealthiest people in the world. His 
network of business enterprises is estimated to generate 
upwards of $30 billion annually.\1\ Rich's personal net worth 
is estimated at between $1.5 and $8 billion.\2\ Along with his 
business partner Pincus ``Pinky'' Green, Rich has made this 
fortune principally through the commodities trading business.
---------------------------------------------------------------------------
    \1\ Josh Getlin, Clinton Pardons a Billionaire Fugitive, and 
Questions Abound, L.A. Times, Jan. 24, 2001, at A1.
    \2\ A. Craig Copetas, Court TV Chat Transcript (visited Mar. 10, 
2002) http://www.courttv.com/talk/chat--transcripts/2001/0220rich-
copetas.html. It should be noted that estimates of Rich's personal 
fortune are probably lower than the actual amount because of Rich's 
history of questionable accounting and tax evasion, including that for 
which he was indicted in 1983.
---------------------------------------------------------------------------
    Rich began his career as a commodities trader in 1954 with 
the New York office of the trading firm Philipp Brothers.\3\ 
Rich traded in a wide variety of commodities, including 
precious metals. Throughout his early career he was highly 
successful, amassing huge profits for the firm. Over time, Rich 
also developed a niche within the firm as a crude oil trader. 
He and Green revolutionized international oil trading by 
creating the ``spot market,'' which is the practice of 
purchasing oil from producers and immediately selling it to 
refineries for a large profit.
---------------------------------------------------------------------------
    \3\ A. Craig Copetas, Metal Men: Marc Rich and the 10-Billion-
Dollar Scam 65 (1985).
---------------------------------------------------------------------------
    After more than twenty years of trading for Philipp 
Brothers, Rich decided that he could make more money on his 
own. In 1975, while managing Philipp Brothers' Madrid office, 
Rich called a meeting of the firm's European managers in Zug, 
Switzerland, during which he demanded an impossibly high 
bonus.\4\ When, as expected, Rich's boss refused, Rich 
announced that he was leaving the firm to start his own 
company. He left with Pincus Green, taking six other top 
traders from the firm, as well as files of information on 
Philipp Brothers' clients.\5\ Rich's new firm was a success, 
and Rich was well on his way to becoming a billionaire. By 
1982, Marc Rich + Co. A.G. had become the second largest 
commodities firm in the world.\6\ However, as Rich's biographer 
explained, the initial financing for Rich's new company was 
based largely on ``a promise from Iranian Senator Ali Rezai to 
help set up a series of no-holds-barred oil deals that would, 
in part, lead to making Marc Rich the most wanted white-collar 
fugitive in American history.'' \7\
---------------------------------------------------------------------------
    \4\ Id. at 96.
    \5\ Id. at 99.
    \6\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 98 (Feb. 
8, 2001) (prepared testimony of Morris ``Sandy'' Weinberg, Jr., and 
Martin J. Auerbach, former Assistant U.S. Attorneys for the S.D.N.Y., 
Department of Justice).
    \7\ A. Craig Copetas, Metal Men: Marc Rich and the 10-Billion-
Dollar Scam 99 (1985).
---------------------------------------------------------------------------
            2. Marc Rich's History of Illegal and Improper Business 
                    Dealings
    Even before he had departed Philipp Brothers, Marc Rich 
developed a reputation as a shrewd and unethical manipulator. 
As fellow Phillip Brothers' trader Bill Spier explained, ``What 
separated our friendship was his belief that you could only 
make it bigger and better than the next guy by buying people 
off. Marc was suave and sophisticated and obsessed with power. 
He was always looking to see who he could buy off.'' \8\ While 
at Philipp Brothers, Rich also learned to deal with rogue 
political regimes in order to make a profit. For example, in 
1958, Rich was sent to Cuba, and continued to work there after 
the fall of the Batista regime. As one former associate 
explained, ``Marc cut his teeth in Havana, and the experience 
shaped his character because it taught him that being illegal 
was okay under certain conditions[.]'' \9\
---------------------------------------------------------------------------
    \8\ Id. at 66.
    \9\ Id. at 71.
---------------------------------------------------------------------------
    Once he set up his own business enterprise, Rich's 
questionable practices appear to have expanded. His trading 
empire was based largely on systematic bribes and kickbacks to 
corrupt local officials. For example, in 1977, one of Rich's 
traders claimed to have deposited $125,000 into the Swiss bank 
account of Reza Fallah, then-head of the Iranian National Oil 
Company, in exchange for ``services rendered'' in securing a 
shipment of Iranian oil to Spain.\10\ In 1978, Rich and Green 
were caught diverting Nigerian oil shipments to South Africa. 
When the Nigerians threatened to cut off relations with Rich, 
he paid a $1 million bribe to the Nigerian transport minister 
to get the contract back.\11\ Rich also reportedly paid former 
Jamaican President Edward Seaga $45,000 to send the Jamaican 
track and field team to the 1984 Olympics. In return, Rich 
signed a ten-year agreement to purchase most of the output of 
the Jamaican Alcoa plant, which annually produced a significant 
portion of the world's aluminum.\12\ One former Rich trader 
explained the standard practices of Rich's companies as 
follows: ``[t]o go into places like Iran and do honest business 
is naive. I'd figure 15 percent of your net in payoffs for 
every deal made.'' \13\
---------------------------------------------------------------------------
    \10\ Id. at 115.
    \11\ Id. at 119.
    \12\ Shawn Tully, Why Marc Rich is Richer Than Ever, Fortune, Aug. 
1, 1988, at 74.
    \13\ A. Craig Copetas, Metal Men: Marc Rich and the 10-Billion-
Dollar Scam 115 (1985).
---------------------------------------------------------------------------
    As is explained in more detail below in the section 
discussing Rich's legal troubles in the United States, Rich 
also laundered funds and hid his profits to protect them from 
the taxing authorities of various countries. For example, Rich 
routinely used Panamanian shell companies (Sociedades Anonimas) 
to launder money and to conceal profits from taxing 
authorities.\14\ As explained by author Craig Copetas:
---------------------------------------------------------------------------
    \14\ Id. at 125.

        Panamanian corporate law is particularly helpful to a 
        trader whose operations extend outside the Central 
        American nation and into several different countries. A 
        Sociedad Anonima is never required to file financial 
        reports or tax returns and may maintain its books in 
        any manner it desires in any part of the world. This 
        permits a procedure generally known as laundering, and 
        for Marc Rich--an expert at sidestepping the politics 
        of nations by acting as a maverick middleman between 
        producers and consumers--it was quite the bargain at 
        $1,650 plus a $50 annual franchise tax.\15\
---------------------------------------------------------------------------
    \15\ Id.

Rescor Incorporated, (a company that Rich used in his illegal 
oil scam that led to his legal troubles in the United States) 
was one such shell company. At one point, according to a former 
Rich shareholder, Rich had $800 million in cash concealed in 
his Panamanian shell companies.\16\
---------------------------------------------------------------------------
    \16\ Id.
---------------------------------------------------------------------------
    Working with corrupt governments was not Marc Rich's only 
trademark. Much of Rich's fortune was made dealing with 
countries that no one else would deal with. Rich shrewdly used 
his multinational status, and his familiarity with unscrupulous 
business practices, to profit from embargoes and wars by 
trading with pariah nations. Rich's pattern of dealing with 
America's enemies, especially Iran, led even one of Rich's own 
lawyers to admit that Rich could be considered a traitor to his 
country:

        Mr. Waxman. Do you agree with the statement that these 
        gentlemen [Rich and Green] were two traitors to their 
        country?

        Mr. Libby. I can understand someone using those terms.

        Mr. Waxman. Do you agree with them?

        Mr. Libby. Their companies engaged in trades with 
        Iran--

        Mr. Waxman. Traitors not traders.

        Mr. Libby. No, sir, I was trying to finish--during a 
        period when trades [sic] were held, and that was an act 
        you could consider an act of a traitor.

        Mr. Waxman. That someone could consider, but you do not 
        consider it?

        Mr. Libby. I could consider it. I do not condone it. I 
        didn't advise it. I do not admire it.\17\
---------------------------------------------------------------------------
    \17\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 486 
(Mar. 1, 2001) (testimony of I. Lewis ``Scooter'' Libby).

    The following section describes specific business 
relationships that Rich maintained with regimes or countries 
with interests adverse to the United States. U.S. intelligence 
agencies have considerable information about Marc Rich, none of 
which was reviewed by the White House prior to the pardons. 
Unfortunately, most of the information remains classified. The 
---------------------------------------------------------------------------
CIA, however, did declassify the following statement:

        If President Clinton had checked with the CIA, he would 
        have learned that Marc Rich had been the subject of 
        inquiries by various foreign government liaison 
        services and domestic government agencies regarding 
        their ongoing investigations of criminal activity.

        In addition, President Clinton would have received 
        information worthy of his consideration in making his 
        decision on the pardon. This information cannot be 
        declassified.

As described below, though, the public record alone should have 
been enough to eliminate any possibility of pardons for Marc 
Rich and Pincus Green.
                a. Iran
    Marc Rich got his start in the oil trade through business 
dealings with the Shah of Iran. After the Shah fell from power, 
many were concerned by Ayatollah Khomeini's violent rise to 
power. However, Rich saw a new opportunity, and began trading 
with the Khomeini regime. In the early days of the Iranian 
revolution, after the new Iranian government seized 51 American 
hostages, the United States imposed a strict trade embargo on 
Iran. Nevertheless, Rich directed his staff to meet the new 
directors of the Iranian state-owned oil company.\18\ Shortly 
thereafter, Marc Rich and Pincus Green reached a deal to 
purchase Iranian oil through his Swiss company, Marc Rich + Co. 
A.G. Reportedly, Rich paid for much of this purchase in small 
arms, automatic rifles, and hand-held rockets.\19\ One of 
Rich's colleagues stated that because of this deal ``Rich got 
more excited than I had ever seen him.'' \20\
---------------------------------------------------------------------------
    \18\ A. Craig Copetas, Metal Men: Marc Rich and the 10-Billion-
Dollar Scam 131 (1985).
    \19\ Id.
    \20\ Id. at 132.
---------------------------------------------------------------------------
                b. South Africa
    Rich's companies also dealt extensively with the South 
African government throughout the apartheid regime. 
Notwithstanding the United Nations' ban on oil sales to South 
Africa, throughout the 1980s Rich's company was one of the 
three main traders of oil between the Middle East and South 
Africa.\21\ Where other companies saw legal peril, Marc Rich 
saw profit, with South African companies willing to pay a 
premium of $8 per barrel of oil. According to the Dutch-based 
Shipping Research Bureau, Rich supplied about 6 percent of all 
oil imports to South Africa between 1979 and 1986, earning 
upwards of $1 billion from the transactions.\22\ And according 
to a former Rich shareholder, at the time of their indictment 
in the United States, Rich and Green were trading Soviet and 
Iranian oil to the apartheid government in South Africa in 
exchange for Namibian uranium, which Rich and Green in turn 
sold back to the Soviet Union.\23\
---------------------------------------------------------------------------
    \21\ Andrew Lycett, Spectrum: Plain Sailing Through the Sanctions 
Net, Times (London), Sept. 12, 1986.
    \22\ Shawn Tully, Why Marc Rich is Richer Than Ever, Fortune, Aug. 
1, 1988, at 74.
    \23\ A. Craig Copetas, Metal Men: Marc Rich and the 10-Billion-
Dollar Scam 198 (1985).
---------------------------------------------------------------------------
    At times, Rich's deals with South Africa were so risky and 
profitable that Rich would scuttle the oil tanker at the 
conclusion of the deal and fly the crew home. In one deal, a 
tanker was loaded with oil from the Soviet Union, was diverted 
from its intended itinerary, covered its name with tarpaulins, 
communicated only in code, and then delivered its oil in secret 
to South Africa.\24\
---------------------------------------------------------------------------
    \24\ Jim Hougan, King of the World (Marc Rich), Playboy, Feb. 1, 
1994, at 104.
---------------------------------------------------------------------------
                c. The Soviet Union/Russia
    The South African uranium transactions were not the only 
dealing Rich had with the Soviet Union. In fact, Rich and his 
companies dealt extensively with the Soviet Union and other 
Communist countries. His oil trading with the Soviet Union 
provided Moscow with the hard currency needed to purchase grain 
during the United States' grain embargo.\25\ Rich's dealings 
with the Soviet Union were so extensive and helpful to the 
Soviet Union that when he was indicted in the United States in 
1983, one Moscow newspaper printed a front page, above-the-fold 
story defending Marc Rich and attacking the United States.\26\ 
In fact, the Russian newspaper Izvestia wrote the following in 
defense of Rich:
---------------------------------------------------------------------------
    \25\ Id.
    \26\ A. Craig Copetas, Metal Men: Marc Rich and the 10-Billion-
Dollar Scam 196-197 (1985).

        The United States thinks that all countries, big and 
        small, must subvert their national interests to 
        American measures. . . . Under the pretext of 
        nonpayment of taxes by the Swiss branch of the Marc 
        Rich firm, American authorities have given an 
        ultimatum: either Switzerland changes its internal 
        legislation or its companies will be deprived of 
        admission to American markets. This action by the 
        Reagan Administration is an open threat, an attempt to 
        interfere into the internal affairs of Western European 
        countries through the threat of economic sanctions. The 
        Americans are living under the illusion of a Pax 
        Americana.\27\
---------------------------------------------------------------------------
    \27\ Id. at 197.

The fact that one of the leading propaganda organs of the 
Soviet state would dedicate itself to the defense of a 
capitalist commodities trader like Marc Rich shows the 
importance Rich and his company had in providing hard currency 
to the Soviet regime.
    Marc Rich's influence has only grown in post-Communist 
Russia. Rich took advantage of widespread privatization in 
Russia to acquire large supplies of industrial materials at 
bargain prices. As explained in The Washington Post, ``[a]fter 
the Soviet Union fell apart in 1991, these relationships helped 
Rich become for a time the single most important Western trader 
in Russia.'' \28\ There is also evidence that Rich has 
developed deep ties with Russian organized crime, a powerful 
force in post-Communist Russia.\29\ According to press 
accounts, law enforcement agencies including the FBI and the 
CIA had information indicating that Rich had financial ties to 
the Russian mafia.\30\ According to one U.S. intelligence 
source who spoke to the press, ``Clinton would have found out 
about the relationships if he had asked either the FBI or CIA, 
[but] [h]e clearly never bothered to ask.'' \31\ Another source 
told the press that ``[t]he FBI has tons of material on the 
Russian mafia and in particular the Rich-mafia connection.'' 
\32\
---------------------------------------------------------------------------
    \28\ Michael Dobbs, Rich Made His Fortune by Breaking the Rules, 
Wash. Post, Mar. 13, 2001, at A1.
    \29\ Robert I. Friedman, Red Mafiya: How the Russian Mob has 
Invaded America 51 (2000) (indicating that Rich had a relationship with 
Russian gangster Marat Balagula, now serving time in prison for 
gasoline price fixing). Rich is also suspected to have been involved in 
metals trading going in and out of the Estonian port of Tallinn, where 
Russian copper, nickel and cobalt are often exported. Tallinn is 
notorious for being controlled by the Russian mafia. Rich's company has 
denied using the port of Tallinn. See Tony Glover, The EU's Baltic 
Extension, EuroBusiness, May 1, 1994.
    \30\ Matthew McAllester, Rich's Suspect Ties/Sources: Clinton Could 
Have Learned Russian Mob Links, Newsday, Mar. 1, 2001, at A5.
    \31\ Id.
    \32\ Id.
---------------------------------------------------------------------------
    Reportedly, Rich has been linked specifically by U.S. law 
enforcement to Mikhail Chernoy, a former agent for Trans-World 
Metals. Chernoy is a defendant in a civil case in the U.S. 
District Court for the Southern District of New York. He is 
named as a controller of two Russian aluminum companies by 
European companies who claim that the defendants used bribery, 
money-laundering and extortion in order to illegally seize a 
large aluminum plant in Russia.\33\ Moreover, according to an 
investigative report commissioned by the World Bank in 1998, 
Chernoy was arrested by the Swiss police in 1996 during an 
investigation of Russian gangs.\34\ As the report states, 
Mikhail's brother Lev ``is believed to be a major Russian mafia 
figure by most international police and intelligence 
organizations.'' \35\ The report further states that Marc Rich 
provided the seed money necessary to start up Trans-World 
metals.\36\
---------------------------------------------------------------------------
    \33\ Id.
    \34\ Id.
    \35\ Id.
    \36\ Id. David Reuben, the Chairman of Trans-World has denied this 
account. See Letters, Newsday, Mar. 7, 2001, at A39.
---------------------------------------------------------------------------
    Rich has also been linked to Grigori Loutchansky, a 
Georgian-born Israeli citizen who is considered to be a 
significant player in Russian mob activities. According to 
press accounts, Loutchansky worked with Rich in the early 1990s 
selling Russian oil and aluminum from formerly state-run 
enterprises.\37\ Loutchansky, who was ``accused of drug 
trafficking and smuggling nuclear weapons,'' \38\ is ``listed 
in a 1995 State Department `watch list' as a `suspected 
criminal,' '' \39\ and was involved in the 1996 campaign 
fundraising scandal. Time magazine has said that Loutchansky is 
``considered by many to be the most pernicious unindicted 
criminal in the world,'' \40\ yet he dined with Clinton at a 
White House dinner in 1993 and subsequently channeled money 
into Clinton's campaign.\41\ He was also invited to a 
fundraising dinner in July 1995 but was unable to attend when 
his visa was denied and invitation withdrawn.\42\
---------------------------------------------------------------------------
    \37\ The U.S. Connection in Caucasus, Intelligence Newsletter, No. 
401, Mar. 8, 2001.
    \38\ Judi Hasson, Panel Offers Evidence of China Link Beijing Bank 
Wired Funds to L.A. Man Prior to Donation, USA Today, July 11, 1997, at 
6A.
    \39\ Jerry Seper, Ukrainian Gained U.S. Entry Because of Spelling 
Mismatch, Wash. Times, Dec. 13, 1997, at A4.
    \40\ Statement by Former CIA Director on Clinton Ties to 
Loutchansky, U.S. Newswire, Nov. 3, 1996.
    \41\ Jerry Seper, Soloman Asks Again for Data on Meetings with 
Russian, Wash. Times, Feb. 11, 1997, at A4.
    \42\ Lee Davidson, Bennett Zeros in on Demo Donations, Deseret News 
(Salt Lake City, UT), July 11, 1997, at A1.
---------------------------------------------------------------------------
                d. Cuba
    In this hemisphere, Rich continued to conduct business with 
Communist Cuba, notwithstanding the U.S. embargo. Rich's early 
dealings with Fidel Castro as a trader for Philipp Brothers 
apparently paid off decades later when he started his own 
companies. Marc Rich reportedly assisted Cuban efforts to 
escalate its nuclear power program in 1991.\43\ Rich negotiated 
with Castro's son to develop a uranium deposit in Western 
Cuba.\44\ The highly enriched uranium could be used to fuel 
Cuba's twin 440-megawatt nuclear power reactors. In addition, 
U.S. officials were concerned about the weapons potential of 
the enriched uranium used in the reactor.\45\ Also in 1991, 
Marc Rich & Co., Ltd. arranged a $3.9 million deal for sugar 
and oil that were transferred through Cuba.\46\ Ultimately, 
these transactions violated the Cuban Assets Control 
regulations, and the Office of Foreign Assets Control of the 
U.S. Department of Treasury blocked nearly $3 million of funds 
from Rich's Cuba transactions.\47\
---------------------------------------------------------------------------
    \43\ John J. Fialka and Jose de Cordoba, Cuba Speeds Nuclear 
Project; Marc Rich Is Said to Assist, Wall St. J. europe, June 4, 1991, 
at 2.
    \44\ Id.
    \45\ See id.
    \46\ Department of Treasury Document Production 000635 (Note to 
file C-17306 from the Compliance Programs Division) (Exhibit 1).
    \47\ Department of Treasury Document Production 000652 (Memorandum 
from R. Richard Newcomb, Director of the Office of Foreign Assets 
Control, Department of the Treasury, to Ronald K. Noble, Under 
Secretary for Enforcement, Department of the Treasury (Sept. 16, 1994)) 
(Exhibit 2).
---------------------------------------------------------------------------
                e. Libya
    Marc Rich also apparently traded with Libya under Muammar 
Qaddafi.\48\ Rich's companies purchased oil from Libya 
beginning in the 1970s.\49\ Yet even after the United States 
bombed Libya in April of 1986 in response to the terrorist 
attacks originating in that country, Rich reportedly continued 
to purchase crude oil from Qaddafi's regime.\50\ Rich continued 
to do business with Libya even after U.S. oil companies 
completely withdrew from the country.\51\ Unlike the other 
American oil companies, Rich ignored the oil embargoes and 
executive orders of the Reagan Administration designed to 
punish the terrorist-sponsoring state.
---------------------------------------------------------------------------
    \48\ A. Craig Copetas, Metal Men: Marc Rich and the 10-Billion-
Dollar Scam 118 (1985).
    \49\ Id.
    \50\ Strong Tanker Fixtures Seen as Indication of Undiminished 
Interest in Libyan Oil, Platt's Oilgram News, July 16, 1986, at 1.
    \51\ Id.
---------------------------------------------------------------------------
                f. Iraq
    It has also been reported that Marc Rich attempted to 
violate the UN embargo against Iraq during the Persian Gulf 
War.\52\ Other reports indicate that U.S. officials have been 
investigating charges that Rich lent money to Saddam Hussein's 
government in exchange for future deliveries of cheap oil.\53\ 
In a statement to The Financial Times of London, Marc Rich 
acknowledged that he had communications with Iraq in September 
of 1991, but denied that it involved oil trading.\54\ The fact 
that Rich would admit to having discussions with Saddam 
Hussein's government just months after the end of the Gulf War 
is remarkable. Based on his pattern of shrewd, unethical, and 
illegal business dealings with other rogue regimes, Rich's 
claim to be interested only in humanitarian aid for Iraq 
completely lacks credibility.
---------------------------------------------------------------------------
    \52\ See John Hooper, Oil Traders Get Rich in Global Game of Chess, 
The Guardian (London), Aug. 7, 1990. See also Jim Hougan, King of the 
World (Marc Rich), Playboy, Feb. 1, 1994, at 104.
    \53\ Paul Klebnikov, How Rich Got Rich, Forbes, June 22, 1992, at 
41.
    \54\ Ian Rodger, Marc Rich Hopes for Resolution of Tax Case, 
Financial Times, (London), Mar. 12, 1993, at 26.
---------------------------------------------------------------------------
                g. Angola
    In Angola, as in many other countries, Marc Rich and Pincus 
Green became close to the dictators ruling the country. These 
relationships gave them exclusive rights to the country's oil. 
When other Western oil companies wanted Angolan oil, they had 
to turn to Marc Rich and Pincus Green. This point was made with 
somewhat comedic effect when, in the late 1970s, a number of 
western oil executives were called to a meeting with Angola's 
oil agents. Expecting a group of communist officials, the 
executives ``were visibly stunned when the communist 
representative who walked into the conference room turned out 
to be Pinky Green, greeting Exxon executives with a hearty `How 
ya doin'?' '' \55\
---------------------------------------------------------------------------
    \55\ A. Craig Copetas, Metal Men: Marc Rich and the 10-Billion-
Dollar Scam 115 (1985).
---------------------------------------------------------------------------
                h. Romania
    Marc Rich is reported to have traded several commodities, 
including oil, with the Romanian regime of Nicolae 
Ceausescu.\56\ At the time, Rich reportedly had his own 
refineries based in Romania.\57\ Trade unionists in Romania 
have accused Rich of cashing in on the fortunes that Ceausescu 
stole from the Romanian people.\58\ It also appears that, based 
on documents received by the Committee from the U.S. Department 
of Agriculture, Marc Rich was trading grain with the Ceausescu 
regime in the late 1980s.\59\ As is discussed in detail below, 
these sales (in addition to sales to countries like China, the 
Soviet Union, and Saudi Arabia) resulted in Rich's companies 
receiving $95 million from the Department of Agriculture 
through a program that provided surplus grain to companies 
selling subsidized grain abroad.\60\ This led to an 
investigation by then-Congressman, and later Secretary of 
Agriculture, Dan Glickman. Glickman's investigation would 
eventually lead the first Bush Administration to direct the 
Department of Agriculture to bar Rich's companies from 
receiving any new contracts.
---------------------------------------------------------------------------
    \56\ Romania: Life After Debt, International Trade Finance, May 18, 
1989.
    \57\ Jim Hougan, King of the World (Marc Rich), Playboy, Feb. 1, 
1994, at 104.
    \58\ Id.
    \59\ See Department of Agriculture Document Production (Minutes of 
Richo Grain Board Meeting, Jan. 6, 1987); Department of Agriculture 
Document Production (Listing of E.E.P. Awards Made to Richco Grain, 
Sept. 27, 1989) (Exhibit 3).
    \60\ Bruce Ingersoll, U.S. Suspends Grain Export Subsidies for Firm 
Linked to Fugitive Marc Rich, Wall St. J., Oct. 12, 1989, at sec. 3, p. 
19.
---------------------------------------------------------------------------
                i. Serbia
    One document from the Office of Foreign Assets Control 
produced to the Committee by the U.S. Department of Treasury 
indicates that Rich was also dealing with Serbia in violation 
of U.S. and international sanctions.\61\ Press accounts 
indicate that Rich violated the U.N. trade embargo by dealing 
with Belgrade in a variety of commodities, including copper and 
oil.\62\ According to an article in The Oil Daily, at the time 
of the U.N. embargo, Serbia reportedly had a deal in place with 
Marc Rich to process crude oil in Romania.\63\
---------------------------------------------------------------------------
    \61\ Department of Treasury Document Production 000652 (Memorandum 
from R. Richard Newcomb, Director of the Office of Foreign Assets 
Control, Department of the Treasury, to Ronald K. Noble, Under 
Secretary for Enforcement, Department of the Treasury (Sept. 16, 1994)) 
(Exhibit 2).
    \62\ Michael Dobbs, Rich Made His Fortune by Breaking the Rules, 
Wash. Post, Mar. 13, 2001, at A1.
    \63\ Roger Benedict, U.N. Oil Cutoff of Serbia Hinges on Russia, 
China (Security Council Vote), Oil Daily, June 1, 1992, at 1.
---------------------------------------------------------------------------
    When asked at a Committee hearing about allegations 
relating to Marc Rich's transactions with rogue states, Rich's 
lawyer Jack Quinn responded ``I don't know the answer to 
that.'' \64\ When asked about the White House's knowledge and 
research of these activities, White House Counsel Beth Nolan 
told the Committee that she never received an intelligence 
briefing and never explained Rich's shady dealings to the 
President.\65\ While it may be understandable that Jack Quinn 
would not know--or at least not want to know--about Rich's 
dealings with so many dictatorships and rogue regimes, it is 
inexcusable that the White House failed to take the time to 
learn about these disturbing details.\66\
---------------------------------------------------------------------------
    \64\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 111 
(Mar. 1, 2001) (testimony of Jack Quinn).
    \65\ Id. at 374.
    \66\ The Committee, however, does not take the position that it was 
``understandable'' for Quinn not to have known about Rich's dealings 
with rogue states. While Quinn's actions may be legally permissible, 
one must think long and hard about the morality of Quinn's actions. 
Given Rich's status as a fugitive, common sense and due diligence 
should have led Quinn to inquire further into Rich's past dealings. 
However, the power of money is often enough to promote willful 
ignorance.
---------------------------------------------------------------------------
    It is clear that Rich built his fortune doing business 
without legal, ethical, or even moral restraints. He regularly 
dealt with corrupt officials, dictators and rogue regimes. U.S. 
and international embargoes and sanctions were not barriers to 
Rich, merely hurdles to be climbed over, under, or around. As 
is discussed in more detail below, it is shameful and an 
embarrassment to the United States that the Clinton 
Administration did not take adequate steps to determine the 
extent of Marc Rich's illegal and unethical business activities 
before the President granted his pardon. This failure by the 
Clinton Administration is especially troubling in light of the 
fact that Marc Rich built his fortune by trading with so many 
enemies of the United States.
B. The Criminal Charges Against Marc Rich and Pincus Green
            1. The Investigation of Rich and Green
    Marc Rich's illegal business practices in the United States 
came under the scrutiny of the United States government in the 
early 1980s. In the fall of 1981, staff from the Fraud Section 
of the Criminal Division of the Department of Justice called 
Assistant U.S. Attorney Morris ``Sandy'' Weinberg, Jr. of the 
Southern District of New York (``SDNY'').\67\ They told 
Weinberg of a lead they had received concerning a crude oil 
reseller named Marc Rich whose company had an office in New 
York City.\68\ As Weinberg and his fellow former prosecutor 
Martin Auerbach explained to the Committee during the first 
hearing on the Rich pardon, this initial lead on Marc Rich was 
developed through oil reseller prosecutions in Abilene, 
Texas.\69\ John Troland and David Ratliff of West Texas 
Marketing--who had been prosecuted for illegal oil reselling--
provided information about the offshore laundering of funds by 
Rich.\70\
---------------------------------------------------------------------------
    \67\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 97 (Feb. 
8, 2001) (prepared testimony of Morris ``Sandy'' Weinberg, Jr., and 
Martin J. Auerbach, former Assistant U.S. Attorneys for the S.D.N.Y., 
Department of Justice).
    \68\ Id.
    \69\ Id. at 97-98.
    \70\ Id.
---------------------------------------------------------------------------
    In December of 1981, when Weinberg flew to Texas to 
investigate, he obtained a furlough for the principals of West 
Texas Marketing (``WTM''), who took him to their office.\71\ 
Upon reviewing their records of WTM's dealings with Marc Rich, 
Weinberg confirmed that Rich earned $70 million in illegal oil 
resale profits in 1980 and 1981 and had funneled the money to 
his Swiss company in order to evade federal income tax and 
federal energy oil control regulations.\72\ As Weinberg 
testified to the Committee, it was then apparent to him that he 
and his office had uncovered ``the biggest tax fraud in 
history.'' \73\ As he further testified:
---------------------------------------------------------------------------
    \71\ Id. at 98.
    \72\ Id.
    \73\ Id. The eventual indictment accused Marc Rich's companies of 
evading taxes on over $100 million in unreported income.

        The case against Mr. Rich and Mr. Green was very 
        strong. . . . Like any fraud case, the evidence was 
        rife with false documents, inflated invoices, sham 
        transactions and off the books deals. The conspirators 
        kept track of the illegal profits in hand written 
        journals in what was described as the ``pot.'' . . . 
        [T]he evidence included meetings between co-
        conspirators and Marc Rich regarding the pots and the 
        scheme to funnel the illegal profits out of the country 
        to off-shore accounts.\74\
---------------------------------------------------------------------------
    \74\ Id. at 104.

    The illegal scheme that Weinberg uncovered stemmed from 
Marc Rich's evasion of specific Department of Energy (``DOE'') 
regulations. In September of 1980, pursuant to the Emergency 
Petroleum Allocation Act of 1973,\75\ the DOE promulgated 
regulations establishing the permissible average markup for oil 
reselling.\76\ The permissible price was different for 
different regulatory categories of crude oil. The categories 
contemplated by the regulations included: ``old'' or ``lower 
tier;'' ``new'' or ``upper tier;'' and ``stripper.'' \77\ Under 
the regulations, every seller or reseller of domestic crude oil 
was required to certify to the purchaser the respective amounts 
and prices of old oil, new oil, and stripper oil contained in 
the crude oil that was being sold.\78\ The regulations 
prohibited markups of more than 20 cents per barrel of oil for 
a reseller such as Marc Rich's company, Marc Rich + Co. 
International, Ltd. (``International'').\79\ International was 
also required to submit ERA-69 forms to the DOE on a monthly 
basis that set forth the dollar amount of any permissible 
average markup overcharges so that they could be immediately 
refunded to customers.\80\
---------------------------------------------------------------------------
    \75\ 15 U.S.C. Sec. 751, et seq.
    \76\ Indictment, U.S. v. Marc Rich, Pincus Green et al. 8-9 
(S.D.N.Y. Mar. 6, 1984) (S 83 Cr. 579) (Exhibit 4).
    \77\ Id. at 6. As the indictment states, ``Crude oil coming from a 
well at or below a designated 1972 level of production was labelled 
`old'; `new' oil referred to crude oil discovered since 1973 or oil 
obtained from existing wells in excess of the 1972 level of production; 
`stripper' oil referred to crude oil produced from a well whose average 
daily production was less then [sic] ten barrels.''
    \78\ Id. at 7.
    \79\ Id. at 8-9.
    \80\ Id. at 9.
---------------------------------------------------------------------------
    Beginning in September of 1980, Marc Rich and Pincus Green 
agreed with the principals of West Texas Marketing that when 
International was limited to the 20 cents per barrel markup, 
the huge profits from their crude oil transactions would be 
retained by WTM rather than being reflected on the books of 
International.\81\ These profits were referred to as the 
``pot.'' \82\ As the indictment against them would allege, to 
further conceal the scheme, Rich, Green and the principals at 
WTM conspired to have WTM prepare and mail invoices to 
International, which falsely indicated that WTM had sold oil 
barrels to International ``at the high world market price, when 
in truth and in fact . . . International was paying a far lower 
price upon WTM's agreement secretly to kickback to [Rich and 
Green] the huge profits held by WTM for . . . International in 
the `pot.' '' \83\
---------------------------------------------------------------------------
    \81\ Id. at 10-11.
    \82\ Id. at 11.
    \83\ Id. The manipulation of the oil categories by oil resellers 
such as Marc Rich and his companies was referred to as ``daisy 
chaining.'' As is explained in the indictment:

        GDuring the period of price controls, in order to evade 
      the regulations and produce huge profits, controlled oil 
      was on occasion sold through a series of oil resellers 
      known in the crude oil industry as a ``daisy chain.'' The 
      defendant INTERNATIONAL frequently participated as the 
      original reseller of controlled oil into a ``daisy chain.'' 
      The ``daisy chain'' was utilized by the original reseller 
      to make it extremely difficult to trace the movement of 
      controlled barrels and to facilitate alteration of the 
      certifications on controlled barrels into stripper barrels 
      (uncontrolled) which could then be sold at the much higher 
---------------------------------------------------------------------------
      world market price.

Id. at 7-8.
    The profits in these ``pots'' were moved out of the U.S. to 
foreign bank accounts at the direction of Marc Rich and Pincus 
Green.\84\ This would occur through sham foreign loss 
transactions involving Marc Rich + Co., A.G., (``A.G.'').\85\ 
From October 1980 through May 1981, Rich, Green, and their 
companies moved more than $23 million in income to offshore 
accounts from WTM ``pots.'' \86\ These fraudulent transactions 
were transmitted through telefaxes and wire transfers.\87\
---------------------------------------------------------------------------
    \84\ Id. at 11.
    \85\ Id. at 11-12.
    \86\ Id. at 12.
    \87\ Id. at 12-13.
---------------------------------------------------------------------------
    This scheme by Rich and Green was essentially repeated with 
another company, Listo Petroleum, for a total of $47 
million.\88\ Rich and Green also entered into false deduction 
transactions with Charter Crude Oil Company, as well as 
ARCO.\89\ In the case of Charter, at the direction of Marc 
Rich, International prepared fraudulent invoices purporting 
that International had purchased foreign crude oil from A.G. at 
its fair market value and subsequently sold it to a Charter 
subsidiary at a substantial discount.\90\ As a result, 
International fraudulently reduced its amount of taxable income 
by more than $31 million dollars.\91\ In the ARCO case, in the 
fall of 1980, Rich and Green's company Rescor invoiced their 
other company, International, for nearly $3 million. The 
invoice concerned a non-existent contract for the sale of 
foreign crude oil to Rescor by International. The fraudulent 
invoice made it appear that International had failed to provide 
oil to Rescor which subsequently had to purchase a similar 
quantity of oil from Arco at five dollars per barrel above the 
original contract price.\92\ As a result, International 
fraudulently reduced its amount of taxable income for 1980 by 
nearly $3 million.\93\
---------------------------------------------------------------------------
    \88\ Id. at 13, 15.
    \89\ Id. at 15-18.
    \90\ Id. at 16.
    \91\ Id.
    \92\ Id. at 17-18.
    \93\ Id. at 18.
---------------------------------------------------------------------------
    Finally, Weinberg uncovered evidence of Marc Rich and 
Pincus Green trading with Iran during the American hostage 
crisis. In 1979 and 1980, President Carter issued several 
executive orders and the Department of Treasury subsequently 
promulgated regulations that prohibited any American from 
trading with Iran without a special license from the Department 
of Treasury.\94\ The regulations further required all 
individuals engaging in trade with Iran to keep records to be 
available for examination by the Office of Foreign Assets 
Control.\95\ Nevertheless, on April 30, 1980, Marc Rich + Co., 
A.G. entered into a contract with the National Iranian Oil 
Company (``NIOC'') for the purchase of crude and fuel oil from 
May 1, 1980 through September 30, 1980.\96\ As the indictment 
indicates, from their offices in New York City, Rich and Green 
in turn sold 6,250,000 barrels of the Iranian oil to an oil 
company in Bermuda for a total of more than $200 million. In 
order to conceal this scheme, Rich and Green did not disclose 
to their banks in the United States that the ultimate 
beneficiary of the U.S. dollars was the NIOC.\97\ Rich and 
Green further devised a secret code for their interoffice cable 
communications to disguise the participation of the Iranian oil 
company.\98\ The scheme was completed through several wire 
transactions and transmissions, and ultimately caused United 
States dollars to be illegally transferred to Iran at the same 
time that Iran was holding American hostages.\99\
---------------------------------------------------------------------------
    \94\ Id. at 44-45. The executive orders issued pursuant to the 
International Economic Emergency Powers Act of 1977 included Executive 
Orders No. 12,170, 12,205, and 12,211.
    \95\ Id. at 45.
    \96\ Id.
    \97\ Id. at 46.
    \98\ Id. at 47.
    \99\ Id. at 47, 49. These charges were brought under 31 CFR 
Sec. Sec. 535.206(a)(4), 535.208, 535.701, and 50 USC Sec. 1705, and 18 
USC Sec. 2.
---------------------------------------------------------------------------
    In early 1982, the Southern District of New York began 
subpoenaing millions of documents from oil companies and crude 
oil resellers in the United States that had done business with 
Marc Rich.\100\ Prosecutors also served subpoenas on Marc 
Rich's companies in New York.\101\ The Southern District 
decided to subpoena Marc Rich + Co. A.G.--even though it was a 
Swiss company--because there were sufficient contacts through 
its American subsidiary to give them jurisdiction for enforcing 
document subpoenas.\102\ Rich, who had retained high-powered 
attorneys such as Edward Bennett Williams, Peter Fleming, and 
former federal judge Marvin Frankel, sought to quash the grand 
jury subpoenas.\103\ However, United States District Judge 
Leonard Sand denied the Rich team's motion to quash and ordered 
A.G. to produce the documents from Switzerland.\104\ The Second 
Circuit Court of Appeals affirmed Judge Sand's decision in May 
of 1983.\105\ When Marc Rich + Co. A.G. refused to produce the 
documents, Judge Sand held the company in contempt and ordered 
a $50,000 per day fine in order to compel production of the 
documents.\106\ Nevertheless, Rich and his company refused to 
produce the documents or pay the fine.\107\
---------------------------------------------------------------------------
    \100\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 99 (Feb. 
8, 2001) (prepared testimony of Morris ``Sandy'' Weinberg, Jr., and 
Martin J. Auerbach, former Assistant U.S. Attorneys for the S.D.N.Y., 
Department of Justice).
    \101\ Id.
    \102\ Id.
    \103\ Id.
    \104\ Id.
    \105\ Id.
    \106\ Id. at 100.
    \107\ Id.
---------------------------------------------------------------------------
    Rich's behavior during the litigation soon became even more 
confrontational and deceptive. As the Southern District of New 
York was to learn, on June 29, 1983, Rich quietly sold off his 
company's only American asset.\108\ Judge Sand called the sale 
a ``ploy to frustrate the implementation of the court's 
order,'' and thereby ordered a freeze of A.G.''s assets in the 
United States.\109\ The Second Circuit Court of Appeals also 
concluded that the sale was a fraud.\110\ As a result of these 
rulings by the courts, Rich and his lawyers agreed to negotiate 
a resolution of the contempt issue. A.G. agreed to pay the more 
than $1 million in contempt fines that had accumulated and to 
continue paying the contempt fines until all of the documents 
had been produced from Switzerland.\111\
---------------------------------------------------------------------------
    \108\ Id.
    \109\ Id.
    \110\ Id.
    \111\ Id. at 101.
---------------------------------------------------------------------------
    At first, Rich's company appeared to be complying with the 
agreement by producing hundreds of thousands of documents from 
Switzerland. However, on August 9, 1983, four days after the 
agreement, the Southern District received an anonymous tip that 
subpoenaed documents were being secreted out of the U.S. by a 
paralegal of the law firm Milgrim Thomajan & Lee.\112\ In 
responding to the tip, the Southern District seized two steamer 
trunks full of subpoenaed documents from a Swiss Air 
flight.\113\ As a result of this incident, Judge Sand ordered 
the production of every document of the Marc Rich companies in 
the world that had been subpoenaed.\114\ Rich and his legal 
team argued that the Swiss government had already seized all of 
the remaining documents, thereby rendering compliance with the 
agreement they had reached impossible.\115\ Judge Sand 
nevertheless ruled that the contempt fines should 
continue.\116\ In total, Marc Rich + Co. A.G. paid over $21 
million in contempt fines over the course of the 
litigation.\117\
---------------------------------------------------------------------------
    \112\ Id. When asked about this episode at the Committee's hearing, 
Jack Quinn testified ``what I have been told is that those documents 
were going to Switzerland for the purpose of being reviewed for 
privilege by the lawyers.'' Id. at 113 (testimony of Jack Quinn). In 
response to this claim, Martin Auerbach testified: ``With respect to 
the documents that were being slipped out of the country, the 
suggestion was never that those were being reviewed for attorney-client 
privilege. It was simply that it would be more convenient for counsel 
to review them in Switzerland then [sic] to review them in New York. 
Now, we had tons and tons of documents delivered to us. These two 
steamer trunks were slipping out. We didn't get a call from them 
saying, you know, we've got some people over in Zug with nothing better 
to do than to look at documents; would you mind if we took them over 
there outside of the jurisdiction at the time when we're in contempt 
for refusing to produce documents from Switzerland?'' Id. (testimony of 
Martin J. Auerbach, former Assistant U.S. Attorney for the S.D.N.Y., 
Department of Justice).
    \113\ Id. at 101 (prepared testimony of Morris ``Sandy'' Weinberg, 
Jr., and Martin J. Auerbach, former Assistant U.S. Attorneys for the 
S.D.N.Y., Department of Justice).
    \114\ Id.
    \115\ Id. at 101-02. The Committee does not know Rich's precise 
role in orchestrating this action by the Swiss government. Rich's power 
in that country makes it reasonable to assume that he might have played 
a part in creating the condition that made his representations in the 
United States possible. The Committee is not aware of the Swiss 
government penalizing Rich or taking any other action against him.
    \116\ Id. at 102.
    \117\ Id.
---------------------------------------------------------------------------
    Rich's attorneys made a number of attempts to settle the 
case before an indictment was issued. When Rich hired Edward 
Bennett Williams to represent him, Williams assured him that he 
could settle the case if Rich paid a large fine, telling Rich 
``I can get rid of it for $30 million.'' \118\ Williams then 
went to Sandy Weinberg and asked how much the government wanted 
to settle the case. When Weinberg told Williams he was not 
interested, Williams asked Weinberg what he had in mind.\119\ 
Weinberg responded ``J-A-I-L.'' \120\ Later, Williams would 
offer as much as $100 million to settle the Rich case.\121\ All 
of these offers were rejected.
---------------------------------------------------------------------------
    \118\ Evan Thomas, The Man to See: Edward Bennett Williams 415 
(1991).
    \119\ Id. at 416.
    \120\ Id.
    \121\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 103 
(Feb. 8, 2001) (prepared testimony of Morris ``Sandy'' Weinberg, Jr., 
and Martin J. Auerbach, former Assistant U.S. Attorneys for the 
S.D.N.Y., Department of Justice).
---------------------------------------------------------------------------
            2. The Indictment
    In September of 1983, a federal grand jury in New York 
returned a 51-count indictment against Marc Rich, Pincus Green, 
and their companies.\122\ The original indictment was 
restructured into a 65-count indictment in March of 1984.\123\ 
All of the first 42 counts were charged against Marc Rich, 
Pincus Green, Clyde Meltzer, A.G., and Marc Rich + Co, 
International Ltd. The superseding indictment was arranged to 
include in counts 1 through 23 the scheme to defraud the 
IRS.\124\ These charges were brought pursuant to 18 USC 
Sec. 1343, the federal statute prohibiting wire fraud.\125\ 
These charges related to the fraudulent transactions among WTM, 
and Marc Rich's companies discussed above. Counts 24 through 38 
included the scheme to defraud the Department of Energy, and 
were brought pursuant to 18 USC Sec. 1341, prohibiting mail 
fraud.\126\ Count 39 and 40 were racketeering charges brought 
under the RICO statute, 18 USC Sec. 1962(c).\127\ Counts 41 and 
42 included two tax evasion counts for Marc Rich + Co. 
International's 1980 and 1981 tax returns, covering an amount 
totaling over $100 million in unreported income which was 
concealed by the efforts of Rich, Green, Meltzer, and Rich's 
two companies.\128\ As stated in the indictment, International 
was able to evade more than $49 million in taxes.\129\ These 
counts were also brought against Marc Rich and Pincus Green 
personally. The tax and racketeering counts were approved and 
authorized by the Department of Justice.\130\ Counts 43 through 
57 alleged that Rich defrauded the Department of Treasury for 
his transactions with the Iranians during the oil embargo and 
the American hostage crisis. Finally, counts 57 through 65 
charged Rich with ``trading with the enemy'' for Rich's secret 
deals with the Iranians.\131\ In the superseding indictment, 
these charges were not leveled against the companies. As a 
letter accompanying the indictment states, ``[t]he primary 
focus of those counts has always been the activities of the 
American individuals, Marc Rich and Pincus Green.'' \132\
---------------------------------------------------------------------------
    \122\ Id.
    \123\ See Indictment, U.S. v. Marc Rich, Pincus Green et al. 
(S.D.N.Y. Mar. 6, 1984) (S 83 Cr. 579) (Exhibit 4).
    \124\ Id. at 19-22.
    \125\ Id. at 22.
    \126\ Id. at 22-25.
    \127\ Id. at 33-34.
    \128\ Id. at 40-42.
    \129\ Id.
    \130\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 102-03 
(Feb. 8, 2001) (prepared testimony of Morris ``Sandy'' Weinberg, Jr., 
and Martin J. Auerbach, former Assistant U.S. Attorneys for the 
S.D.N.Y., Department of Justice).
    \131\ U.S. v. Marc Rich, Pincus Green et al. (S.D.N.Y. Mar. 6, 
1984) (S 83 Cr. 579). See also 50 U.S.C. Sec. 1705.
    \132\ Cover letter to superseding indictment, U.S. v. Marc Rich, 
Pincus Green et al. (S.D.N.Y. Mar. 6, 1984) (S 83 Cr. 579) (Exhibit 4).
---------------------------------------------------------------------------
            3. Rich and Green Flee the Country
    Even though their companies eventually pled guilty and paid 
heavy fines, Rich and Green personally refused to face the U.S. 
justice system. Rich and Green were out of the country when 
their indictments were handed down. They refused to return to 
the United States, even after warrants were issued for their 
arrest. As Weinberg and Auerbach explained to the Committee, 
``[b]y the time of the indictment, Marc Rich and Pincus Green 
had made it clear that they would not return to the United 
States to face the charges. Apparently, they had quietly left 
the United States in June 1983 at a time when their lawyers 
were attempting to negotiate a resolution of the case.'' \133\ 
Even Rich's own lead attorney, Edward Bennett Williams, was 
shocked by Rich's conduct:
---------------------------------------------------------------------------
    \133\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 103 
(Feb. 8, 2001) (prepared testimony of Morris ``Sandy'' Weinberg, Jr., 
and Martin J. Auerbach, former Assistant U.S. Attorneys for the 
S.D.N.Y., Department of Justice). It should be noted that by this 
point, Rich and Green had already renounced their U.S. citizenship and 
become citizens of Spain and perhaps Bolivia.

        Rich responded to the warrant for his arrest by 
        refusing to return from Switzerland. Williams was 
        standing in the office of Marvin Davis in Los Angeles 
        when he heard the news that his client was on the lam. 
        According to Davis, Williams shouted in the phone, 
        ``You know something, Marc? You spit on the American 
        flag. You spit on the jury system. Whatever you get, 
        you deserve. We could have gotten the minimum. Now 
        you're going to sink.'' \134\
---------------------------------------------------------------------------
    \134\ Evan Thomas, The Man to See: Edward Bennett Williams 417 
(1991). Rich denied Davis' account of this conversation, saying, 
``There is not a shred of truth in it.''

Despite the outrage of their own lawyers, as well as the 
prosecutors, Rich and Green never returned to the country to 
face the charges. They remained fugitives in Switzerland for 
more than seventeen years until they received their pardons 
from President Clinton.
            4. The Corporate Guilty Pleas
    Notwithstanding the fact that Rich and Green would not 
return to face the charges against them, their companies 
entered plea negotiations with the government. A year after the 
indictment was handed down, Marc Rich's companies pled guilty 
to evading $50 million in taxes. In the allocution on October 
11, 1984, Peter Fleming, counsel for Marc Rich + Co. 
International, Ltd. stated to the court:

        Beginning in September 1980 International generated 
        millions of dollars of income from crude oil 
        transactions which International should have disclosed 
        but intentionally did not disclose to the Internal 
        Revenue Service and the Department of Energy.

                                *  *  *


        In connection with matters within the jurisdiction of 
        agencies of the United States, specifically the 
        Department of Energy and the Internal Revenue Service, 
        International and A.G. knowingly and willfully made 
        those documents and the ERA 69s filed with the 
        Department of Energy which were false in that they 
        failed to disclose material facts regarding the actual 
        income from those crude oil transactions, in violation 
        of Title 18, United States Code, Section 1001, which is 
        the charging statute of counts 1 through 38.

                                *  *  *


        In addition, by knowingly and willfully failing to 
        report at least $50 million of taxable income generated 
        from these transactions for the years 1980 and 1981, 
        International committed income tax evasion for these 
        years in violation of Title 26, United States Code, 
        Section 7201.\135\
---------------------------------------------------------------------------
    \135\ Transcript of Allocution, U.S. v. Marc Rich + Co., A.G. et 
al. 18-19 (S.D.N.Y. Oct. 11, 1984) (S 83 Cr. 579) (Exhibit 5).

Counsel for Marc Rich + Co. A.G. then stated to the court, 
``[a]s you know, A.G. is charged only in counts 1 through 38 of 
this information, and A.G. adopts Mr. Fleming's statements in 
connection with those counts.'' \136\ As part of their guilty 
plea, A.G. and International (which by then had been renamed 
``Clarendon, Ltd.''), also agreed to pay the United States $150 
million,\137\ and agreed to waive any right to recover the $21 
million in fines they had already paid the government.\138\ The 
total amount that the companies paid to the government for 
their crimes was $200 million.\139\ As then-United States 
Attorney Rudolph Giuliani explained in court, this represented 
the largest amount of money ever recovered by the United States 
in a criminal tax evasion case.\140\
---------------------------------------------------------------------------
    \136\ Id. at 20.
    \137\ Id. at 3.
    \138\ Id. at 4.
    \139\ Id.
    \140\ Id. at 5.
---------------------------------------------------------------------------
    The guilty pleas and fines paid by the companies controlled 
by Marc Rich and Pincus Green clearly demonstrate the guilt of 
the two principals. Based on the overwhelming evidence against 
them, it is no wonder Rich and Green fled the country rather 
than face trial. The evidence, including the admissions by Marc 
Rich's companies, also explains why Martin Auerbach of the 
Southern District of New York could confidently respond to Jack 
Quinn's criticism at the Committee's hearing, stating, ``Mr. 
Quinn has suggested to the Committee and to the Nation that we 
had a legal house of cards. Well, if we did, it was all aces.'' 
\141\
---------------------------------------------------------------------------
    \141\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 106 
(Feb. 8, 2001) (testimony of Martin J. Auerbach, former Assistant U.S. 
Attorney for the S.D.N.Y., Department of Justice).
---------------------------------------------------------------------------

C. Attempts to Bring Rich and Green to Justice

            1. Attempts to Extradite Rich and Green
    After Rich and Green fled the country in anticipation of 
their indictment, the Southern District of New York made many 
attempts to have foreign governments extradite the two 
fugitives in order to bring them back to the country to stand 
trial on the numerous charges against them. On July 20, 1984, 
the United States requested extradition of Rich and Green from 
Switzerland. That request was rejected by the Swiss government 
in September of 1984 on the basis that the offenses charged 
against Rich and Green were ``fiscal violations'' and 
violations of ``provisions concerning currency, trade policy 
and economic policy'' \142\ and that the government of 
Switzerland did not recognize the charges against Rich and 
Green as extraditable crimes. In June of 1994, the Justice 
Department attempted to extradite Rich and Green from Israel, 
but the Israeli government also turned down the request. 
Israel's Attorney General, Michael Ben-Ya'ir, told the U.S. 
Government that the extradition treaty between the two 
governments did not include fiscal offenses.\143\ And even 
though Rich had become a citizen of Spain, prosecutors could 
not extradite him from that country because, like Switzerland 
and Israel, Spain does not extradite its citizens for tax 
evasion.
---------------------------------------------------------------------------
    \142\ Unofficial translation of a note delivered on September 25, 
1984, by the Office for Police Matters to the Embassy of the United 
States. See ``They Went Thataway: The Strange Case of Marc Rich and 
Pincus Green,'' Hearing Before the Comm. on Govt. Operations, 102d 
Cong. 3 (May 27, 1992).
    \143\ Bo'az Ga'on, Rich as Korach, Ma'ariv Weekend Magazine, Oct. 
1, 1999 (Exhibit 6).
---------------------------------------------------------------------------
            2. Marc Rich and Pincus Green's Attempts to Renounce Their 
                    Citizenship
    After fleeing the United States, Rich and Green attempted 
to renounce their U.S. citizenship for the specific purpose of 
avoiding extradition on the charges against them. According to 
a U.S. government memorandum from the Embassy in Madrid, Rich 
expatriated himself on September 3, 1982, prior to his 
indictment, and became a naturalized Spaniard on February 11, 
1983.\144\ As Rich explained in a letter to the U.S. Consul 
General in Zurich, ``I was naturalized under the laws of Spain, 
swore an oath of allegiance to the King of Spain, and formally 
stated that I thereby renounced U.S. nationality.'' \145\ On 
May 27, 1983, Green, and perhaps Rich, were naturalized as 
Bolivian citizens according to U.S. State Department 
cables.\146\ In the case of Green, a letter from the Ministry 
of the Interior in Bolivia states that ``the privilege of 
Bolivian nationality has been given to Pincus Green Bergstein, 
who previously renounced his nationality of origin and complied 
with the required procedures determined by current legal 
regulations.'' \147\ According to a letter from the Department 
of Justice to Congressman Robert Wise in November of 1991, Rich 
and Green also became citizens of Israel in 1983.\148\ The 
pardon application submitted to the White House by Jack Quinn 
also lists Green as a citizen of Switzerland, although it does 
not list Rich as a Swiss citizen, and it appears that Rich is, 
in fact, not a Swiss citizen.\149\
---------------------------------------------------------------------------
    \144\ Department of State Document Production (Government 
Memorandum from U.S. Embassy in Madrid to U.S. Department of State, 
Aug. 25, 1983) (Exhibit 7).
    \145\ Department of State Document Production (Letter from Marc 
Rich to Ruth H. Van Heuven, U.S. Consul General, Switzerland (Oct. 27, 
1992)) (Exhibit 8). In this and other letters, Rich claims that he 
became a citizen of Spain in July of 1982, earlier than the date 
indicated by the U.S. government. Spanish government documents appear 
to confirm this. The Second Circuit Court of Appeals also affirmed a 
district court ruling that Rich's attempt to renounce his citizenship 
in Madrid had failed. The Second Circuit held:

        GThe evidence strongly supports the district court's 
      finding that Rich had no intention whatsoever to relinquish 
      his American citizenship prior to commencement of this 
      action. Despite mouthing words of renunciation before a 
      Spanish official, he refused to acknowledge such 
      renunciation before the United States Consul in Madrid 
      before this action commenced. Instead, he brought a Swiss 
      action as an American national, traveled on his American 
      passport, and publicized himself in a commercial register 
---------------------------------------------------------------------------
      as a United States citizen.

Action S.A. v. Marc Rich & Co., Inc., 951 F.2d 504, 507 (2d Cir. 1991).
---------------------------------------------------------------------------
    \146\ Department of State Document Production (Letter from the 
American Consul to Pincus Green (Dec. 19, 1983)) (Exhibit 9). The State 
Department apparently believed that Rich and Green entered Bolivia 
illegally because of the restrictions on their passports, which would 
have jeopardized their claim of Bolivian citizenship. See U.S. Marshals 
Service Document Production (Department of State Cable, Oct. 11, 1983) 
(Exhibit 10).
    \147\ Department of State Document Production (Letter from Dr. 
Emilio Perez Barrios, Sub-Secretary of Immigration, Bolivian Ministry 
of Interior, to the American Consul (Sept. 9, 1983)) (Exhibit 11).
    \148\ Department of Justice Document Production DOJ/SDNY-MR-00008-
09 (Letter from W. Lee Rawls, Assistant Attorney General, Office of 
Legislative Affairs, Department of Justice, to the Honorable Robert E. 
Wise, Jr., Chairman, Subcommittee on Govt. Information, Justice, and 
Agriculture, Comm. on Govt. Operations (Nov. 21, 1991)) (Exhibit 12).
    \149\ Petition for Pardon for Marc Rich and Pincus Green 1, 3 (Dec. 
11, 2000) (Appendix III).
---------------------------------------------------------------------------
    In 1983, the State Department informed the Southern 
District of New York that Rich was seeking to renounce his U.S. 
citizenship. The American embassy attempted to contact Rich to 
have him fill out a questionnaire to determine his citizenship, 
but he never responded.\150\ Rich and Green also never 
responded to letters from the American Consul in Bern, 
Switzerland, attempting to determine their citizenship. On 
September 29, 1993, the U.S. State Department revoked Rich's 
American passports because of the ``outstanding federal felony 
warrant of arrest issued by the U.S. District Court for the 
Southern District of New York.'' \151\ The next day, the State 
Department also revoked Pincus Green's passport.\152\
---------------------------------------------------------------------------
    \150\ Department of State Document Production (Letter from Julian 
L. Bartley, Consul, Embassy of the United States of America in Madrid, 
to Marc Rich (Mar. 25, 1983)) (Exhibit 13).
    \151\ U.S. Marshals Service Document Production (State Department 
Cable, Sept. 29, 1983) (Exhibit 14).
    \152\ U.S. Marshals Service Document Production (State Department 
Cable, Sept. 30, 1983) (Exhibit 15).
---------------------------------------------------------------------------
    The confusion over Marc Rich's citizenship status also 
became an issue of concern to the U.S. Treasury Department in 
November of 1991. A letter written by the Office of Foreign 
Assets Control prompted the State Department to make a 
determination of Rich's citizenship. In its response of April 
14, 1992, the State Department made a final determination that 
Marc Rich had failed to renounce his citizenship, and was still 
a U.S. citizen.\153\ The conclusion was based on the fact that 
the Department never approved Rich's Certificate of Loss of 
Nationality.\154\ It was also based on the fact that Rich did 
not demonstrate the requisite intent to lose his U.S. 
Citizenship--in part because he used his U.S. passport to 
travel to the United States after he became a Spanish 
citizen.\155\
---------------------------------------------------------------------------
    \153\ Department of Treasury Document Production 000660-61 (Letter 
from Carmen A. DiPlacido, Director of the Office of Citizens Consular 
Services, Department of State, to Richard Newcomb, Director of the 
Office of Foreign Assets Control, Department of the Treasury (Apr. 14, 
1992)) (Exhibit 16).
    \154\ Id.
    \155\ Id.
---------------------------------------------------------------------------
    Despite the U.S. Government's official finding that Rich is 
still a U.S. citizen, Rich and his lawyers claim that he is not 
a U.S. citizen. When he appeared on television after the Rich 
pardon, Jack Quinn stated ``he is a U.S. citizen.'' \156\ 
However, when he appeared before the Committee, Quinn stated 
that he ``misspoke'' when he was on Meet the Press, and took 
the position that Rich had indeed renounced his citizenship. 
Sandy Weinberg, testifying with Quinn, observed:
---------------------------------------------------------------------------
    \156\ Meet the Press (NBC television broadcast, Jan. 28, 2001).

        I suppose when he [Marc Rich] heard on television from 
        Mr. Quinn that he was a citizen, I'm sure it did 
        concern him whether or not he had a problem over the 
        last 20 years. I suspect that . . . Mr. Quinn got a 
        call the next day saying ``no, I'm not a citizen'' 
        because I believe that there are some very significant 
        tax implications if he's been a citizen all these 
        years.\157\
---------------------------------------------------------------------------
    \157\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 167 
(Feb. 8, 2001) (testimony of Morris ``Sandy'' Weinberg, Jr., former 
Assistant U.S. Attorney for the S.D.N.Y., Department of Justice).
---------------------------------------------------------------------------
            3. U.S. Attempts to Apprehend Rich and Green
    Between 1984 and 1992, the Department of Justice submitted 
five provisional arrest requests to various countries in an 
attempt to apprehend Rich and Green.\158\ None of these 
attempts were successful. As early as October 9, 1985, Rich and 
Green were listed as wanted international criminals by the U.S. 
National Central Bureau of Interpol.\159\ In 1987, Interpol 
issued an international ``red notice'' (warrant) that requested 
the provisional arrest of Rich and Green with the eventual goal 
of extradition.\160\ On several occasions, the FBI and the U.S. 
Marshals Service appeared ready to apprehend the two fugitives. 
One operation set up by the Marshals Service to snare Rich, 
referred to as ``the Otford Project,'' was nearly 
successful.\161\ In the fall of 1987, a U.S. Marshal assigned 
to the project barely missed apprehending Rich in France after 
he canceled a meeting with an African oil minister.\162\ A few 
months later, in November of 1987, the U.S. Marshals Service 
again came close to capturing Rich. They were tipped off by a 
businessman close to Rich that Rich would be taking a private 
plane to England for a weekend party. The Marshals set the trap 
for Rich at the Biggen Hill Airport in Kent. However, thick fog 
settled in over England, and Rich's plane turned back to 
Switzerland.\163\
---------------------------------------------------------------------------
    \158\ See ``They Went Thataway: The Strange Case of Marc Rich and 
Pincus Green,'' Comm. on Govt. Operations, 102d Cong. 10 (May 27, 1992) 
(quoting Letter from W. Lee Rawls, Assistant Attorney General, Office 
of Legislative Affairs, Department of Justice, to the Honorable Robert 
E. Wise, Jr., Chairman, Subcommittee on Govt. Information, Justice, and 
Agriculture, Comm. on Govt. Operations (received Oct. 11, 1991)).
    \159\ Interpol Document Production (Wanted International Criminal 
Request, Oct. 9, 1985) (Exhibit 17). The document itself lists Rich and 
Green as wanted for the indictments in the Southern District of New 
York for wire fraud, mail fraud, income tax evasion, racketeering, 
racketeering conspiracy, and trading with the enemy.
    \160\ Interpol Document Production (Interpol International Red 
Notice, June 4, 1992) (Exhibit 18).
    \161\ Craig Copetas, The Sovereign Republic of Marc Rich, 
Regardie's, Feb. 1, 1990, at 46.
    \162\ Id.
    \163\ Id.
---------------------------------------------------------------------------
    In 1986, prior to the international arrest warrant being 
issued, Rich had another brush with the law. Rich had been 
asked by his wife Denise to visit her in London. After the 
visit, Rich was at Heathrow airport to catch the return 
Swissair flight to Zurich. As he approached the gate, Rich 
apparently noticed that the security staff was conducting a 
complete search of luggage and identification.\164\ Rather than 
submit to the search, Rich apparently went to a public 
telephone and left three checks payable to him for 
1.6 million stuck between the pages of a telephone 
book.\165\ Free of the checks that Rich thought would identify 
him to the British authorities, Rich then boarded the flight 
for Zurich.\166\
---------------------------------------------------------------------------
    \164\ Id.
    \165\ Id.
    \166\ Id.
---------------------------------------------------------------------------
    In September of 1991, the FBI and Interpol attempted to 
arrest Rich in Finland.\167\ According to a Finnish businessman 
who helped the FBI with the matter, Rich was tipped off that he 
would be arrested at the Helsinki airport, and he therefore 
turned his plane around before landing.\168\ Other failed 
attempts to arrest Rich are indicated by several documents 
produced to the Committee. As an Interpol cable indicates, Rich 
was expected to be in Moscow both in May and September of 1992. 
Attempts were made at the Justice Department in September of 
that year to ``insure a provisional arrest warrant is in place 
should [Rich] appear in Moscow.'' \169\ In March of 1992, the 
U.S. Attorney for the Southern District of New York, as well as 
the Office of International Affairs at the Justice Department, 
made a request for Interpol to assist in apprehending Rich in 
Dushanbe, Tajikistan, based on information that he would be 
meeting with the new republic's prime minister.\170\ In fact, 
Interpol sent a senior officer directly to Dushanbe carrying 
the United States' provisional arrest request.\171\ A request 
for the arrest of Rich was also made in anticipation of his 
arrival in Czechoslovakia in February of 1992, when Rich was 
negotiating the purchase of the Slovak Aluminum Company.\172\ 
Yet another document indicates that provisional arrest warrants 
were also issued for Marc Rich in France, Portugal, and 
Norway.\173\
---------------------------------------------------------------------------
    \167\ Interpol Document Production (Letter from Darrell W. Mills, 
Chief, Interpol-USNCB (1991)) (Exhibit 19).
    \168\ Telephone Interview with Pertti Ruoho, Finnish Oil Trader 
(Feb. 22, 2001). See also Letter from Darrell W. Mills, Chief, 
Interpol-USNCB (1991)) (Exhibit 19).
    \169\ Interpol Document Production (Interpol-USNCB transmission, 
Sept. 1, 1992) (Exhibit 20).
    \170\ Interpol Document Production (Interpol-USNCB transmission, 
1992) (Exhibit 21).
    \171\ Id.
    \172\ Interpol Document Production (Fax from Donald S. Donovan, 
Assistant Chief, Interpol-USNCB, to Don Ward, Deputy Chief, U.S. 
Marshals Service (Feb. 21, 1992)) (Exhibit 22).
    \173\ Interpol Document Production 000317 (Identifiers on Marc 
Rich, Nov. 19, 1991) (Exhibit 23).
---------------------------------------------------------------------------
    It is difficult to believe that Marc Rich went from being 
an international fugitive, sought by teams of Marshals across 
the world, to a free man with the simple stroke of a pen. The 
effort to apprehend Marc Rich was the subject of intense law 
enforcement, diplomatic, and Congressional interest. Beyond the 
obvious negative effects of the Rich pardon, it also had a 
demoralizing effect on the individuals who tried for so long to 
track down Rich. In addition, it undermines U.S. authority to 
apprehend criminal fugitives. When the United States government 
attempts to apprehend someone by utilizing Interpol and working 
with law enforcement in foreign countries, it is reasonable to 
assume that those persons being sought should have to face 
trial in the United States. By granting pardons to Rich and 
Green, international law enforcement efforts on behalf of the 
United States were seriously undermined.
            4. 1992 Congressional Hearings
    The Marc Rich matter and the failure of the government to 
apprehend him was an issue of great interest to this Committee 
when it was under a Democratic chairmanship in the early 1990s. 
In particular, Congressman Robert Wise held three days of 
hearings on the matter when he served as chairman of the 
Subcommittee on Government Information, Justice, and 
Agriculture of the Committee on Government Operations.\174\ The 
hearings, entitled ``The Strange Case of Marc Rich: Contracting 
with Tax Fugitives and At Large in the Alps,'' also resulted in 
two Committee reports. One of those reports, entitled ``They 
Went Thataway: The Strange Case of Marc Rich and Pincus 
Green,'' focused on the efforts of the United States to 
apprehend the two fugitives.\175\
---------------------------------------------------------------------------
    \174\ The Government Information, Justice, and Agriculture 
Subcommittee held three separate Marc Rich hearings on December 4, 
1991, February 18, 1992, and March 5, 1992, entitled ``The Strange Case 
of Marc Rich: Contracting with Tax Fugitives and At Large in the 
Alps.''
    \175\ ``They Went Thataway: The Strange Case of Marc Rich and 
Pincus Green,'' Hearing Before the Comm. on Govt. Operations, 102d 
Cong. (May 27, 1992).
---------------------------------------------------------------------------
    Congressman Wise and his Subcommittee criticized the Reagan 
and Bush Administrations for failing to take adequate steps to 
apprehend Marc Rich. At a hearing on December 4, 1991, 
Congressman Mike Synar was particularly critical of the 
Department of Justice for failing to apprehend the fugitives:

        It is unacceptable that the Justice Department has 
        failed to show up today. It is unacceptable that they 
        have failed to enforce the law in this very important 
        matter, and as the chairman pointed out, in the case of 
        the No. 1 tax abuser in our history. Can there be 
        little wonder, can there be little wonder why Americans 
        have lost confidence with respect to this government's 
        ability to enforce the laws? And can there be little 
        wonder why most Americans believe there are two sets of 
        laws in this country, one for the rich, no pun 
        intended, and one for the rest of us? \176\
---------------------------------------------------------------------------
    \176\ ``The Strange Case of Marc Rich: Contracting with Tax 
Fugitives and At Large in the Alps,'' Hearing Before the Govt. 
Information, Justice, and Agriculture Subcommittee of the Comm. on 
Govt. Operations, 102d Cong. 7 (Dec. 4, 1991) (statement of the 
Honorable Mike Synar).

    The Committee reached similar conclusions in its 1992 
reports on the Rich matter, stating, for instance, that the 
U.S. government ``lacked the political will to effect the 
return of these fugitives[.]'' \177\ The Subcommittee urged 
``that the Department of Justice rejuvenate its efforts to 
apprehend the fugitives Marc Rich and Pincus Green and that it 
become a high profile matter for the U.S. Government.'' The 
report continued to admonish, stating, ``[t]he continuing 
failure to return these fugitives to the United States to stand 
trial before their fellow citizens only furthers the idea `that 
there are . . . two standards of justice in the United States . 
. . one for accused criminals without money and there's one for 
accused criminals with money.' '' \178\
---------------------------------------------------------------------------
    \177\ ``They Went Thataway: The Strange Case of Marc Rich and 
Pincus Green,'' Hearing Before the Comm. on Govt. Operations, 102d 
Cong. 37 (May 27, 1992).
    \178\ Id. at 34.
---------------------------------------------------------------------------
    The second report by the Subcommittee, ``Coin, Contracting, 
and Chicanery: Treasury and Justice Departments Fail to 
Coordinate,'' focused on the failure of the U.S. government to 
keep Rich from receiving government contracts after he fled the 
U.S.\179\ The Subcommittee concluded that Rich's Clarendon firm 
continued to provide the U.S. Mint with metals despite being 
debarred from government contracting.\180\ The Subcommittee 
also criticized the Justice and Treasury Departments for 
failing to take any action against Clarendon for over three 
years because of a series of missteps and 
miscommunications.\181\
---------------------------------------------------------------------------
    \179\ ``Coins, Contracting, and Chicanery: Treasury and Justice 
Departments Fail to Coordinate,'' Hearing Before the Comm. on Govt. 
Operations, 102d Cong. (May 27, 1992).
    \180\ Id. at 18.
    \181\ Id. at 19.
---------------------------------------------------------------------------
            5. Actions Taken by the U.S. Against Rich's Business 
                    Interests
    After they fled the country, several federal agencies took 
actions against Rich and Green's businesses. Notwithstanding 
their indictment and fugitive status, Rich and Green continued 
to contract with several agencies within the U.S. government. 
Companies controlled by Rich and Green held contracts with the 
U.S. Mint as well as the U.S. Department of Agriculture. These 
contracts continued for several years until they were 
eventually reviewed by Congress and relevant agencies. The 
Department of the Treasury also was forced to block money 
destined for Rich and Green because of their companies' 
dealings with Cuba.
                a. U.S. Mint Contract Cancellation
    In the wake of Rich's indictment, in 1985, one of his 
companies, Clarendon, Ltd., was debarred from contracting with 
the federal government by the Defense Logistics Agency. 
However, the debarment lasted only three years. Soon after that 
period, in July of 1988, Clarendon, Ltd. began contracting with 
the U.S. Mint to supply raw metal for producing coins. From 
1989 through 1992, Clarendon won numerous contracts to supply 
the mint with copper, nickel, and zinc.\182\
---------------------------------------------------------------------------
    \182\ ``The Strange Case of Marc Rich: Contracting with Tax 
Fugitives and At Large in the Alps,'' Hearing Before the Govt. 
Information, Justice, and Agriculture Subcommittee of the Comm. on 
Govt. Operations, 102d Cong. 58 (Dec. 4, 1991) (statement of Kenneth 
Gubin, Chief Counsel, U.S. Mint).
---------------------------------------------------------------------------
    Clarendon was able to secure the metal contracts because, 
from mid-1988 on, the company was not listed on the GSA's 
``Parties Excluded from Procurement Programs'' list. This was 
possible in part because Marc Rich set up the management of the 
company so that he was not the majority stockholder. By 
controlling 49 percent of Clarendon's stock, Rich could claim 
that he did not have control over the company's business 
decisions. This move, however, was part of a scheme by Marc 
Rich in which he purchased back the remaining 51 percent of 
Clarendon through a wholly owned subsidiary of Marc Rich + Co., 
A.G.\183\ By the time Clarendon was reaping the benefits of the 
new contract with the Mint, Marc Rich was in full control of 
the company. The contracts were reported to be worth up to 
$45.5 million to Marc Rich's company.\184\ As discussed above, 
this prompted congressional hearings and a subsequent report. 
Congressman Robert Wise of West Virginia, who chaired the 
hearings, stated to the press, ``[e]very time I reach into my 
pocket for some change, I have to wonder if there's a little 
bit of Marc Rich in there.'' \185\ This attention by Congress 
eventually played a part in ending Rich's contracts with the 
U.S. Mint. In a letter on February 27, 1992, Rich's lawyers 
announced that, ``Clarendon does not intend to participate in 
bid or contract opportunities with the Mint in the foreseeable 
future.'' \186\
---------------------------------------------------------------------------
    \183\ This scheme also led to a civil action against the company. 
See U.S. v. Clarendon, Ltd. (D.D.C. Apr. 12, 1995) (CA 1:95CV00700). 
The charges were authorized under the signature of Deputy Attorney 
General Eric Holder.
    \184\ Rick Wartzman, Bid to End Pact to Clarendon Comes Amid 
Disputes Over Marc Rich's Stake, Wall St. J., Feb. 28, 1992, at B2a.
    \185\ Id.
    \186\ Department of Agriculture Document Production (Letter from 
David P. Langlois, Partner, Milgrim Thomajan & Lee, to Kenneth Gubin, 
Chief Counsel, U.S. Mint (Feb. 27, 1992)) (Exhibit 24).
---------------------------------------------------------------------------
                b. Suspension of Rich's Grain Dealings
    Between July of 1986 and September of 1989, one of Marc 
Rich's companies, Richco Grain Ltd., participated in the 
Commodity Credit Corporation's Export Enhancement Program. The 
Department of Agriculture used the program to sell American 
grain to overseas customers at prices below U.S. market levels. 
The companies who won the contracts received subsidies from the 
department in the form of surplus grains. A tally by the 
Department showed that Richco received $95 million worth of 
such U.S. grain through the program.\187\ Rich made money 
through his sales of grain to China, the Soviet Union, Romania, 
and Saudi Arabia.
---------------------------------------------------------------------------
    \187\ Bruce Ingersoll, U.S. Suspends Grain Subsidies for Exporter, 
Wall St. J., Oct. 12, 1989, at sec. 3, p. 19.
---------------------------------------------------------------------------
    After prompting from Congressman Dan Glickman and an 
investigation by the Inspector General, the Department of 
Agriculture suspended Richco Grain Ltd. from participating in 
the program. A letter written on September 29, 1989, by the 
Vice-President of the Commodity Credit Corporation listed Rich 
and Green's fugitivity and indictment as reasons for the 
suspension.\188\ Notwithstanding the suspension, Congressman 
Glickman continued to press the Bush Administration on the 
matter. On March 4, 1992, Congressman Glickman wrote to 
President Bush to ask that the Department of Agriculture 
permanently exclude Rich and Green from participating in the 
program by debarring them.\189\ The Bush Administration 
responded by referring Glickman's letter to the Department of 
Agriculture, requesting that the department ``take action, if 
warranted, to see that no new contracts are awarded to Richco 
Grain.'' \190\ It appears that no new contracts were awarded to 
Marc Rich's company.
---------------------------------------------------------------------------
    \188\ Department of Agriculture Document Production (Letter from 
R.E. Anderson, Jr., Vice President of the Commodity Credit Corporation, 
Department of Agriculture, to Robert Thomajan, Partner, Milgrim 
Thomajan & Lee (Sept. 29, 1989)) (Exhibit 25).
    \189\ Department of Agriculture Document Production (Letter from 
Dan Glickman, Chairman, Subcommittee on Wheat, Soybeans, and Feed 
Grains, Committee on Agriculture, to President George H.W. Bush (Mar. 
4, 1992)) (Exhibit 26).
    \190\ Department of Agriculture Document Production (Letter from 
Allan V. Burman, Administrator of the Office of Federal Procurement 
Policy, the White House, to Charles R. Hilty, Assistant Secretary for 
Administration, Department of Agriculture (Apr. 20, 1992)) (Exhibit 
27).
---------------------------------------------------------------------------
    It is troubling that a member of President Clinton's own 
cabinet, who, as a Member of Congress was justifiably concerned 
over Marc Rich's dealings with the Agriculture Department, was 
apparently not consulted when the White House was considering 
the pardons. As Secretary of Agriculture, Glickman could have 
provided insight into the ways in which the fugitive from 
American justice continued to profit from the very government 
that had indicted him.
                c. Cuban Asset Forfeiture
    Marc Rich has also had Department of Treasury actions taken 
against his companies because of his disregard for U.S. 
regulations related to the embargo against Cuba. In late 1991, 
the Compliance Programs Division of the Office of Foreign 
Assets Control blocked more than $2.5 million relating to a 
$3.9 million deal for Cuban sugar brokered by Marc Rich + Co., 
Ltd. in the United Kingdom.\191\ This transaction had run afoul 
of the Cuban Assets Control regulations.\192\ As R. Richard 
Newcomb, Director of the Office of Foreign Assets Control 
explained to Rich attorney Robert Fink in a December 27, 1995, 
letter, these regulations prohibit transactions by persons 
subject to U.S. jurisdiction involving any property of Cuba or 
Cuban nationals.\193\ According to Newcomb, Rich's Cuban sugar 
deal was clearly contemplated by the regulations and was 
therefore illegal.\194\
---------------------------------------------------------------------------
    \191\ Department of Treasury Document Production 000022 (Memorandum 
from R. Richard Newcomb, Director of the Office of Foreign Assets 
Control, Department of Treasury, to Peter K. Nunez, Assistant Secretary 
of Enforcement of the Office of Foreign Assets Control, Department of 
Treasury) (Exhibit 28).
    \192\ Id. See 31 C.F.R. part 515.
    \193\ Department of Treasury Document Production (Letter from R. 
Richard Newcomb, Director of the Office of Foreign Assets Control, 
Department of Treasury, to Robert F. Fink, Partner, Piper and Marbury 
(Dec. 27, 1995)) (Exhibit 29).
    \194\ Id.
---------------------------------------------------------------------------
    In September of 1994, Marc Rich + Co., A.G. in Switzerland 
provoked a similar blocking of nearly $1 million in proceeds 
from an oil deal with Venezuela going through Cuba. Internal 
notes of the Compliance Programs Division indicate deep concern 
with attempts by the Venezuelan state-run oil company to have 
the funds released. As the Compliance Division wrote in its 
internal notes, the Venezuelan oil company ``also stated that 
it `believes' that Marc Rich intended to resell the oil to 
Cuba, but that this particular transfer did not relate to the 
sale of the oil to Cuba. If it did not relate to Cuba, why did 
it reference Cuba?'' \195\ Ultimately, in February of 1995, the 
Department of Treasury unblocked the funds because, as it 
stated in one document, ``Cuba does not have a direct interest 
in the blocked transaction, which involves a Venezuelan and a 
Swiss company[.]'' \196\
---------------------------------------------------------------------------
    \195\ Department of Treasury Document Production 000635 (Note from 
Compliance Programs Division, Office of Foreign Assets Control) 
(Exhibit 1).
    \196\ Department of Treasury Document Production 000636 (License 
Request by J. Kerrigan, Compliance Programs Division of the Office of 
Foreign Assets Control, Department of Treasury (Jan. 1, 1995)) (Exhibit 
30).
---------------------------------------------------------------------------
    It does not appear that the Clinton Administration took 
into consideration the fact that Marc Rich and Pincus Green 
profited from the United States while flouting its embargoes. 
Indeed, a review of Rich and Green's business relationships 
shows a complete disregard for the welfare of the United States 
and its citizens. Furthermore, Rich's clever and illegal 
business schemes meant that U.S. taxpayers' money came out of 
agencies such as the U.S. Mint and the Department of 
Agriculture and wound up in the pockets of Rich and Green while 
they evaded the U.S. legal system, and U.S. income taxation. 
This is one of the many reasons that Republicans and Democrats 
alike have been so critical of President Clinton's decision to 
grant these men a pardon.

II. ATTEMPTS TO SETTLE THE MARC RICH AND PINCUS GREEN CASE

A. Attempts to Settle in the 1980s

    While living as fugitives in Switzerland, Marc Rich and 
Pincus Green attempted to negotiate a settlement with the 
Southern District of New York. In addition to prominent lawyers 
such as Edward Bennett Williams, Rich and Green hired other 
well-known and politically connected lawyers.\197\ In the 
Spring of 1985, they hired President Richard Nixon's attorney 
Leonard Garment.\198\ Around this same time, Garment hired 
Lewis ``Scooter'' Libby to join his firm.\199\ Garment assigned 
Libby the task of assessing whether or not there were legal 
defenses to the charges to which Rich and Green's companies had 
already pled guilty.\200\ As Libby testified at the Committee's 
March 1, 2001, hearing, he worked with Robert Fink and other 
attorneys in an attempt to demonstrate that Marc Rich's 
companies ``had properly reported their tax obligations and 
energy transactions and that these criminal charges should be 
reexamined.'' \201\ Libby and the Rich legal team used their 
analysis in an effort to negotiate a settlement with the 
Southern District on the outstanding indictment.\202\
---------------------------------------------------------------------------
    \197\ Marc Rich's practice of hiring attorneys who are close to the 
parties investigating him has continued to this day. In response to 
this Committee's investigation, Rich and his attorneys have hired an 
array of prominent Republicans, including the former personal attorneys 
to Chairman Burton and the Committee's former Chief Investigator.
    \198\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 438 
(Mar. 1, 2001) (testimony of Lewis Libby, former counsel for Marc Rich, 
Dechert Price & Rhoads).
    \199\ Id. Libby is currently Chief of Staff to Vice President Dick 
Cheney.
    \200\ Id.
    \201\ Id.
    \202\ Id.
---------------------------------------------------------------------------
    It should be noted that Lewis Libby's involvement in the 
Rich matter--like that of Garment and former Reagan Justice 
Department official William Bradford Reynolds--was limited to 
settlement negotiations and never included work on the pardon 
matter. Libby, and to a lesser extent, Garment and Reynolds, 
have been mentioned by President Clinton and others as 
prominent Republicans who supported the Rich pardon. This 
representation is inaccurate, as Libby, Reynolds and Garment 
worked only on settlement negotiations, and did not work on the 
pardon. Libby's efforts included an attempt to negotiate a 
settlement with the Southern District of New York in the late 
1980s until he left to work at the Pentagon in the first Bush 
Administration in 1989.\203\ When he returned to private 
practice in 1993, Libby again attempted to achieve a settlement 
for Rich and Green.\204\ This attempt again failed by 
1995.\205\ Libby's final involvement in the Rich case was in 
1999 and early 2000, when he briefed the newly-hired Jack Quinn 
on the legal team's previous efforts to reach a settlement with 
the Southern District and helped prepare yet another request to 
the Southern District.\206\ Libby was instructed to cease all 
work on behalf of Rich and Green in the spring of 2000.\207\
---------------------------------------------------------------------------
    \203\ Id.
    \204\ Id. On this occasion he also worked with Laurence Urgenson of 
Kirkland & Ellis.
    \205\ Id.
    \206\ Id. at 438-39.
    \207\ Id. at 439. It appears that Rich's lawyers considered 
approaching Libby to help with the pardon effort, but were concerned 
that he would refuse them. On December 26, 2000, Robert Fink sent the 
following e-mail to Jack Quinn and Michael Green:

        GMarc thought it made sense to call Scooter to see if he 
      could be helpful, knowing he might not be able to be 
      helpful but that he would never do anything that hurt Marc. 
      I agreed and raised it with Mike Green. Mike is concerned 
      that Scooter would want to help but would feel he had to 
      raise the matter with the ethics committee on the 
      transition and it would get caught up there, and we would 
      effectively be bringing it to the attention of a number of 
---------------------------------------------------------------------------
      people who might not be helpful.

Piper Marbury Rudnick & Wolfe Document Production PMR&W 00398 (E-mail 
from Robert Fink, Partner, Piper Marbury Rudnick & Wolfe, to Jack Quinn 
and Michael Green, Partner, Dickstein Shapiro Morin & Oshinsky (Dec. 
26, 2000)) (Exhibit 31).
    Despite the fact that Rich and Green fled the country as a 
result of their pending indictment, the Southern District of 
New York continued to negotiate with lawyers like Fink, Libby 
and Garment to try to achieve the return of Rich and Green to 
the United States. In their appeals to President Clinton for a 
pardon, Rich's lawyers often claimed that the SDNY refused to 
negotiate with Rich. Nothing could be further from the truth. 
Despite the fact that Rich and Green had fled the country, SDNY 
prosecutors continued to negotiate with Rich, even offering to 
reduce the charges against Rich and Green in return for their 
surrender. For example, in the early 1990s, Otto Obermaier, 
U.S. Attorney for the Southern District of New York, traveled 
to Switzerland to meet with Rich and Green. This was a highly 
unusual step for a United States Attorney to make. In fact, 
Eric Holder testified at a Committee hearing that he could 
think of no other instance in which a U.S. Attorney had 
traveled to a foreign country to negotiate with an indicted 
fugitive.\208\ Despite this accommodation, Rich and Green 
failed to reach an agreement with the Southern District to 
return to the United States to stand trial.
---------------------------------------------------------------------------
    \208\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 268-69 
(Feb. 8, 2001) (testimony of Eric Holder, former Deputy Attorney 
General, Department of Justice).
---------------------------------------------------------------------------
    The SDNY also offered a number of other accommodations if 
Rich would return to the U.S. to face the charges. For example, 
prosecutors offered to agree in advance on bail, so that Rich 
would not have to be incarcerated pending trial.\209\ They also 
offered to have a full meeting with Rich's attorneys, and 
conduct a complete review of the charges against Rich.\210\ 
Most importantly, they offered to drop the RICO charges against 
Rich and Green.\211\ Marc Rich's own lawyer, Robert Fink, 
confirmed that prosecutors offered to drop the RICO charge as a 
result of negotiations.\212\ Fink wrote about these 
negotiations in an e-mail he sent to Avner Azulay on February 
10, 2000, stating ``I was told at one point that they would 
drop the RICO charge if we wanted if Marc came in.'' \213\ Fink 
confirmed the substance of this e-mail at the Committee's 
hearing:
---------------------------------------------------------------------------
    \209\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00697 
(E-mail from Robert Fink to Avner Azulay, Director, Rich Foundation 
(Feb. 10, 2000)) (Exhibit 32).
    \210\ Id.
    \211\ Id.
    \212\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 469 
(Mar. 1, 2001) (testimony of Robert Fink).
    \213\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00697 
(E-mail from Robert Fink to Avner Azulay, Director, Rich Foundation 
(Feb. 10, 2000)) (Exhibit 32).

        Mr. LaTourette. Looking at [the February 10, 2000, e-
        mail], or your recollection from the representation of 
        Marc Rich, is it accurate that at one point you were 
        told that the prosecuting authorities would drop the 
---------------------------------------------------------------------------
        RICO charge if Marc Rich returned to this country?

        Mr. Fink. That was something that was discussed with me 
        in at least one meeting I had with the 
        prosecutors.\214\
---------------------------------------------------------------------------
    \214\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 469 
(Mar. 1, 2001) (testimony of Robert Fink).

Given the fact that the SDNY had offered to drop the RICO 
charges if Rich and Green returned to the U.S., it is 
interesting that Quinn continued to cite the RICO charges as 
one reason the pardon was necessary. Throughout the pardon 
petition, his contacts with White House officials, and even his 
attempts to justify the pardon after the fact, Quinn cited the 
RICO charges as a reason Rich and Green fled the country rather 
than face trial. However, the SDNY's offer makes it clear that 
Quinn's RICO argument, like most of his other arguments, was 
false and misleading.
    Finally, in addition to the offer to drop the RICO charges, 
prosecutors also offered another accommodation to Rich and 
Green. The SDNY indicated it would agree to bail so that Rich 
and Green would not have to be incarcerated while they stood 
trial. The only condition of this offer was that they give up 
their passports.\215\ Even after the offers to drop RICO and 
allow bail was presented to them, the two men still chose to 
remain fugitives and refused to face the American judicial 
system.
---------------------------------------------------------------------------
    \215\ Id. at 470.
---------------------------------------------------------------------------

B. Marc Rich's Humanitarian Activities in the 1980s and 1990s

    After he fled the United States, Marc Rich began to 
contribute large sums of money to various humanitarian 
activities, mainly in Israel and to Jewish communities in 
Europe and the United States. Marc Rich's contributions, beyond 
achieving their humanitarian purposes, also served a useful 
purpose of making Rich a well-known and respected figure in 
Israeli and Jewish political circles. These contacts would 
prove useful both in Rich's unsuccessful attempt to settle his 
indictment and in his successful campaign to win a pardon.
    Rich also used his wealth to cultivate political contacts. 
In 1985, after an Egyptian policeman shot and killed a number 
of Israeli tourists at Ras Burka, Rich contributed $400,000 to 
a compensation fund which was established for the victims.\216\ 
More recently, in 1995, Rich began to make offers of providing 
substantial sums of money to help the Israeli-Palestinian peace 
process.\217\ According to internal Marc Rich legal documents, 
Rich offered to help fund the economic development of 
Palestinian territories as part of the peace process.\218\ As 
part of his offer, Rich apparently told Israeli officials that 
his ability to help was limited by his outstanding U.S. 
indictment. Receptive Israeli officials then went to U.S. 
officials to see what could be done to settle Rich's case. 
According to an account of the negotiations prepared by Rich's 
lawyers, the Israeli government approached the Justice 
Department to discuss the Rich case.\219\ Mark Richard, a 
Deputy Assistant Attorney General in the Criminal Division, 
informed the Israelis that while the Justice Department could 
not act directly on the Israeli request, the Justice Department 
would ``give serious consideration to a statement by the State 
Department or the White House that the United States had an 
interest in allowing Israel to obtain the active participation 
of Rich in a Middle East Initiative.'' \220\
---------------------------------------------------------------------------
    \216\ Petition for Pardon for Marc Rich and Pincus Green 8 (Dec. 
11, 2000) (Appendix III); Leonard Garment, Crazy Rhythm 375 (1997).
    \217\ Id. at 9; Jack Quinn Document Production (Background 
Memorandum to the Marc Rich Case, Dec. 1997) at 5 (Exhibit 33).
    \218\ Id.
    \219\ Id.
    \220\ Id.
---------------------------------------------------------------------------
    Following Mark Richard's suggestion, the Israeli Foreign 
Ministry took the Rich case to the State Department. In July 
1995, Uri Savir, the Director General of the Foreign Ministry, 
presented Ambassador Dennis Ross with a briefing paper on the 
Rich case.\221\ Several months later, Ross informed Savir that 
the Rich case was a ``hot potato'' and should not be 
pursued.\222\ Despite Ross' rebuff, then-Foreign Minister 
Shimon Peres instructed the Israeli Ambassador to the U.S., 
Itamar Rabinovich, to press the Rich matter with the State 
Department.\223\ Peres himself also raised the Rich case with 
Ross and the U.S. Ambassador to Israel, Martin Indyk.\224\ 
While Ross did not respond to Peres, Indyk suggested that the 
Rich case could be discussed at greater length by Israeli 
officials and the State Department.\225\ Ambassador Rabinovich 
and his staff met with a State Department official in October 
1995 and discussed the Rich case.\226\ In follow-up meetings 
with the State Department, Israeli officials learned that they 
were not likely to win support from the State Department for 
settling the Rich case.\227\ According to the Israeli 
officials, State Department officials were concerned about 
allegations that the Administration was interfering with law 
enforcement for political purposes, and the potential 
embarrassment that would follow if the public learned of a deal 
with Marc Rich.\228\
---------------------------------------------------------------------------
    \221\ Id. at 5-6.
    \222\ Id. at 6.
    \223\ Id. Itamar Rabinovich, now President of Tel Aviv University, 
wrote a letter of support for the Rich pardon to President Clinton.
    \224\ Id.
    \225\ Id.
    \226\ Id.
    \227\ Id.
    \228\ Id.
---------------------------------------------------------------------------
    According to the internal account prepared by the Marc Rich 
lawyers, Shimon Peres continued his efforts on behalf of Marc 
Rich even after Yitzhak Rabin was assassinated and Peres became 
Prime Minister.\229\ However, by 1996, as Israeli elections 
approached, Peres' priorities shifted, and Israeli contacts 
with the U.S. government on the Rich matter subsided until the 
pardon effort.
---------------------------------------------------------------------------
    \229\ Id. at 7.
---------------------------------------------------------------------------
    Other than the initial response from Mark Richard, it 
appears that Justice Department and State Department officials 
were unified in their resistance to Israeli efforts to have the 
Rich case settled. The resistance of these government officials 
should be contrasted with the receptivity displayed by 
President Clinton and Deputy Attorney General Holder for the 
much more drastic step of pardoning Rich. Also noteworthy is 
the fact that this brief effort in 1995 appears to be the only 
time that Marc Rich's name came up in the context of the Middle 
East peace talks. To the extent that Rich's name came up, it 
appears to have been a minor matter that never had any impact 
on the Middle East peace talks. Dennis Ross, the Clinton 
Administration's Middle East envoy, has stated that Marc Rich 
``was not a factor in the Middle East talks.'' \230\ The fact 
that Marc Rich was never a factor in the peace talks, either in 
1995 or in 2000, suggests that President Clinton's key 
justification for the pardon--that it was important to Israel--
is an after-the-fact excuse that the President has put forward 
to cover up other motivations for the pardon.
---------------------------------------------------------------------------
    \230\ James Risen and Alison Leigh Cowan, U.S. Diplomats Turned 
Aside Israeli Push on Rich's Behalf, N.Y. Times, Feb. 17, 2001, at A1.
---------------------------------------------------------------------------

C. Rich Hires Jack Quinn

    After several years of failed negotiations with the 
Southern District of New York, Marc Rich and his team tried 
another approach to resolve his case. Instead of dealing only 
with the federal prosecutors from New York, Rich began a 
process of going directly to the Justice Department in 
Washington. Beginning sometime in 1997, Michael Steinhardt, a 
prominent hedge-fund investor and friend of Rich, recommended 
that Rich hire public relations consultant Gershon Kekst to 
help with his case.\231\ Although Kekst was at first reluctant 
to get involved, he eventually began working with Rich to help 
resolve his legal troubles in the United States.\232\ It was 
through Kekst's efforts that Jack Quinn was hired to work on 
the Marc Rich case.
---------------------------------------------------------------------------
    \231\ Telephone Interview with Michael Steinhardt (Mar. 12, 2001).
    \232\ As discussed in Section IV(A)(9) of the report, Kekst tried 
to disavow his role in helping Marc Rich with negotiations and the 
pardon effort. It appears, however, that Kekst was deeply involved in 
the pardon effort.
---------------------------------------------------------------------------
    Kekst explained that in late 1998, he attended a dinner 
celebrating the merger of Daimler Benz and Chrysler.\233\ At 
the dinner, he was seated next to an individual he did not 
know, who explained that he worked at ``Main Justice.'' \234\ 
It turned out that this individual was Deputy Attorney General 
Eric Holder.\235\ Kekst asked this stranger to whom U.S. 
Attorneys are accountable.\236\ Holder explained that they 
answer to Main Justice.\237\ Kekst had Marc Rich in mind, but 
did not mention Rich's name at the time.\238\ Kekst then asked 
Holder what someone should do if ``they were improperly 
indicted by an overzealous prosecutor.'' \239\ Holder told 
Kekst that a person in that situation should try to work it out 
and resolve it.\240\ Holder further stated that, ``lawyers know 
there is a path back to DOJ, to me.'' \241\ Holder told Kekst 
that such a person should ``hire a lawyer who knows the 
process, he comes to me, and we work it out.'' \242\ Kekst 
asked who such a lawyer would be, and Holder pointed to an 
individual sitting at a nearby table and said, ``there's Jack 
Quinn. He's a perfect example.'' \243\ According to Kekst, 
Quinn was in attendance, but he did not discuss Marc Rich or 
Eric Holder with Quinn at that dinner.\244\
---------------------------------------------------------------------------
    \233\ Interview with Gershon Kekst, President, Kekst and Co. (Mar. 
15, 2001). To the best of Kekst's recollection, the Daimler Chrysler 
dinner took place in November of 1998.
    \234\ Id.
    \235\ Id.
    \236\ Id.
    \237\ Id.
    \238\ Id.
    \239\ Id.
    \240\ Id.
    \241\ Id.
    \242\ Id.
    \243\ Id.
    \244\ Id.
---------------------------------------------------------------------------
    Shortly after the Daimler Chrysler dinner, Kekst began to 
explore this new strategy. First, he worked to gather names of 
lawyers in addition to Jack Quinn who might be able to help 
Marc Rich.\245\ By the time he met with Michael Steinhardt and 
Robert Fink to discuss the Rich case several weeks later, Kekst 
recommended that Rich hire a senior Washington lawyer who could 
intercede with the Justice Department in Washington.\246\ Kekst 
then provided the names of three such lawyers who might be able 
to help: Warren Christopher, Judah Best, and Jack Quinn.\247\ 
Kekst called each of the three to introduce them to Fink.\248\ 
According to Kekst, Warren Christopher said that taking the job 
would be inappropriate since he had just come out of 
government.\249\ Fink interviewed Best but did not like him 
enough to hire him for the job. Rich, Fink, and Kekst 
eventually settled on Jack Quinn. As Quinn explained to The New 
York Times, he traveled to Switzerland, studied the issues, and 
met with Marc Rich ``not for hours, but for days.'' \250\
---------------------------------------------------------------------------
    \245\ Id.
    \246\ Id.
    \247\ Id.
    \248\ Id. At the Committee's March 1, 2001, hearing, Fink testified 
that he asked Kekst to ``recommend someone who [he] called the white-
haired man.'' Fink testified that this expression referred to ``someone 
who understood the entire political process.'' ``The Controversial 
Pardon of International Fugitive Marc Rich,'' Hearings Before the Comm. 
on Govt. Reform, 107th Cong. 471 (Mar. 1, 2001) (testimony of Robert 
Fink).
    \249\ Interview with Gershon Kekst, President, Kekst and Co. (Mar. 
15, 2001).
    \250\ Alison Leigh Cowan and Raymond Bonner, Lawyer Tells of His 
Pursuit of Pardon for His Client, and Conversation With Clinton, N.Y. 
Times, Jan. 25, 2001, at A21.
---------------------------------------------------------------------------
    Jack Quinn began working for Marc Rich in the spring of 
1999.\251\ According to Quinn, he was hired at first, ``not to 
go to the White House, but to work with Main Justice and the 
Southern District of New York.'' \252\ It is noteworthy that 
Eric Holder's recommendation to Gershon Kekst was the impetus 
for Marc Rich's hiring of Jack Quinn. Quinn had a warm 
relationship with Holder--Holder even solicited Quinn for 
support to have Holder nominated as Attorney General. This warm 
relationship appears to have had a significant role in Holder's 
support for the Rich pardon.
---------------------------------------------------------------------------
    \251\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 216 
(Feb. 8, 2001) (testimony of Jack Quinn).
    \252\ Id.
---------------------------------------------------------------------------

D. Quinn's Fee Arrangements

    Jack Quinn was a partner with the law firm of Arnold & 
Porter when he began working for Marc Rich. Quinn also worked 
on the Rich matter with Kathleen Behan, another Arnold & Porter 
partner. As Behan explained to Committee staff, although they 
were not officially retained by Marc Rich until July of 1999, 
from February until July, Quinn and Behan were ``engaged in a 
series of familiarization and preparatory efforts'' to learn 
about the case ``in preparation for possible retention on the 
matter.'' \253\ Quinn and Behan were officially retained after 
they met with Marc Rich in Zug, Switzerland, in May of 1999 to 
discuss the representation.\254\ As the engagement letter 
explains, Quinn and Behan were hired for a minimum rate of 
$55,000 per month for six months, totaling $330,000, with an 
option to reconsider if their billable hours were to 
``substantially exceed'' $55,000 per month.\255\
---------------------------------------------------------------------------
    \253\ Interview with Kathleen Behan, Partner, Arnold & Porter (Feb. 
27, 2001).
    \254\ Id.
    \255\ Arnold & Porter Document Production A0507-10 (Letter from 
Kathleen Behan, Partner, Arnold & Porter, to Marc Rich (July 21, 1999)) 
(Exhibit 34).
---------------------------------------------------------------------------
            1. Was Quinn Expecting Payment for His Work on the Pardon?
    In November 1999, just several months after he was hired by 
Rich, Quinn left Arnold & Porter to form the lobbying firm of 
Quinn and Gillespie.\256\ While Quinn brought Rich as a client 
to the new firm, he did not sign a new retainer with Rich. 
Quinn continued to work for Rich at Quinn and Gillespie, both 
on negotiations with the Justice Department, and on lobbying 
for the pardon. However, Quinn has taken the incredible 
position that he did not expect to be paid for any of his work 
on the Rich case after he left Arnold & Porter. In the first 
days of the uproar regarding the pardon, Quinn told The New 
York Times, ``I have no understanding with Marc Rich about 
future payments. If Marc Rich sent me a box of Godiva 
chocolates tomorrow, it would be more than he is obligated to 
do.'' \257\ He expanded on this position at a Committee 
hearing:
---------------------------------------------------------------------------
    \256\ According to one magazine article about his departure from 
Arnold & Porter, Quinn brought $4.5 million in business to Arnold & 
Porter. The article continued:
---------------------------------------------------------------------------
        GBut that's small potatoes to what he can make on his 
      own, because now Quinn is not constrained by the hourly 
      rate structure and will take equity stakes in start-up 
      companies in exchange for his services. That will give him 
      the possibility of making millions on one client when it 
      goes public. Arnold & Porter, like almost all corporate 
      firms, does not allow equity participation with clients.
Kim Eisler, Old Political Opponents Join Forces for Lucrative Lobbying, 
Washingtonian, Feb. 2000, at 12.
---------------------------------------------------------------------------
    \257\ Raymond Bonner and Alison Leigh Cowan, Notes Show Justice 
Official Knew of Pardon Application, N.Y. Times, Feb. 2, 2001, at A14.

        Mr. Burton. You left [Arnold & Porter], and I guess the 
        contract stayed with them; is that right? What 
        happened? They went on just to a fee-for-service with 
---------------------------------------------------------------------------
        that law firm?

        Mr. Quinn. Yes, sir.

        Mr. Burton. And you have said that you didn't receive 
        any fees from Mr. Rich. You said something about a box 
        of chocolates. It was all going to be voluntary if you 
        got that. That just seems very unusual to me. Don't 
        most attorneys have some kind of a contractual 
        agreement when they leave a law firm with a new client?

        Mr. Quinn. Yeah. Let me try to explain this to you. The 
        fees you just reported were received by Arnold and 
        Porter. And, of course, as a partner, and because I had 
        a contractual relationship with a firm, I benefited to 
        some extent from those fees. To another extent, the 
        fees went to other partners of the firm.

        After leaving Arnold and Porter, I did consider and 
        discuss with Mr. Fink whether we should have a new 
        arrangement. I came to the conclusion that, 
        particularly because of the fact that we were 
        unsuccessful in achieving a resolution of this at the 
        Southern District, and because I didn't think, frankly, 
        there would be that much more additional time in it, 
        and because I believed that the earlier payments had 
        been fair and reasonable, that I would see this through 
        to the end simply on the basis of the fees we had been 
        paid earlier.

        Mr. Burton. So you received nothing further from Mr. 
        Rich?

        Mr. Quinn. I have not received any further fees from 
        him on this pardon matter.

        Mr. Burton. Have you received any fees from him for 
        anything?

        Mr. Quinn. No, sir.

        Mr. Burton. You've received no fees from Marc Rich or 
        his--how about any of his companies or friends or 
        associates?

        Mr. Quinn. No, sir.

        Mr. Burton. All that was received was from the--to the 
        law firm that you previously worked with?

        Mr. Quinn. Right.

                                *  *  *


        Mr. Burton. Do you have any kind of understanding where 
        he is going to give you a lump sum of money or funds 
        down the road for the services you've rendered?

        Mr. Quinn. No sir[.] \258\
---------------------------------------------------------------------------
    \258\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 242 
(Feb. 8, 2001) (testimony of Jack Quinn).

    It is impossible to believe that Jack Quinn did his work on 
the Rich pardon out of the goodness of his heart, on a pro bono 
basis. Quinn apparently spent hundreds of hours \259\ on the 
Rich matter, calling and e-mailing his colleagues on the Rich 
legal team in the middle of the night, on vacation, on 
Christmas Day, and New Year's Eve.\260\ While Quinn's 
dedication to his client was admirable, it suggests that Quinn 
anticipated some satisfaction beyond seeing Marc Rich and 
Pincus Green pardoned.
---------------------------------------------------------------------------
    \259\ In media accounts Quinn claimed that he spent 60-100 hours on 
the Rich pardon. These claims simply are not credible. Kitty Behan, who 
was considerably less involved in the Rich pardon than Quinn spent 126 
hours on the Rich pardon. Arnold & Porter Document Production A0513-15, 
A1128 (Arnold & Porter billing records for Marc Rich (Jan. 16, 2001 and 
Feb. 23, 2001)) (Exhibit 35). It is likely that Quinn was 
underestimating his hours to the media to try to support his claims 
that he was not expecting to be paid.
    \260\ See Arnold & Porter Document Production A0844 (E-mail from 
Jack Quinn to Avner Azulay, Director, Rich Foundation et al. (Dec. 25, 
2000)); Arnold & Porter Document Production A0850 (E-mail from Jack 
Quinn to Avner Azulay, Director, Rich Foundation et al. (Dec. 27, 
2000)); Arnold & Porter Document Production A0861 (E-mail from Robert 
Fink to Avner Azulay, Director, Rich Foundation et al. (Jan. 2, 2001)); 
Piper Marbury Rudnick & Wolfe Document Production PMR&W 00091 (E-mail 
from Robert Fink to Avner Azulay, Director, Rich Foundation, and Marc 
Rich (Dec. 28, 2000)); Piper Marbury Rudnick & Wolfe Document 
Production PMR&W 00097-98 (E-mail from Jack Quinn to Robert Fink (Dec. 
31, 2000)) (Exhibit 36).
---------------------------------------------------------------------------
    In addition to the common sense rejection of Quinn 
proceeding on a pro bono basis, e-mails between Jack Quinn, 
Robert Fink, and Marc Rich indicate that Rich was specifically 
contemplating entering into a large-dollar retainer agreement 
with Quinn after Quinn left Arnold & Porter. These documents 
were withheld from the Committee for over a year on the basis 
of a claim of attorney-client privilege which was rejected by 
federal Judge Denny Chin. Once provided to the Committee, the 
documents seriously undermined Quinn's claims that he never 
expected any payment from Rich. On February 3, 2000, the day 
after the Southern District of New York rejected Quinn's 
request for a meeting to discuss the Rich case, Quinn asked 
Fink about his status with Marc Rich, asking ``not that I'm 
concerned, but did marc decide to renew the retainer? I've not 
heard anything.'' \261\ Two weeks later, Fink addressed Quinn's 
status in an e-mail to Marc Rich, suggesting that Quinn could 
still be useful, despite his failure to date:
---------------------------------------------------------------------------
    \261\ Jack Quinn Document Production JQ 02847 (E-mail from Jack 
Quinn to Robert Fink (Feb. 3, 2000)) (Exhibit 37).

        Separately, I have been thinking about your reaction to 
        Jack. When we meet [sic], he felt (and made it clear 
        that he believed this, but was not sure) that he could 
        convince Eric that it made sense to listen to the 
        professors and that he could convince Eric to encourage 
        Mary Jo to do the same. In this he was correct. 
        Moreover, in the preparation process, it became clear 
        that Jack was not just a pretty face but had thoughtful 
        ideas and questions and was not simply relying on his 
        past contacts to make this happen. So, I would not give 
        up on him, at least not yet, as he is still a 
        knowledgeable guy who has a clear understanding of 
        relationships and what may be doable. While we may get 
        more than that, we should not have enlarged 
        expectations.\262\
---------------------------------------------------------------------------
    \262\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 
00720-21 (E-mail from Robert Fink to Marc Rich (Feb. 17, 2000)) 
(Exhibit 38).

On February 29, 2000, Fink sent another message to Rich 
suggesting that he enter into a retainer agreement with Quinn 
while their negotiations with the Justice Department were still 
---------------------------------------------------------------------------
pending:

        All in all, while he has been very busy and sometime 
        hard to get to, he has not separated himself from the 
        matter and has fully participated. He has not pushed me 
        for the retainer, though, and realizes that he does not 
        have an agreement with you. I think it makes sense to 
        compensate him for what he has done and may continue to 
        do. Just give it some more thought and we can come back 
        to it soon. We can wait, if you want, to see what Eric 
        says, although it may pay to respond now, before Eric 
        response [sic] to the last message from Jack, so it 
        does not look like you were only willing to pay because 
        of a positive response, as that was not the agreement. 
        Even if we stop everything we are doing, and decide not 
        to investigate the pardon, etc., at this time, we 
        should fold this down in a friendly way.\263\
---------------------------------------------------------------------------
    \263\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00722 
(E-mail from Robert Fink to Marc Rich (Feb. 29, 2000)) (Exhibit 39).

    After the effort to settle the criminal case with the 
Justice Department failed, Fink continued to recommend that 
Rich enter into a retainer agreement with Quinn, who was 
continuing to raise the issue. On June 6, 2000, Fink sent the 
---------------------------------------------------------------------------
following e-mail to Rich:

        Jack raised the question of his status. I told him that 
        I felt that you would feel that he had been compensated 
        for the past, even though the retainer had run out 
        before he stopped work, but that you would not want or 
        expect him to work without compensation going forward--
        indeed, you appreciated that it was important to 
        compensate people who asked you to perform for you; 
        although I thought you would not want to get involved 
        in another one of those six month retainers.

        Jack said he did not want to make a proposal that you 
        might find objectionable, but felt some clear 
        arrangement for the future was appropriate. I told him 
        I hoped to see you soon, and that I would raise it with 
        you when I see you and come back with a suggestion. He 
        was happy with that and we agreed to catch up with each 
        other on this issue in the beginning of July.\264\
---------------------------------------------------------------------------
    \264\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00731 
(E-mail from Robert Fink to Marc Rich (June 6, 2000)) (Exhibit 40).

At the beginning of July 2000, Fink e-mailed the figures for a 
---------------------------------------------------------------------------
proposed retainer agreement to Marc Rich:

        Here is my proposal on Jack Quinn, consistent with your 
        advice to me.

        Jack originally proposed a $50,000 per month retainer 
        and additional hourly charges for Kitty Behan. We 
        settled at $55,000 per month, including Kitty, which 
        was a better deal because at her hourly rate her 
        billings would have averaged over $10,000 per month. 
        Moreover, we continued to consult with Jack (and Kitty) 
        after the retainer period had ended so that the average 
        blended rate for Jack was well below $45,000. (OK, 
        enough with making you feel better.)

        At the moment the issue raised by you and Michael is 
        how to keep Jack on a ``retainer'' so that he is 
        available for questions that might arise and, more 
        importantly, available in the Fall, if we want him to 
        be. Since the Fall is not far away, and you will know 
        whether you want him to gear up again within four 
        months or so, I suggest that we offer Jack $10,000 per 
        month as a retainer to keep his eyes, ears and brain 
        open to events and thoughts that may be helpful, with 
        the understanding that if a decision is made to proceed 
        that we will renegotiate the monthly retainer to 
        reflect the changed circumstances.

        This arrangement could start mid-July or August 1st. He 
        has not pushed me for this and, indeed, we are the ones 
        who raised the idea of keeping him on a retainer. 
        Still, if we do go back to Jack and offer a package, we 
        should not schedule it to begin weeks after the 
        proposal. So, if I were to call him next week, I would 
        want to suggest a July 15th start date.\265\
---------------------------------------------------------------------------
    \265\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00732 
(E-mail from Robert Fink to Marc Rich (July 7, 2000)) (Exhibit 41).

Despite the clear and detailed indications that Rich and Quinn 
were negotiating a lucrative retainer agreement, Quinn 
testified that he never received any money from Marc Rich 
between the time that he left Arnold & Porter and the time that 
the pardon was granted. The Committee requested interviews with 
Jack Quinn and Robert Fink so that they could provide further 
explanation regarding these e-mails. Both refused to 
participate in an interview.
            2. Has Quinn Received Payments from Marc Rich Since the 
                    Pardon Was Granted?
    Because he spent so much time and effort on the Marc Rich 
pardon effort, and was successful, many believe that Quinn may 
have expected some large payment from Rich after the pardon was 
granted. Quinn has always denied these allegations. However, 
among the documents withheld by Quinn, and which were forced 
out by the decision of Judge Denny Chin in December 2001, were 
documents which undermined Quinn's denials. Shortly after the 
pardon was granted, Quinn was asked by a reporter if he 
received a fee for his work on the Rich matter. Rather than 
just saying ``no,'' it appears that Quinn did not know what to 
say. On January 23, Quinn told Gershon Kekst that ``Debra [sic] 
Orin wants to know if I received a fee. My instinct is to 
either not respond or say that I have never, in 25 yrs, thought 
it propoer [sic] to discuss a client fee arrangement or even if 
there was one. What say you?'' \266\ Kekst suggested a response 
that ``[t]he privacy of my personal and professional 
relationships is inviolate and so I would not, as a lifelong 
practice, discuss such a question. Suffice to say that in this 
case my motivation was quite simple: an injustice needed to be 
corrected and I determined to do what I could to help 
accomplish that.'' \267\ Quinn then fueled further speculation 
about his fee arrangement when he told the press that he was 
handling the Rich pardon as a ``personal matter,'' indicating 
he would not share the profits with his partners at Quinn & 
Gillespie.\268\
---------------------------------------------------------------------------
    \266\ Jack Quinn Document Production JQ 02973 (E-mail from Jack 
Quinn to Gershon Kekst, President, Kekst and Co. (Jan. 23, 2001)) 
(Exhibit 42).
    \267\ Id.
    \268\ Alison Leigh Cowan and Raymond Bonner, Lawyer Tells of His 
Pursuit of Pardon for His Client, and Conversation With Clinton, N.Y. 
Times, Jan. 25, 2001, at A21.
---------------------------------------------------------------------------
    E-mails between Marc Rich and Jack Quinn after January 20, 
2001, suggest that Rich was seeking some way to show his thanks 
to Quinn, perhaps alluding to a payment to Quinn. On January 
23, 2001, Rich told Quinn that ``As time goes by it's sinking 
in more and more and I once again want to thank you for all 
you've done. I still want to thank you personally and properly 
on a separate occasion when we meet.'' \269\ After Quinn's 
appearance before the Committee, and on a number of television 
programs, Rich e-mailed Quinn to congratulate him.\270\ Quinn 
responded with his own thanks, and an assurance that he would 
continue to fight to point out the flaws in Rich's 
indictment.\271\
---------------------------------------------------------------------------
    \269\ Jack Quinn Document Production JQ 02924 (E-mail from Marc 
Rich to Jack Quinn (Jan. 23, 2001)) (Exhibit 43).
    \270\ Jack Quinn Document Production JQ 02916 (E-mail from Marc 
Rich to Jack Quinn (Feb. 9, 2001)) (Exhibit 44).
    \271\ Jack Quinn Document Production JQ 02930 (E-mail from Jack 
Quinn to Marc Rich (Feb. 9, 2001)) (Exhibit 45).
---------------------------------------------------------------------------
    The most conclusive piece of evidence that Quinn fully 
intended to be paid by Marc Rich for his work on the pardon 
came from Rich lawyer Robert Fink at the Committee's March 1 
hearing. Fink confirmed that Rich fully intended to pay Quinn 
for his work. Fink's testimony also strongly suggests that 
Quinn was lying when he stated that he had no expectation of 
being paid for his work on the pardon:

        Counsel. When Mr. Quinn began pursuing the pardon, the 
        prospect of a pardon, did you anticipate compensating 
        him for that work?

        Mr. Fink. I anticipated that he would be compensated 
        for that work by Mr. Rich.

        Counsel. And if you could, tell us what you were 
        thinking.

        Mr. Fink. Actually, I--I don't know that I was thinking 
        anything other than he was entitled to some fair fee, 
        the exact parameters of which I did not have in mind. I 
        believe I told Mr. Quinn when we started to discuss the 
        pardon that we would find a fair fee arrangement for 
        him consistent with whatever his fee arrangements were. 
        I did not know how he was handling his fee 
        arrangements.

        Counsel. Did you discuss with Mr. Rich compensating Mr. 
        Quinn?

        Mr. Fink. Could you excuse me just one moment?

        Counsel. Certainly.

        [Mr. Fink confers with counsel.]

        Mr. Fink. The answer is yes, I did. I communicated 
        thoughts I had to Mr. Rich, with which he did not 
        disagree.

        Counsel. And what did you communicate to him?

        Mr. Fink. I actually communicated to him what I told to 
        Mr. Quinn.

        Counsel. And what was that?

        Mr. Fink. That we would come to a fair fee arrangement 
        that was consistent with his normal fee arrangements.

        Counsel. So you had communicated to Mr. Quinn that you 
        would come to an arrangement with him to compensate 
        him?

        Mr. Fink. Yes.

        Counsel. And when was that?

        Mr. Fink. The precise date I do not know, but it was 
        most likely early November 2000.

        Counsel. And when did you stop thinking that was going 
        to be the case?

        Mr. Fink. I stopped thinking that was going to be the 
        case during the first hearings of this committee.

        Counsel. When I was asking Mr. Quinn about his 
        compensation?

        Mr. Fink. I believe you were the questioner.

        Counsel. I'm not quite sure where to go after that. But 
        you had not had a conversation with Mr. Quinn during 
        which you had discussed the prospect of him not being 
        compensated up until at least the time of our last 
        hearing; is that correct?

        Mr. Fink. It was always my contemplation, I mean, not 
        that I reflected on this frequently, but if you had 
        stopped me at any point in time and said would you 
        expect that Mr. Quinn would be compensated for this 
        work, I would have thought that he would be.\272\
---------------------------------------------------------------------------
    \272\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 505-06 
(Mar. 1, 2001) (testimony of Robert Fink).

Fink's testimony, in addition to the circumstantial evidence, 
establishes that Quinn expected to receive payment for his work 
on the Rich pardon. It is likely that Quinn attempted to 
mislead the public and the Committee on this point to try to 
improve the public perception of his actions in this case. That 
is, if Quinn could say he did all of his work on the Rich 
pardon out of his belief in the merits, rather than his belief 
in a large payday, it would show the strength of the Rich case.
    Knowing now that Quinn did do his work on the Rich pardon 
with an expectation of payment, the question is--how large of a 
payment would Quinn receive? Fink loosely characterized it as 
``consistent with his normal fee arrangements.'' However, given 
the enormous sums at Rich's disposal, and the vast amounts Rich 
had spent, unsuccessfully, to resolve his case, it is not 
unreasonable that Rich would pay Quinn a large sum of money. 
However, at the Committee's February 8, 2001, hearing, Quinn 
pledged not to accept any future payment on the Rich case:

        Counsel. Mr. Quinn, the Chair asked you some questions 
        about compensation. Apart from your attorney's fees, 
        will you accept any money from Mr. Rich in the future?

        Mr. Quinn. Well, look, I don't think it would be fair 
        to ask me to commit never to accept moneys from him. As 
        I've said to you, if I do work that justifies my 
        billing him for it, I will do so. I expect to be 
        reimbursed for the expenses I'm put to in connection 
        with this. Those are the only moneys I anticipate 
        receiving from him.

        Counsel. But as far as your work done in pursuit of 
        obtaining a pardon for him, you do not anticipate him--
        you're not going to ask him to pay you any money?

        Mr. Quinn. That's correct.

        Counsel. You're not going to accept any money if he did 
        offer it to you; is that correct?

        Mr. Quinn. I only anticipate receiving from him moneys 
        in connection with work I may do.

        Counsel. My question was, will you accept any money if 
        he offers it to you for the work you did in obtaining 
        the pardon?

        Mr. Quinn. I have no idea what he might offer. It's a 
        hypothetical question. I don't think I should be 
        required to say--

        Counsel. It's not a hypothetical question. It's a very 
        clear question. If Mr. Rich offers to pay you money in 
        the future for work you did in pursuit of obtaining his 
        pardon, will you accept it or will you not accept it?

        Mr. Quinn. I will not bill him, and I will not accept 
        any further compensation for work done on the 
        pardon.\273\
---------------------------------------------------------------------------
    \273\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 266 
(Feb. 8, 2001) (testimony of Jack Quinn).

    However, in February 2002, as a result of Judge Chin's 
decision in the Southern District of New York, the Committee 
received a number of documents which had been earlier withheld 
from the Committee on the basis of attorney-client privilege. 
One of the e-mails provided to the Committee indicated that on 
March 5, 2001, after the Committee's second and final hearing 
on the Marc Rich pardon, Quinn asked Rich to enter into a new 
retainer agreement to pay Quinn. Quinn's e-mail reads as 
---------------------------------------------------------------------------
follows:

        Greetings. Quite a month we have had! If you are 
        agreeable, and I hope you are, I need to fax to you in 
        the next few days a new retainer agreement. I cannot, 
        under the D.C. Bar rules continue to work without a 
        written agreement, and I have been crafting one which I 
        will forward shortly. I hope that, in recent days, the 
        public has begun to see your pardon in a different 
        light. I particularly thought that our hearing last 
        Thursday brought to the fore aspects not previously 
        appreciated. About all this I hope we shall speak soon. 
        Best to you.\274\
---------------------------------------------------------------------------
    \274\ Jack Quinn Document Production JQ 02916 (E-mail from Jack 
Quinn to Marc Rich (Mar. 5, 2001)) (Exhibit 44).

    Rich responded to Quinn by telling him: ``[w]ith reference 
to your email of March 5, please go ahead and send me the new 
retainer agreement.'' \275\ Neither Quinn nor Robert Fink 
provided the Committee with a copy of any retainer agreement, 
or any further e-mails regarding payments from Rich to Quinn 
after March 5, 2001. However, the March 5 e-mail raises the 
possibility that Quinn is receiving payment from Rich, despite 
his express promise to the contrary at the Committee's February 
8 hearing. The Committee requested an interview with both Quinn 
and Fink to provide further explanation for these e-mail 
messages, but both declined to participate. While Quinn has 
refused to provide an explanation to the Committee, his 
spokesman has told the press that Quinn has signed a new 
retainer with Rich to ``cover new legal matters.'' \276\ The 
Committee will continue to investigate this matter to determine 
the nature of Quinn's work for Rich and the amounts that Quinn 
is being paid.
---------------------------------------------------------------------------
    \275\ Jack Quinn Document Production JQ 02974 (E-mail from Marc 
Rich to Jack Quinn (Mar. 6, 2001)) (Exhibit 46).
    \276\ Michael Isikoff, Secret E-Mail, Newsweek, Mar. 10, 2002.
---------------------------------------------------------------------------

E. Quinn's Attempts to Settle the Case

    In October 1999, Quinn followed the advice offered by Eric 
Holder to Gershon Kekst and approached Main Justice in an 
effort to settle the Rich case. He started by drafting a 
presentation for the Justice Department. Quinn also hired Neal 
Katyal, a lawyer who interned for Quinn when he was Counsel to 
Vice President Gore.\277\ Katyal had also worked as National 
Security Advisor to Deputy Attorney General Eric Holder. 
According to Katyal, he was hired more as a consultant than as 
a lawyer.\278\ Katyal characterized the presentation he helped 
prepare as more marketing than legal.\279\ Katyal helped draft 
documents that were presented to Eric Holder. He denied 
contacting Holder directly, or using his access to Holder to 
benefit the Rich lawyers. However, he did acknowledge that on 
several occasions Jack Quinn told him, ``you know, I want to 
talk to Eric about this.'' \280\
---------------------------------------------------------------------------
    \277\ Telephone Interview with Neal Katyal, Associate Professor, 
Georgetown University Law Center (Mar. 26, 2001).
    \278\ Id.
    \279\ Id.
    \280\ Id. Katyal further explained that Quinn already had an 
independent relationship with Holder and would not have needed Katyal's 
assistance in setting up any meetings between them.
---------------------------------------------------------------------------
    Quinn had a number of contacts with Holder about settling 
the Rich case. It appears that Quinn's main request to Holder 
was that he intercede with the Southern District of New York 
and have the Southern District's prosecutors meet with the 
members of the Marc Rich legal team. On October 22, 1999, Quinn 
met with Holder for the first time regarding the Rich case. 
Quinn reviewed a number of points about the Rich case with 
Holder, and asked that Holder intervene with the Southern 
District of New York, to encourage the Southern District to 
meet with Marc Rich's lawyers and reach a settlement of the 
criminal case.\281\ On November 8, 1999, Holder called Quinn 
and told him that he and other senior staff at the Justice 
Department believed that the refusal of the Southern District 
to meet with Rich's lawyers was ``ridiculous.'' \282\ Holder 
recommended that Quinn send a letter requesting a meeting to 
U.S. Attorney Mary Jo White, with copies to Holder and 
Assistant Attorneys General James Robinson and Loretta Collins 
Argrett.\283\ Holder told Quinn that once he got the letter, he 
would call White and suggest that she should meet with 
Quinn.\284\ Holder also told Quinn that he was assigning one of 
his top deputies, David Margolis, to look at the Rich 
matter.\285\
---------------------------------------------------------------------------
    \281\ Jack Quinn Document Production (Note of Jack Quinn) (Exhibit 
47).
    \282\ Jack Quinn Document Production (Note of Jack Quinn (Nov. 8, 
1999)) (Exhibit 48).
    \283\ Id.
    \284\ Id.
    \285\ Id.
---------------------------------------------------------------------------
    After Holder spoke with Mary Jo White about a meeting with 
Quinn and members of the Rich legal team, Quinn made a direct 
appeal to Mary Jo White, writing her on December 1, 1999:

        We would like to begin by asking that you or your 
        representative, along with representatives of the Tax 
        and Criminal Divisions of the Department of Justice, 
        meet with Professors Wolfman and Ginsburg, and members 
        of our legal team, to personally evaluate their 
        conclusions. We urge this approach because the tax 
        allegations underlie so much of the indictment, and 
        because the merits of our tax position can be quickly 
        evaluated. We believe that such a meeting will advance 
        a resolution of this matter. We further believe that we 
        can persuade you that neither the law nor the policies 
        of the Department of Justice support the RICO charges 
        and that, in this regard, too, the indictment as 
        currently drafted should not stand.\286\
---------------------------------------------------------------------------
    \286\ Jack Quinn Document Production (Letter from Jack Quinn and 
Kathleen Behan, Partner, Arnold & Porter, to Mary Jo White, U.S. 
Attorney for the S.D.N.Y., Department of Justice (Dec. 1, 1999)) 
(Exhibit 49).

    On January 18, 2000, Quinn spoke to Holder to see how Mary 
Jo White had received his letter. Holder told Quinn that he had 
spoken to White, and that she was reviewing the matter 
personally. Holder told Quinn that he would ``do what he can,'' 
\287\ and also provided encouragement to Quinn, telling him 
that White ``didn't sound like her guard was up.'' \288\ On 
February 2, 2000, the Southern District responded to Quinn and 
Behan's letter by turning down their request to meet in order 
to modify the indictment.\289\ As Mary Jo White further 
explained in her letter to Quinn, ``I have communicated with 
representatives of the Deputy Attorney General and Assistant 
Attorney General, Criminal Division, and with the Acting 
Assistant Attorney General of the Tax Division. They all concur 
that this is a matter within the discretion of the United 
States Attorney for the Southern District of New York.'' \290\ 
White's letter was a complete rejection of the overtures made 
by Quinn and Holder, and was a significant setback for the Marc 
Rich legal team. Robert Fink sent an e-mail to Avner Azulay 
explaining that ``[w]e received a negative response to our 
overture from [Deputy U.S. Attorney] Shira[h Neiman]. She said 
her office will not negotiate while Marc is away, and that the 
DoJ agrees. JQ was surprised and disappointed that the DoJ had 
agreed even though he had not heard from Eric.'' \291\ Azulay 
responded that ``I am not exactly surprised. I foresaw this 
answer from the moment I read JQ's ltr. I hate to say that `I 
told you so.' I was surprised by JQ's optimistic report.'' 
\292\
---------------------------------------------------------------------------
    \287\ Jack Quinn Document Production (Note of Jack Quinn) (Exhibit 
50).
    \288\ Id.
    \289\ Jack Quinn Document Production (Letter from Mary Jo White, 
U.S. Attorney for the S.D.N.Y., to Jack Quinn and Kathleen Behan, 
Partner, Arnold & Porter (Feb. 2, 2000)) (Exhibit 51).
    \290\ Id.
    \291\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00697 
(E-mail from Robert Fink to Avner Azulay, Director, Rich Foundation 
(Feb. 10, 2001)) (Exhibit 32).
    \292\ Id.
---------------------------------------------------------------------------
    After this rejection, Quinn turned his efforts to Eric 
Holder, asking him to review the Rich case, despite White's 
refusal to do so. Robert Fink laid out Quinn's proposed plan of 
action in a February 17, 2000, e-mail to Marc Rich:

        [Jack] agrees (subject to further discussion) with 
        trying to have Eric help us meet with the tax lawyers 
        in Main Justice (and maybe the head of the criminal 
        division) to see if the professors can convince the 
        chief government tax lawyers that this was a bad tax 
        case. He also agrees that such a conclusion would be 
        useful for many purposes including going back to the 
        SDNY. Similarly, he agrees we should make something of 
        the fact that the office was dealing with fugitives 
        (who surrendered this week) in connection with the 
        Russian money laundering case, while insisting that 
        they can't deal with fugitives. Still, he wants to give 
        Eric a short list of what is wrong with the indictment 
        as he agreed to do that. He feels we can do both.\293\
---------------------------------------------------------------------------
    \293\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00701 
(E-mail from Robert Fink to Marc Rich (Feb. 17, 2001)) (Exhibit 52).

    On February 28, 2000, Quinn sent Holder a short memorandum 
entitled ``Why DOJ Should Review the Marc Rich Indictment.'' 
\294\ In this memorandum, Quinn stated that ``[t]he refusal of 
the SDNY to participate in a discussion of the Marc Rich case 
is sorely disappointing. That office (and DOJ) should not sit 
on a defective indictment.'' \295\ Quinn then explained why he 
believed that the RICO, mail fraud, wire fraud, tax evasion, 
and energy charges against Rich were faulty.\296\ Quinn also 
claimed that the SDNY had recently negotiated with fugitive 
Russian money launderers, despite their policy against 
negotiating with fugitives. Quinn also stated that ``[t]he DOJ 
website lists Marc Rich on its International Fugitive page. 
This involves USG resources and is a potential embarrassment 
for DOJ.'' \297\ Quinn did not provide any explanation, though, 
of why listing Rich as a fugitive would be an embarrassment for 
DOJ, given the fact that the Justice Department had been trying 
to extradite or apprehend him for almost 20 years. Holder 
apparently reviewed Quinn's arguments, but failed to help 
Quinn. Quinn spoke to Holder on March 14, 2000, and reported 
back to Fink, Behan, and Kekst:
---------------------------------------------------------------------------
    \294\ Jack Quinn Document Production (Memorandum entitled ``Why DOJ 
Should Review the Marc Rich Indictment'' (Feb. 28, 2000)) (Exhibit 53).
    \295\ Id.
    \296\ Id.
    \297\ Id.

        [W]e spoke briefly today. it started out badly--``we've 
        gone as far as we can go, can't figure out a way around 
        Shira[h Neiman], etc.''--but I pushed back hard on the 
        russian money laundering culprits and the uneven 
        treatment of marc. he wants to talk further about that 
        with his people, said he'd call me back tomorrow. it's 
        time to move on the GOI [Government of Israel] 
        front.\298\
---------------------------------------------------------------------------
    \298\ Jack Quinn Document Production (E-mail from Jack Quinn to 
Robert Fink (Mar. 14, 2000)) (Exhibit 54). Quinn's suggestion to ``move 
on the GOI front'' was rebuffed by Avner Azulay, who stated that 
``there is no way the MOJ [Israeli Minister of Justice] is going to 
initiate a call to EH--a minister calling a second level bureaucrat who 
has proved to be a weak link.'' Piper Marbury Rudnick & Wolfe Document 
Production PMR&W 00728 (E-mail from Avner Azulay, Director, Rich 
Foundation, to Robert Fink (Mar. 18, 2000)) (Exhibit 55).

Holder did speak to Quinn almost a month later, on March 25, 
2000, and told him that ``we're all sympathetic'' and that the 
``equities [are] on your side.'' \299\ However, Holder 
apparently informed Quinn that he could not force a meeting on 
the Rich case.
---------------------------------------------------------------------------
    \299\ Jack Quinn Document Production (Note of Jack Quinn) (Exhibit 
56). In this conversation, Holder also answered Quinn's arguments 
regarding the SDNY's negotiations with the fugitive Russian money 
launderers, pointing out that they, unlike Rich, agreed to cooperate 
with the government.
---------------------------------------------------------------------------
    At the Committee's February 8, 2001, hearing, Jack Quinn 
confirmed that Holder was sympathetic to his cause:

        I certainly formed the impression that there was, as 
        one of my notes reflect, a view among some senior 
        people in Main Justice that the equities were on our 
        side in some senses.

        Again, I'm not trying to overstate this. I'm not trying 
        to say that I believed that senior people at Main 
        Justice thought the indictment was meritless, but I did 
        absolutely believe that Main Justice thought that the 
        Southern District was being unreasonable in being 
        unwilling to talk to us. I thought that there was a 
        more sympathetic audience at Main Justice.\300\
---------------------------------------------------------------------------
    \300\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 230 
(Feb. 8, 2001) (testimony of Jack Quinn).

However, Eric Holder attempted to qualify his support of Jack 
---------------------------------------------------------------------------
Quinn's arguments:

        With regard to question of equities and whether or not 
        we thought the Southern District was being 
        unreasonable, I think Mr. Quinn was just a little 
        confused. What we were talking about there was them 
        being unreasonable and not having the meeting. The 
        equities were on their side, as Mr. Quinn's side, with 
        regard to the meeting. No one at Main Justice thought 
        that, with regard to the substance, the equities were 
        on Mr. Quinn's side.\301\
---------------------------------------------------------------------------
    \301\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 231 
(Feb. 8, 2001) (testimony of Eric Holder, former Deputy Attorney 
General, Department of Justice).

Even assuming, though, that Holder's support was limited to his 
request for a meeting with Mary Jo White, it is still unclear 
why he thought the ``equities were on Quinn's side,'' even with 
respect to a meeting. The SDNY had a number of meetings and 
negotiations with Rich's attorneys, both before and after 
Rich's flight from the U.S. The SDNY had made a number of 
reasonable offers to settle the case, and U.S. Attorney Otto 
Obermaier and one of his senior aides even met with Rich in 
Switzerland. Rich's lawyers, however, took an inflexible 
position that they would not agree to any plea that required 
jail time. Given this position, the SDNY decided further 
negotiations would not be productive. For Holder to 
characterize the SDNY's position as ``ridiculous,'' suggests 
that Eric Holder supported Quinn's efforts to settle the Rich 
case from the beginning.

III. THE MARC RICH AND PINCUS GREEN PARDON PETITION

A. Rich Contemplated a Pardon Early in 2000

    Jack Quinn and others on the Marc Rich legal team have 
maintained that they did not decide to seek pardons for Rich 
and Green until October 2000.\302\ However, there is extensive 
evidence that Marc Rich and his lawyers were contemplating a 
pardon as early as February 2000, while they were still 
attempting to settle Rich's criminal case with the Southern 
District of New York. It appears that Rich and his legal team 
viewed the Presidential pardon effort as a fall-back in case 
they were unable to settle the criminal case. Moreover, it 
appears that although they were considering petitioning for a 
pardon as early as February 2000, Rich and his legal team 
waited until November 2000 to submit their petition.
---------------------------------------------------------------------------
    \302\ See, e.g., ``The Controversial Pardon of International 
Fugitive Marc Rich,'' Hearings Before the Comm. on Govt. Reform, 107th 
Cong. 45 (Feb. 8, 2001) (testimony of Jack Quinn).
---------------------------------------------------------------------------
    As discussed previously, on February 2, 2000, Mary Jo 
White, the U.S. Attorney for the Southern District of New York, 
rejected Jack Quinn's offer to meet regarding the Marc Rich 
case. After White's rejection, Jack Quinn turned again to 
Deputy Attorney General Eric Holder, and asked him to intervene 
and force a reconsideration of the Marc Rich indictment. By 
late March 2000, it became clear to Quinn that Holder was 
sympathetic to Quinn's requests, but would not force the 
Southern District to meet with Quinn. However, during the time 
that Quinn was discussing his request for a meeting with Eric 
Holder, the Marc Rich legal team was already considering a 
Presidential pardon.
    A privilege log submitted to the Committee by Arnold & 
Porter suggests that attorneys working for Marc Rich had been 
researching Presidential pardons as early as March 1999.\303\ 
It appears, though that serious consideration of a pardon began 
in February 2000, while Quinn was still attempting to settle 
the criminal case through Eric Holder. February 9, 2000, Robert 
Fink sent an e-mail to Jack Quinn and Kathleen Behan, which 
referred to the pardon effort cryptically as the ``second 
option:''
---------------------------------------------------------------------------
    \303\ Arnold & Porter Document Production (Privilege Log, Mar. 27, 
2001) (Exhibit 57). The privilege log notes that a memorandum regarding 
the pardon power was prepared on March 12, 1999, and withheld from the 
Committee on the basis of the attorney work product privilege.

        I briefed Marc and he is awaiting word on your call. (I 
        have also sent Avner a briefed [sic] email letting him 
        know of the current status.) I also told Marc that I 
        would discuss with you and Kitty your views on the 
        second option (whether there is any reason to consider 
        it, or whether what happened here made it so unlikely 
        that you did not think it worthwhile, as I told him 
        that you would not work on it unless you thought there 
        was some possibility of success). He was curious as to 
        your thinking. I told him I would also check on your 
        thinking on what Avner was doing. but let's see what 
        Eric says.\304\
---------------------------------------------------------------------------
    \304\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00695 
(E-mail from Robert Fink to Jack Quinn and Kathleen Behan, Partner, 
Arnold & Porter (Feb. 9, 2000)) (Exhibit 58).

On February 14, 2000, Fink had a telephone discussion with 
Quinn regarding the efforts to settle Rich's criminal case in 
New York. Quinn apparently mentioned the possibility of seeking 
a Presidential pardon, as Fink's notes of the call state in 
part, ``Pardon--mid to late Nov.'' \305\ Two weeks later, 
Robert Fink sent another e-mail to Marc Rich explaining Quinn's 
role in the negotiations with the Justice Department, and his 
potential role in seeking a Presidential pardon. Fink concluded 
his e-mail to Rich by suggesting that Rich enter into a 
retainer agreement with Quinn before they heard back from Eric 
Holder:
---------------------------------------------------------------------------
    \305\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 
01202-03 (Notes of Robert Fink, Feb. 14, 2000) (Exhibit 59).

        I think it makes sense to compensate him for what he 
        has done and may continue to do. Just give it some more 
        thought and we can come back to it soon. We can wait, 
        if you want, to see what Eric says, although it may pay 
        to respond now, before Eric response [sic] to the last 
        message from Jack, so it does not look like you were 
        only willing to pay because of a positive response, as 
        that was not the agreement. Even if we stop everything 
        we are doing, and decide not to investigate the pardon, 
        etc., at this time, we should fold this down in a 
        friendly way.\306\
---------------------------------------------------------------------------
    \306\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00722 
(E-mail from Robert Fink to Marc Rich (Feb. 29, 2000)) (Exhibit 39).

    On March 18, 2000, Avner Azulay sent Fink an e-mail which 
again alluded to the possibility of seeking a pardon in 
November 2000. More importantly, this e-mail also raised the 
possibility of capitalizing on Denise Rich's relationship with 
---------------------------------------------------------------------------
President Clinton:

        I had a long talk with JQ and Michael. I explained why 
        there is no way the MOJ [Israeli Minister of Justice] 
        is going to initiate a call to E[ric] H[older]--a 
        minister calling a second level bureaucrat who has 
        proved to be a weak link. We are reverting to the idea 
        discussed with Abe--which is to send D[enise] R[ich] on 
        a ``personal'' mission to N01. with a well prepared 
        script. IF it works we didin't [sic] lose the present 
        opportunity--until nov--which shall not repat [sic] 
        itself. If it doesn't--then probably Gershon's course 
        of acion [sic] shall be the one left option [sic] to 
        start all over again.\307\
---------------------------------------------------------------------------
    \307\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00729 
(E-mail from Avner Azulay, Director, Rich Foundation, to Robert Fink 
(Mar. 18, 2000)) (Exhibit 60).

At the March 1, 2001, hearing on the Rich pardon, Jack Quinn 
and Robert Fink were asked to explain their understanding of 
this communication. Fink stated that he understood ``N01'' to 
mean President Clinton.\308\ However, neither of the two 
attorneys could provide a definitive answer as to whether 
Denise Rich actually undertook the `` `personal' mission'' to 
the President contemplated in the e-mail. For example, Quinn 
provided the following response:
---------------------------------------------------------------------------
    \308\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 515 
(Mar. 1, 2001) (testimony of Robert Fink).

        Now, I'm telling you, I did not speak to the President 
        in the year 2000 about the Marc Rich matter. I was not 
        a recipient of this [e-mail]. I have no reason to 
        believe that anyone asked Denise Rich to speak to him 
        about this matter, and I have no reason to believe that 
        she did so. But my firsthand knowledge of this is 
        limited to the facts I'm able to testify to.\309\
---------------------------------------------------------------------------
    \309\ Id. at 396 (testimony of Jack Quinn).

When asked what Denise Rich's involvement was around this time, 
Robert Fink provided an even more lawyerly response: ``I have 
an imperfect memory, so I'll be careful. I believe as I sit 
here that there was no involvement by Denise Rich in Mr. Rich's 
problems during that period of time. I have absolutely no 
recollection that she became involved in any way.'' \310\
---------------------------------------------------------------------------
    \310\ Id. at 515 (testimony of Robert Fink).
---------------------------------------------------------------------------
    Furthermore, neither attorney could give a definitive 
answer as to whether this ``well prepared script'' for Denise 
Rich related to the pardon, or to negotiations with the 
Department of Justice. During questioning about the March 18, 
2000, e-mail, Quinn testified that it was possible that ``every 
one of us involved in this thought out loud with each other, is 
there any way to persuade the President to tell Justice, to 
tell the southern district to do something.'' \311\ Quinn 
continued, however, stating, ``It's also entirely possible that 
Mr. Azulay, others, myself included, were involved in a 
conversation where someone said you know we are going to try to 
pardon one of these days.'' \312\ Robert Fink's testimony, 
while also not definitive, suggests that the script related to 
negotiations with the Department of Justice. When asked about 
the last sentence of Azulay's e-mail that discusses reverting 
to ``Gershon's course of action'' if Denise Rich's script were 
to fail, Fink stated, ``I suspect that he's talking about an 
application for a pardon here.'' \313\ Assuming Fink's 
supposition is correct, then the script for Denise would have 
related to Department of Justice negotiations.\314\
---------------------------------------------------------------------------
    \311\ Id. at 396 (testimony of Jack Quinn).
    \312\ Id.
    \313\ Id. at 516 (testimony of Robert Fink).
    \314\ This also tends to suggest that while the attorneys were not 
working on a pardon effort in March of 2000, the idea had already been 
discussed.
---------------------------------------------------------------------------
    In June 2000, Robert Fink had further communications with 
Marc Rich indicating that they were intentionally waiting until 
after the November 2000 election to petition for a Presidential 
pardon:

        Jack Quinn and I traded calls until today. He is well 
        and doing well. He has not forgotten you or what we set 
        out to do, but has pretty much concluded that there is 
        nothing to do until we get closer to (or even passed) 
        [sic] the election, or as he put it, the closing days 
        of the current administration.\315\
---------------------------------------------------------------------------
    \315\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00731 
(E-mail from Robert Fink to Marc Rich (June 6, 2000)) (Exhibit 40).

In July 2000, Fink again e-mailed Rich suggesting that Rich 
sign a retainer agreement with Quinn so that he would be 
---------------------------------------------------------------------------
available to work in the Fall of 2000:

        At the moment the issue raised by you and Michael is 
        how to keep Jack on a ``retainer'' so that he is 
        available for questions that might arise and, more 
        importantly, available in the Fall, if we want him to 
        be. Since the Fall is not far away, and you will know 
        whether you want him to gear up again within four 
        months or so, I suggest that we offer Jack $10,000 per 
        month as a retainer to keep his eyes, ears and brain 
        open to events and thoughts that may be helpful, with 
        the understanding that if a decision is made to proceed 
        that we will renegotiate the monthly retainer to 
        reflect the changed circumstances.\316\
---------------------------------------------------------------------------
    \316\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00732 
(E-mail from Robert Fink to Marc Rich (July 7, 2000)) (Exhibit 41).

    This documentary evidence is supported by the information 
provided by two witnesses who indicate that they were aware of 
pardon discussions well before the Fall of 2000. Abraham 
Foxman, the National Director of the Anti-Defamation League, 
informed the Committee that he recommended that Rich seek a 
Presidential pardon as early as February 2000. Foxman first met 
Marc Rich fifteen years ago through mutual friend Max Maxin who 
was President of B'nai B'rith.\317\ According to Foxman, Maxin 
asked Foxman to meet with Rich ``because Rich felt that there 
may have been anti-Semitism involved in his prosecution.'' 
\318\ According to Foxman, he met Rich in Europe sometime in 
late 1998 or early 1999.\319\ Foxman told Rich at that meeting 
that he did not see any evidence to support a charge of anti-
Semitism.\320\ Later, in February of 2000, Foxman was contacted 
by Zvi Rafiah, who was then congressional liaison for the 
Israeli Embassy in Washington.\321\ Rafiah suggested that 
Foxman go to Paris to meet with Avner Azulay, the former Mossad 
agent who managed Marc Rich's philanthropic organizations.\322\ 
At that meeting in Paris, Foxman allegedly told Azulay that if 
the attorneys for Rich continued to be unsuccessful in their 
negotiations with the prosecutors in New York, a pardon might 
be a ``long-shot'' possibility to consider.\323\ Foxman told 
Azulay that, to the best of his knowledge, Denise Rich ``hated 
Marc Rich's guts,'' but that if someone could convince her to 
speak to the President, ``then you have the beginning of a 
pardon situation.'' \324\ Foxman later learned that, ``as it 
turns out, that is what happened.'' \325\
---------------------------------------------------------------------------
    \317\ Interview with Abraham Foxman, National Director, Anti-
Defamation League (Mar. 19, 2001).
    \318\ Id. Marc Rich has charged on a number of occasions that he 
was singled out for prosecution because he was Jewish. There is no 
support for Mr. Rich's assertion. Mr. Rich's decision to play the race 
card emphasizes the extent to which he has failed to accept 
responsibility for his crimes. Rather than recognizing the extent of 
his criminal acts, of which violation of Department of Energy 
regulations and the Tax Code were among the least, Rich has made 
baseless accusations against federal prosecutors.
    \319\ Id.
    \320\ Id.
    \321\ Id. According to Foxman, Rafiah is now a lobbyist for 
``commercial interests.'' Id. Lobbying registration materials from the 
FEC indicate that Rafiah's main client is Elisra Electronic Systems 
Ltd., a company that develops and manufactures electronic warfare 
systems. Lobbying Registration of Zvi Rafiah (visited Feb. 16, 2001) 
 (Exhibit 61).
    \322\ Id.
    \323\ Id.
    \324\ Id.
    \325\ Id.
---------------------------------------------------------------------------
    Publicist Gershon Kekst claims that he mentioned the 
possibility of a Presidential pardon to Rich's lawyers as early 
as 1999. Kekst had been hired by Rich to assist with strategy 
and public relations relating to his criminal case.\326\ In 
1999, the same time period in which Kekst was looking for a 
Washington lawyer to represent Rich, Kekst was giving general 
thought to the Rich case, including his basic conclusion that a 
public relations campaign could not help Rich. Seeking to 
conduct a ``sanity check'' on his conclusion, Kekst turned to 
former Attorney General William P. Barr, the Senior Vice 
President and General Counsel for Verizon Communications. Kekst 
met Barr through public relations work he did for Verizon 
Communications.\327\ Kekst claimed that he was unaware at that 
time that Barr had been U.S. Attorney General.\328\ However, 
Kekst was impressed with Barr's legal acumen, and thought that 
he could offer some insight into the Rich case. Kekst called 
Barr, and asked him whether he thought that a public relations 
campaign would be useful in trying to resolve the Rich 
case.\329\ Kekst claims that Barr told him that a public 
relations campaign was the worst thing he could do. According 
to Kekst, Barr told Kekst that, assuming the Rich case was a 
bad case, the most that Rich could do was wait until the end of 
the Administration and seek a pardon from President 
Clinton.\330\ Kekst stated that before Barr's suggestion, he 
had never heard any discussion of Rich seeking a Presidential 
pardon. Kekst also believes that Barr told him that even if the 
case against Rich was not justified, as long as Mary Jo White 
was U.S. Attorney and Rudolph Giuliani was Mayor, there was 
nothing to be done.\331\ The latter point appears to have been 
the main thing taken away from the conversation by Kekst and 
those on the Rich team who he informed about the conversation 
with Barr. In December 2000, Robert Fink e-mailed Jack Quinn 
and reminded him that Kekst had spoken to Barr in 1999, and 
that Barr believed ``it paid to wait for the new administration 
and the retiring of several of the then-current players.'' 
\332\ Fink then suggested that they ask Barr to assist with the 
pardon effort, but apparently, Quinn and Fink decided not to 
include a prominent Republican in their efforts.\333\
---------------------------------------------------------------------------
    \326\ Interview with Gershon Kekst, President, Kekst and Co. (Mar. 
15, 2001).
    \327\ Id.
    \328\ Id.
    \329\ Id.
    \330\ Id.
    \331\ Id.
    \332\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00073 
(E-mail from Robert Fink to Jack Quinn (Dec. 26, 2000)) (Exhibit 62).
    \333\ Id.
---------------------------------------------------------------------------
    For his part, Barr recalls that he told Kekst that 
political pressure would be a ``waste of time.'' \334\ Barr 
explained to Kekst that the Justice Department supported the 
Southern District of New York prosecutors because it was a 
matter of significant principle for the Department.\335\ He 
also told Kekst that it was inconceivable that any relief was 
possible as long as Rich remained a fugitive.\336\ In short, 
Barr believed that the White House would never do anything for 
Rich unless Rich were willing to surrender himself and accept 
responsibility for what he had done.\337\
---------------------------------------------------------------------------
    \334\ Telephone interview with William P. Barr (Mar. 10, 2002).
    \335\ Id.
    \336\ Id.
    \337\ Id.
---------------------------------------------------------------------------
    In the days immediately following the Rich pardon, Jack 
Quinn and the other lawyers for Marc Rich emphasized that they 
did not decide to seek a pardon for Rich until October 2000. 
What they did not make clear, however, was that they were 
actively considering a pardon much earlier. They decided to 
wait until the closing days of the Clinton Administration to 
apply for the pardon. While the reasons for the delay are not 
clear, there are two likely reasons: first, by waiting until 
December to apply, opponents of the pardon would have a limited 
amount of time to learn of and resist the pardon effort; 
second, the Clinton White House would have limited time to 
conduct a detailed review of the petition and learn of its 
numerous flaws.

B. The Preparation of the Pardon Petition

    The centerpiece of Marc Rich's effort to obtain a 
Presidential pardon was the pardon petition, which was put 
together by the Marc Rich legal team in October and November 
2000. The main attorneys involved in preparing the pardon 
petition were Jack Quinn; Kathleen Behan; Robert Fink; 
Christopher Man, an associate at Arnold & Porter; Michael 
Hepworth, Of Counsel at Piper Marbury Rudnick & Wolfe; and G. 
Michael Green of Dickstein Shapiro Morin & Oshinsky. These 
lawyers spent dozens, if not hundreds, of hours compiling the 
petition.
    The resulting document, which had a number of 
misrepresentations and factual inaccuracies, was a surprisingly 
poor effort, considering the amount of time and money that went 
into it. The argument section of the petition, the only portion 
that was actually drafted anew in October and November 2000, 
totaled 31 double-spaced pages. The first 20 of those pages 
were dedicated to biographical sketches of Rich and Green. 
These pages attempted to cast Rich and Green in a favorable, 
even likable light. These statements seem almost laughable 
given what the world knows now about Marc Rich and Pincus 
Green:

        Mr. Rich and Mr. Green have lived exemplary, indeed, 
        remarkable lives. Although they have suffered terrible 
        hardships as the result of their exile from the United 
        States, they have continued to work productively and 
        contribute to society.\338\
---------------------------------------------------------------------------
    \338\ Petition for Pardon for Marc Rich and Pincus Green, 
Memorandum in Support of Petitioners' Application for Pardon 4 (Dec. 
11, 2000) (Appendix III).

Although it is true that the work of Rich and Green assisted 
the governments of countries like Iraq, Iran, and Libya, it is 
difficult to argue that they contributed to the United States 
once they fled their country and attempted to renounce their 
citizenship.
    Included in the attempt to make Marc Rich seem like the 
victim was a reference to the tragic death of his daughter 
Gabrielle while Marc Rich was a fugitive from justice: 
``Because Gabrielle lived and died in the United States, Mr. 
Rich felt the extra weight of being unable to personally visit 
with her during her final months.'' \339\ This claim, which was 
repeated by Denise Rich in her appeals to the President, made 
it sound as if the prosecutors in the Southern District of New 
York denied Rich the opportunity to visit with his dying 
daughter. Nothing could be further from the truth. Rich knew 
that if he returned he would receive bail, and that he would 
not be incarcerated unless convicted of the crimes he had been 
accused of committing. He was prevented from returning to visit 
his dying daughter only if he refused to face the U.S. justice 
system. Rich's desire to both have his cake and eat it too, 
makes it difficult to generate any sympathy for him in this 
matter. In fact, the only possible conclusion is that Marc Rich 
placed his own needs over those of his daughter.
---------------------------------------------------------------------------
    \339\ Id. at 7 n.1.
---------------------------------------------------------------------------
    The petition also made it sound as if Rich was providing 
the world with an economic benefit through his dealings:

        In building this business, Mr. Rich and Mr. Green made 
        substantial contributions to the world economy by 
        increasing competition--and even breaking cartels--in 
        the physical commodities industries.\340\
---------------------------------------------------------------------------
    \340\ Id. at 6.

Of course, the petition did not mention that Marc Rich's 
business was built by supporting corrupt and dictatorial 
regimes across the world, ranging from Communist Cuba to 
apartheid South Africa. Nor did the petition mention that 
Rich's deals with third world countries meant that Rich himself 
gained monopolies over commodities that often paid developing 
nations less than fair-market prices for their commodities. Nor 
did the petition point out that Rich provided opportunities to 
those regimes the United States was actively attempting to 
penalize, including Iran during the period when 54 Americans 
were held hostage at the U.S. Embassy in Tehran.
    The petition also made the claim that Rich and Green's 
lives were exemplary, setting aside the 65-count indictment:

        Other than the allegations for which clemency is 
        sought, Mr. Rich and Mr. Green never have been charged 
        with a crime. Indeed, Mr. Rich's and Mr. Green's lives 
        both before and after the accusations have been ones of 
        hard-working, resourceful businessmen who have become 
        remarkably successful and have devoted much time and 
        money to philanthropy and statesmanship.\341\
---------------------------------------------------------------------------
    \341\ Id. at 20.

Again, the pardon petition made no mention of other less-than-
savory aspects of Marc Rich's business dealings, for which he 
was never prosecuted, but which remain of questionable legality 
and morality, including supporting the Khomeini regime while it 
held U.S. hostages, selling weapons and missile parts to 
Khomeini, and trying to do business with Saddam Hussein during 
the Gulf War.
    The petition then takes six pages to argue that the 
indictment of Rich and Green was flawed and unfair, and the 
appropriate subject of a Presidential pardon. As described 
below, these arguments were largely a rehash of the same 
arguments that Rich and his lawyers had been making since the 
indictment was handed down. The final four pages of the 
petition were used to explain that it was permissible for the 
President to issue a pardon before a conviction. Also attached 
to the petition were the ``letters of support,'' as well as 
other attachments, including the tax analysis by Professors 
Ginsburg and Wolfman, as well as other varied materials related 
to negotiations with the Southern District of New York and the 
President's pardon power in general.

C. The Misleading Legal Arguments in the Petition

    The pardon petition crafted by Jack Quinn and the other 
attorneys on the Rich legal team is filled with numerous 
misleading and disingenuous legal arguments. Many commentators 
have stated that Quinn was merely being a good lawyer providing 
zealous representation to Marc Rich. However, many of the 
points made by Quinn and others go beyond zealous 
representation to the point of deception. Quinn had a 
responsibility to be honest in the pardon petition, and he 
failed. Normally, such dishonesty would not have a tremendous 
effect, but when it was combined with the total failure of the 
Clinton White House to examine the Rich case, the result was 
disastrous.
            1. The Indictment of Rich Was Not Flawed
    The first charge leveled by Quinn and the Rich legal team 
is that Rich and Green and their companies, Marc Rich + Co. 
A.G. (``A.G.'') and Marc Rich + Co. International, Ltd. 
(``International''), were subjected to an ``unprecedented 
criminal investigation'' and ``a unique indictment based on 
now-discarded and rejected theories.'' \342\ Notwithstanding 
the fact that this is an argument made by almost all 
individuals and companies accused of white collar crime, this 
claim is especially specious here.
---------------------------------------------------------------------------
    \342\ Id.
---------------------------------------------------------------------------
                a. The Department of Energy Regulations Were
                    Fair
    In his pardon petition, Rich claimed to have been the 
victim of overly complex and unfair Department of Energy 
regulations. One element of this line of defense is that the 
regulations governing the conduct for which Rich and Green were 
indicted were too confusing. According to the pardon petition, 
the Department of Energy regulations limiting prices in oil 
reselling were ``extremely complicated,'' and were therefore 
rescinded in January 1981 because they were ``unworkable.'' 
\343\ Such an argument is completely disingenuous. Rich and 
Green were able to understand the regulations well enough to 
exploit them for millions of dollars in profit. Regardless of 
whether they outlived their usefulness, they were deemed 
appropriate at the time when the United States was seriously 
concerned about fuel shortages. More important, they were the 
law at that time, and Rich and Green therefore had a duty to 
play by the rules or face the consequences. Indeed, other 
companies were able to obey the law and were not subject to 
prosecution.
---------------------------------------------------------------------------
    \343\ Id. at 21.
---------------------------------------------------------------------------
    Quinn also argued that the Department of Energy indicated 
that Rich and his company ``properly . . . accounted for the 
transactions.'' \344\ This argument is irrelevant because 
Rich's accounting was not the central issue. Rather, Rich's 
companies falsified reports in order to hide profits over the 
legal limits in violation of law. Marc Rich's own companies 
admitted as much when they pled guilty and paid $200 million in 
taxes, penalties, and interest. As the lawyers for Rich's 
companies stated in federal court:
---------------------------------------------------------------------------
    \344\ Id. at 27.

        Beginning in September 1980 International generated 
        millions of dollars of income from crude oil 
        transactions which International should have disclosed 
        but intentionally did not disclose to the Internal 
---------------------------------------------------------------------------
        Revenue Service and the Department of Energy.

                                *  *  *


        In connection with matters within the jurisdiction of 
        agencies of the United States, specifically the 
        Department of Energy and the Internal Revenue Service, 
        International and A.G. knowingly and wilfully made 
        those documents and the ERA 69s filed with the 
        Department of Energy which were false in that they 
        failed to disclose material facts regarding the actual 
        income from those crude oil transactions[.] \345\
---------------------------------------------------------------------------
    \345\ Transcript of Allocution, U.S. v. Marc Rich + Co., A.G. et 
al. 18-19 (S.D.N.Y. Oct. 11, 1984) (S 83 Cr. 579) (Exhibit 5).

This language from the allocution clearly demonstrates not only 
that the Department of Energy in no way exonerated Rich and 
Green's activities, but also that Rich and Green and their 
companies clearly understood the nature of the supposedly 
complicated regulations well enough to violate them ``knowingly 
and wilfully.'' Their arrangement with West Texas Marketing was 
clearly intended to contravene the regulations and perpetrate 
tax fraud against the United States.
                b. Rich and Green Were Not Singled Out
    Another element of Quinn's attack on the indictment is that 
Rich and Green were unfairly singled out because ``others 
engaging in similar activity'' were pursued only in civil 
regulatory actions.\346\ This argument is simply false, and a 
minimally competent lawyer would have known that it was false. 
Even Rich's own lawyers had earlier determined this in their 
research, which was also in Jack Quinn's possession. According 
to a 1988 memo drafted by Rich's lawyers, there were 48 
criminal cases nationwide brought against crude oil 
resellers.\347\ In 14 cases, the defendants spent some time in 
prison.\348\ Texas resellers John Troland and David Ratliff of 
West Texas Marketing were prosecuted for ``daisy chain'' oil 
transactions and for falsely classifying different types of 
crude oil to skirt DOE regulations. It was while serving 10 
months in prison that they first alerted prosecutors to the 
activities of Rich and Green.
---------------------------------------------------------------------------
    \346\ Petition for Pardon for Marc Rich and Pincus Green, 
Memorandum in Support of Petitioners' Application for Pardon 22 (Dec. 
11, 2000) (Appendix III).
    \347\ Jack Quinn Document Production (Memorandum from Mark Ehlers 
to Scooter Libby 1 n.1 (June 10, 1988)) (Exhibit 63).
    \348\ Id. at 1-2 n.2.
---------------------------------------------------------------------------
    Rich's lawyers have also argued that, unlike Rich and 
Green, the few violators who were pursued criminally were 
involved in ``daisy chaining'' or miscertification (falsely 
labeling controlled oil as uncontrolled oil).\349\ However, 
Rich and Green were not alone in facing criminal penalties even 
though they were not accused of miscertification. Oscar Wyatt, 
David Chalmers, and Sam Wilson, Jr. pled guilty to a willful 
violation of the price control enforcement provision that 
involved no accusation of miscertification.\350\ These cases 
are consistent with the relevant statute, which distinguishes 
between civil and criminal violations on the basis of whether 
the conduct was willful--not whether it involved 
miscertification.\351\
---------------------------------------------------------------------------
    \349\ Quinn made this argument before the Senate Judiciary 
Committee. See ``President Clinton's Eleventh Hour Pardons,'' Hearing 
Before the Senate Judiciary Comm., 107th Cong. 78 (Feb. 14, 2001) 
(testimony of Jack Quinn).
    \350\ Jack Quinn Document Production (Memorandum from Mark Ehlers 
to Scooter Libby 2-3 n.4 (June 10, 1988)) (Exhibit 63).
    \351\ 15 U.S.C. Sec. 754 (1982 ed.)
---------------------------------------------------------------------------
    More important, Rich and Green were also involved in 
illegal conduct that was unique in the context of the commodity 
they were trading. In September 1980, DOE clarified its oil 
reseller regulations to make it plain that resellers were not 
permitted to profit more than $0.20 per barrel.\352\ Rich and 
Green made profits far in excess of that limitation but created 
fraudulent invoices and filed false reports to hide about $100 
million in illegal profits from both the DOE and the IRS. In 
other words, Rich and Green were engaged in classic criminal 
financial fraud. The grand jury in New York had ample evidence 
from documents and witnesses that Rich and Green were willfully 
violating the price controls and, as discussed above, their 
companies later pled guilty to doing so.\353\
---------------------------------------------------------------------------
    \352\ U.S. v. Marc Rich, Pincus Green et al. 9 (S.D.N.Y. Mar. 6, 
1984)(S 83 Cr. 579).
    \353\ Telephone Interview with Morris ``Sandy'' Weinberg, Jr., 
former Assistant U.S. Attorney for the S.D.N.Y., Department of Justice 
(Feb. 7, 2001).
---------------------------------------------------------------------------
    Quinn further tried to advance the argument that Rich and 
Green's entire case was sui generis by stating in the petition 
that similarly situated individuals and corporations such as 
ARCO were never criminally charged.\354\ However, ARCO was not 
a similarly situated corporation because it was never involved 
in attempting to hide illegal profits as was Rich's company. In 
fact, in looking at the more analogous case of the corporations 
(West Texas Marketing and Listo Petroleum) that helped Rich 
hide illegal profits, the executives of those companies were 
prosecuted. Two executives from West Texas Marketing served 10 
months in prison and one from Listo pled guilty to felony 
charges of making false statements and was sentenced to five 
years probation and fined $5,000.\355\
---------------------------------------------------------------------------
    \354\ Petition for Pardon for Marc Rich and Pincus Green, 
Memorandum in Support of Petitioners' Application for Pardon 26 (Dec. 
11, 2000) (Appendix III).
    \355\ See Patrick E. Tyler, U.S. Grand Jury Probing Shift of Oil 
Profits, Wash. Post, Oct. 18, 1982, at A1. See also Rich Associate Gets 
Probation, Associated Press, Dec. 17, 1984.
---------------------------------------------------------------------------
    Beyond being completely false, the argument that Marc Rich 
was ``singled out'' for prosecution also draws upon the 
preposterous claims, made by Marc Rich himself, that the 
prosecution was the result of anti-Semitism.\356\ In an 
interview with the Israeli Ma'ariv Weekend Magazine, Rich 
stated, ``I'm convinced that the fact that I was a foreigner 
and a relative newcomer on the oil-trading market and Jewish 
influenced the manner in which my case was handled.'' \357\ 
Rich has never provided any support for this outlandish claim. 
Rich's clumsy attempt to play the race card was rejected even 
by associates like Abraham Foxman, who found no evidence to 
support it. Rich's attorneys did not make any overt reference 
to anti-Semitism in the pardon petition, but did repeatedly 
claim that Marc Rich had been ``singled out'' by prosecutors, 
never explaining why they believed that to be the case. 
Furthermore, Quinn's own notes make it appear possible that he 
raised the specter of anti-Semitism in his last-minute appeal 
to the President on January 19, 2001.\358\ It is unfortunate 
that the President found Rich's arguments believable--when in 
fact, they were completely inaccurate--a fact the President 
could have discovered with minimal due diligence.
---------------------------------------------------------------------------
    \356\ While these arguments were not made explicitly in the pardon 
petition, Rich made them in the media, and Jack Quinn may have made 
them to President Clinton. See Section IV(G)(4).
    \357\ Bo'az Ga'on, Rich as Korach, Ma'ariv Weekend Magazine, Oct. 
1, 1999 (Exhibit 6).
    \358\ For a detailed discussion, see Section IV(G)(4) below.
---------------------------------------------------------------------------
                c. Rich and Green Did Trade with the Enemy
    The pardon petition claims that ``the Iranian [trading with 
the enemy] counts were added to the indictment to incite public 
opinion against the defendants.'' \359\ The petition further 
claims that ``[t]he prosecutors quietly dropped the Iranian 
claims against the companies, but never dealt with the claims 
against the individuals.'' \360\ By making this claim, Rich 
suggested that the charges had no merit. In fact, the charges 
appear to have been accurate, and were only dropped from the 
indictment for technical reasons. The trading with the enemy 
charges against the Marc Rich companies were dropped because 
Clyde Meltzer--the Listo petroleum executive who, unlike Rich 
and Green, did not flee the United States--was not involved in 
trading with Iran. Since Rich and Green fled and were 
unavailable for trial, the only charges of conspiracy against 
the remaining defendants were unrelated to Iran.
---------------------------------------------------------------------------
    \359\ Petition for Pardon for Marc Rich and Pincus Green, 
Memorandum in Support of Petitioners' Application for Pardon 22 (Dec. 
11, 2000) (Appendix III).
    \360\ Id.
---------------------------------------------------------------------------
    The charges against Rich and Green personally for trading 
with Iran during the hostage crisis were never dropped or 
dismissed. They remained in effect at the time of the 
pardon.\361\ Indeed, there is voluminous evidence that Rich and 
Green traded with Iran, in addition to a number of other 
prominent enemies of the United States. While a foreign company 
may have been allowed to trade with Iran, Rich and Green were 
American citizens and it was illegal for them to engage in 
trade with Iran regardless of whether they did so on foreign 
soil or through the use of a foreign corporation. In fact, the 
evidence showed that Rich and Green negotiated the deals from 
the Manhattan offices of Marc Rich International, an American 
firm.\362\ It was the height of irresponsibility for Marc Rich 
and his lawyers to suggest that prosecutors charged Rich with 
trading with the enemy only to ``incite public opinion'' 
against Rich when Rich was, in fact, trading with Iran.
---------------------------------------------------------------------------
    \361\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 110 
(Feb. 8, 2001) (testimony of Morris ``Sandy'' Weinberg, Jr., former 
Assistant U.S. Attorney for the S.D.N.Y., Department of Justice).
    \362\ Id.
---------------------------------------------------------------------------
    Jack Quinn, who signed the pardon petition, admitted in the 
Committee's February 8, 2001, hearing that Rich had indeed 
traded with Iran:

        Mr. Shays. Did Mr. Rich trade with Iran when U.S. 
        hostages were being held captive?

        Mr. Quinn. I do not know the precise answer to that 
        question. It is my belief that he traded with Iran. I 
        can't tell you right now when that occurred.

        Mr. Shays. Should it make any difference to you if it 
        did?

        Mr. Quinn. Again, I approached this as a lawyer 
        concerned with the indictment that was before me and 
        whether or not it should stand. I was not here to be a 
        character witness. I was here to take on four points--

        Mr. Shays. It didn't make any difference to you. Should 
        it have made a difference to the President of the 
        United States?

        Mr. Quinn. It is something he well may have taken into 
        consideration, certainly.\363\
---------------------------------------------------------------------------
    \363\ Id. at 111.

While Quinn admitted that he knew that Rich did indeed trade 
with Iran, he failed to address how he could state in the 
pardon petition that ``the prosecutors quietly dropped the 
Iranian charges against the companies, but never dealt with the 
claims against the individuals.'' Quinn likely failed to 
address this statement because he knew the implication that the 
charges were ``quietly'' dropped for lack of evidence is 
misleading.
                d. Rich and Green Did Evade Federal Taxes
    Quinn and the Rich legal team also attacked the core tax 
evasion counts in the indictment against Rich and Green. As 
they argued in the petition, ``The tax treatment of the 
transactions in the indictment, however, is governed by a U.S.-
Swiss tax treaty, which was ignored by the prosecution. . . . 
The transactions in issue were consistently reported in 
accordance with the tax treaty.'' \364\ In making these 
arguments, Rich's lawyers relied on what they called the 
``independent'' analyses of law professors Bernard Wolfman and 
Martin Ginsburg.\365\ However, the language from the pardon 
application is misleading in its use of the word 
``independent.'' First of all, the professors were paid 
handsomely by Marc Rich for their work on his behalf. Professor 
Ginsburg, husband of Supreme Court Justice Ruth Bader Ginsburg, 
was paid $66,199 for his work on the Rich case.\366\ Professor 
Wolfman was paid $30,754 for his analysis.\367\ Wolfman was 
hired as a consultant by one of Rich's firms, and was paid 
between $250 and $300 per hour.\368\ Hence, the analysis was 
not ``independent'' of Marc Rich. Second, the professors did 
not come to the same conclusion ``independently'' of each 
other, but rather worked jointly. Third, they emphasized that 
their analysis made ``no independent verification of the 
facts,'' and that they were merely ``accepting the statements 
thereof made to us by'' Marc Rich's attorneys.\369\ As Rich 
prosecutor Martin Auerbach stated:
---------------------------------------------------------------------------
    \364\ Petition for Pardon for Marc Rich and Pincus Green, 
Memorandum in Support of Petitioners' Application for Pardon 23 (Dec. 
11, 2000) (Appendix III).
    \365\ Id.
    \366\ Letter from Professor Martin D. Ginsburg, Professor, 
Georgetown University Law Center, to the Honorable Dan Burton, 
Chairman, Comm. on Govt. Reform (Feb. 12, 2001) (Exhibit 64). Ginsburg 
is also of Counsel at Fried, Frank, Harris, Shriver & Jacobson. Of the 
$66,199 received by his firm on the Rich matter, $43,980 reflected work 
by Ginsburg personally. The remainder reflects work by other attorneys 
assisting Ginsburg. Ginsburg billed his time at rates of $300 to $400 
per hour. Id.
    \367\ Letter from Bernard Wolfman, Professor, Harvard Law School, 
to the Honorable Dan Burton, Chairman, Comm. on Govt. Reform (Feb. 8, 
2001) (Exhibit 65).
    \368\ Id.
    \369\ Jack Quinn Document Production (Letter from Bernard Wolfman, 
Professor, Harvard Law School, to Gerard E. Lynch, Criminal Division 
Chief of the Office of the U.S. Attorney for the S.D.N.Y., Department 
of Justice (Dec. 7, 1990)) (Exhibit 66).

        The transmittal letter that came with that analysis 
        says it all and betrays the problem, the fundamental 
        flaw in the pardon application as it was applied to Mr. 
        Rich and Mr. Green, and that is a complete absence of a 
        knowledge of the facts, the true facts of this case, 
---------------------------------------------------------------------------
        the facts that led the companies to plead guilty.

        When that analysis was sent 10 years ago, the 
        professors who wrote it said, . . . quote, making no 
        independent verification of the facts but accepting the 
        statements thereof made to us by Mr. Rich and Mr. 
        Green's lawyers.

        And that is the problem. The President relied on the 
        facts as described to him by Mr. Rich and Mr. Green's 
        lawyers, making no independent investigation.\370\
---------------------------------------------------------------------------
    \370\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 106 
(Feb. 8, 2001) (testimony of Martin J. Auerbach, former Assistant U.S. 
Attorney for the S.D.N.Y., Department of Justice).

In the end the analysis by the two professors cannot, and does 
not, attempt to explain the necessity for double accounting, 
phony invoices, and false reports to the Department of Energy. 
Nor do the professors discuss the double accounting, phony 
invoices, and false reports employed by Rich and Green to hide 
their illegal profits. The only rational explanation for the 
artifices employed by Rich is that he was fraudulently 
attempting to hide profits from the DOE and the IRS. In the 
final analysis, it is hard to avoid the conclusion that 
Professors Ginsburg and Wolfman sold their names to the highest 
bidder, thereby turning their backs on the accounting and legal 
considerations that were necessary for a meaningful 
professional opinion.
    Quinn further attempted to justify the granting of a pardon 
by explaining that Rich's companies reached a settlement with 
the government and ``paid a total of approximately 200 million 
dollars in back taxes, interest, fines and foregone tax 
deductions, an amount far in excess of any taxes, penalties or 
interest which might have been assessed in a civil tax 
proceeding.'' \371\ Far from being a reason to grant a pardon, 
this fact only proves the point that Rich and Green fled from 
justice because they were caught red-handed and most likely 
would have gone to prison if they stood trial in the United 
States. Marc Rich + Co., A.G. and Marc Rich + Co. 
International, Ltd. each pled guilty to making false statements 
and evading about $48 million in taxes because the strength of 
the case against them was overwhelming.\372\ Rich's companies 
pled guilty to a criminal scheme to conceal ``in excess of $100 
million in taxable income . . . most of which income was 
illegally generated through the defendants' violations of 
federal energy laws and regulations.'' \373\ Rich's companies 
further admitted that they had engaged in this criminal scheme 
``together with Marc Rich, Pincus Green . . . and others . . . 
unlawfully, wilfully and knowingly[.]'' \374\ That Rich's 
companies paid these moneys and made these admissions of guilt 
squarely contradicts Quinn's claim that the indictment was 
without merit.
---------------------------------------------------------------------------
    \371\ Petition for Pardon for Marc Rich and Pincus Green, 
Memorandum in Support of Petitioners' Application for Pardon 24-25 
(Dec. 11, 2000) (Appendix III).
    \372\ The case against Rich and Green individually was just as 
strong as the case against the companies. As noted above, Edward 
Bennett Williams offered to have Rich pay $100 million to settle the 
charges against him individually. Prosecutor Sandy Weinberg told 
Williams that the government would not reach any settlement that did 
not result in jail time for Rich. See ``The Controversial Pardon of 
International Fugitive Marc Rich,'' Hearings Before the House Comm. on 
Govt. Reform, 107th Cong. 176 (Feb. 8, 2001) (testimony of Morris 
``Sandy'' Weinberg, Jr., former Assistant U.S. Attorney for the 
S.D.N.Y., Department of Justice). See also Evan Thomas, The Man to See: 
Edward Bennett Williams 415-16 (1991).
    \373\ Indictment, U.S. v. Marc Rich, Pincus Green et al. at 3-4 
(Mar. 6, 1984) (S 83 Cr. 579) (Exhibit 4). See Transcript of 
Allocution, U.S. v. Marc Rich + Co., A.G., Marc Rich Int'l, Ltd. et al. 
at 11 (Oct. 11, 1984) (SS 83 Cr. 579) (Exhibit 5).
    \374\ Indictment, U.S. v. Marc Rich, Pincus Green et al. at 3 (Mar. 
6, 1984) (S 83 Cr. 579) (Exhibit 4). See Transcript of Allocution, U.S. 
v. Marc Rich + Co., A.G., Marc Rich Int'l, Ltd. et al. at 11 (Oct. 11, 
1984) (SS 83 Cr. 579) (Exhibit 5).
---------------------------------------------------------------------------
            2. The Prosecutors Were Not ``Overzealous''
    A second theme in the pardon application is that the 
investigation and indictment of Rich and Green was flawed 
because the prosecutors were overzealous and overly ambitious. 
Quinn attacked not only Weinberg and Auerbach on this basis, 
but also Rudolph Giuliani who was at the time the United States 
Attorney for the Southern District of New York. As with the 
claims of the flawed indictment, however, these claims were 
also misleading.
                a. The Prosecutors Negotiated with Rich and
                    Green
    The pardon petition claims that the federal prosecutors 
refused to negotiate with Rich and Green. Quinn repeated this 
claim before the Committee, as well as in the press. However, 
as is discussed in detail above, Rich and Green were fugitives. 
The Southern District of New York had (and continues to have) a 
longstanding policy of not negotiating with fugitives from 
justice. As was explained by the SDNY in its February 2, 2000, 
letter to Quinn, negotiating with fugitives ``would give 
defendants an incentive to flee,'' providing them ``the 
inappropriate leverage and luxury of remaining absent unless 
and until the Government agrees to their terms.'' \375\ The 
particular history of the office's dealings with Rich counseled 
against negotiations. As is discussed in detail above, Rich had 
a history of acting in bad faith during the grand jury 
investigation. From refusal to obey grand jury subpoenas to 
attempting to fly two steamer trunks full of subpoenaed 
documents to Switzerland, Rich showed that he was not the type 
of defendant with whom to negotiate.
---------------------------------------------------------------------------
    \375\ Jack Quinn Document Production (Letter from Mary Jo White, 
U.S. Attorney for the S.D.N.Y., Department of Justice, to Jack Quinn 
and Kathleen Behan, Partner, Arnold & Porter (Feb. 2, 2000)) (Exhibit 
51).
---------------------------------------------------------------------------
    Yet even with such outrageous conduct, the Southern 
District of New York made many good faith efforts to reach an 
accommodation with Rich. During the investigation of Rich and 
his companies, prosecutors undertook numerous negotiations with 
Rich's lawyers, which resulted in the guilty pleas by Rich's 
companies. Even after Rich fled the country, prosecutors 
attempted to negotiate terms for Rich's return. In the early 
1990s, U.S. Attorney Otto Obermaier and a top prosecutor in his 
office took the extraordinary step of flying to Switzerland and 
meeting with Marc Rich in an attempt to negotiate a resolution 
to the case. Moreover, the Southern District made numerous 
accommodations for Rich, including offering to drop the RICO 
charges as well as allowing him and Green to stand trial 
without spending any time in jail prior to trial. Despite these 
efforts, Rich and Green refused to return to the United States 
to stand trial. Rather, they would only return as part of a 
settlement that guaranteed they would not serve jail time 
unless convicted. It is therefore misleading for Quinn to 
simply state that the Southern District of New York ``takes the 
position that it will not even discuss the matter while Mr. 
Rich and Mr. Green continue to live outside of the United 
States.'' \376\ By itself, this statement fails to account for 
the numerous good faith efforts of the prosecutors in spite of 
their well-founded reluctance to negotiate with fugitives.
---------------------------------------------------------------------------
    \376\ Petition for Pardon for Marc Rich and Pincus Green, 
Memorandum in Support of Petitioners' Application for Pardon 25 (Dec. 
11, 2000) (Appendix III).
---------------------------------------------------------------------------
    Quinn also argued in the petition that the Southern 
District had ``negotiated with numerous other absent defendants 
over the years, and the Department of Justice has no such 
policy against such negotiations.'' \377\ However, as the 
Southern District noted in its February 2, 2000, letter to 
Quinn, Department of Justice policy places the decision to 
negotiate with a fugitive within the discretion of the office 
responsible for the prosecution.\378\ The Southern District of 
New York was well within the reasonable exercise of its 
discretion to require Rich to return to the United States 
before engaging in further negotiation, especially given Marc 
Rich's history of bad faith behavior and brazen legal tactics.
---------------------------------------------------------------------------
    \377\ Id.
    \378\ Jack Quinn Document Production (Letter from Mary Jo White, 
U.S. Attorney for the S.D.N.Y., Department of Justice, to Jack Quinn 
and Kathleen Behan, Partner, Arnold & Porter (Feb. 2, 2000)) (Exhibit 
51).
---------------------------------------------------------------------------
    Finally, Quinn argued that the Southern District refused to 
negotiate with his legal team by failing to agree to a meeting 
between Professors Wolfman and Ginsburg and tax experts in the 
Department of Justice.\379\ This, too, is misleading. As the 
Southern District explained in the February 2, 2000, letter to 
Quinn, ``in 1987, an Assistant in this Office met with Mr. 
Rich's counsel and listened to the same presentation by 
Professor Martin D. Ginsburg referenced in your letter 
regarding the merits of the tax charges.'' \380\ Prosecutors 
had rejected the Wolfman/Ginsburg analysis because it was based 
on an inaccurate and incomplete representation of the facts of 
this case. Its legal conclusions were, therefore, irrelevant. 
For the Southern District to meet with the professors again 
would have been redundant and fruitless.
---------------------------------------------------------------------------
    \379\ Petition for Pardon for Marc Rich and Pincus Green, 
Memorandum in Support of Petitioners' Application for Pardon 26 (Dec. 
11, 2000) (Appendix III).
    \380\ Jack Quinn Document Production (Letter from Mary Jo White, 
U.S. Attorney for the S.D.N.Y., Department of Justice, to Jack Quinn 
and Kathleen Behan, Partner, Arnold & Porter (Feb. 2, 2000)) (Exhibit 
51).
---------------------------------------------------------------------------
                b. The Rich Prosecution Was Not Tainted with
                    Media Attention
    Quinn and the Rich legal team further tried to discredit 
the prosecution by claiming that United States Attorney Rudolph 
Giuliani was unfairly bringing the glare of the media to the 
case. According to the pardon petition, Giuliani 
``aggressively'' pursued Rich and Green in court as well as in 
the press: ``Not only did Mr. Giuliani and other prosecutors 
from his office speak frequently to the media in off and on 
record conversations, the office held formal press conferences 
where purported `evidence' against Mr. Rich and Mr. Green was 
showcased to the press.'' \381\ Responding to this charge, 
Mayor Giuliani said on Meet the Press,
---------------------------------------------------------------------------
    \381\ Petition for Pardon for Marc Rich and Pincus Green, 
Memorandum in Support of Petitioners' Application for Pardon 23 (Dec. 
11, 2000) (Appendix III).

        First of all, the indictment was actually just about 
        put together before I even became United States 
        Attorney. It's been pursued by at least three 
        Democratic appointees, who were United States attorney 
        and the Justice Department, that had him number six on 
        the fugitive list, was President Clinton's Democratic 
        Justice Department. And the United States attorney of 
        the Southern District in New York, an appointee of 
        President Clinton, is as outraged as I am by the pardon 
        that was given here. . . . You've been covering me a 
        long time, right, running for office? Did you ever hear 
        me mention Marc Rich? So this was hardly used by me in 
        any way in any of my political campaigns. . . . And the 
        fact that he was a fugitive--it was not something 
        [about which I would] say, ``Gee, look what a good job 
        I did as United States attorney.'' So that's kind of a 
        silly thing to [s]ay.\382\
---------------------------------------------------------------------------
    \382\ Meet the Press (NBC television broadcast, Jan. 28, 2001).

    Rudolph Giuliani was one of dozens of prosecutors, 
Republican and Democrat, who worked on the Rich case. Robert 
Litt and Gerald Lynch were prominent Democrats who were also 
involved in the case. It would be strange for Quinn also to 
accuse them of overcharging. Litt was one of Attorney General 
Janet Reno's closest advisors, and Lynch, currently a professor 
at Columbia University Law School, was appointed to the federal 
bench by President Clinton. The two main prosecutors who 
brought the Rich case, Morris Weinberg and Martin Auerbach, 
were Democrats as well. The attempt to cast the Rich indictment 
as the result of partisan prosecutorial overreaching by Rudolph 
Giuliani is simply one more fabrication by Marc Rich's legal 
team. This argument had no basis in reality, and likely was 
invented to appeal to President Clinton's partisan instincts, 
as well as his dislike for aggressive prosecutors. As many have 
observed, by the end of his term, President Clinton was very 
sensitive to issues of prosecutorial overreaching, as a result 
of his perceptions of the Independent Counsel 
investigations.\383\ Quinn exploited these sentiments 
masterfully by fabricating claims regarding prosecutorial 
conduct in the Rich case.
---------------------------------------------------------------------------
    \383\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 341 
(Feb. 8, 2001) (statement of the Honorable Henry Waxman).
---------------------------------------------------------------------------
                c. RICO Charges Were Fairly Brought
    The pardon application also accuses the federal prosecutors 
of unfairly bringing a racketeering charge against Rich and 
Green. According to Quinn, RICO was misused because the 
underlying allegation involved tax fraud.\384\ The petition 
points to a Department of Justice policy that was adopted in 
1989, stating that, ``[f]ollowing the indictment, the United 
States government recognized the misuse of RICO in tax fraud 
cases and issued guidance in the United States Attorney's 
Manual explicitly stating that tax offenses are not predicates 
for RICO offenses.'' \385\ Jack Quinn suggested at the 
Committee's February 8, 2001, hearing that the decision to 
bring RICO charges against Marc Rich and Pincus Green was the 
key factor that led to their flight from the United States:
---------------------------------------------------------------------------
    \384\ Petition for Pardon for Marc Rich and Pincus Green, 
Memorandum in Support of Petitioners' Application for Pardon 22 (Dec. 
11, 2000) (Appendix III).
    \385\ Id.

        It's the position of my client that he remained outside 
        the United States because what Mr. Weinberg earlier 
        described to you as, in essence, a simple tax evasion 
        case was also made into a RICO case. And he may choose 
        to say it was only one count in the indictment, but it 
        was the sledgehammer that brought about the current 
        impasse.\386\
---------------------------------------------------------------------------
    \386\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 161 
(Feb. 8, 2001) (testimony of Jack Quinn).

    Quinn's argument is flawed for a number of reasons. First, 
at the time of the indictment, there was no policy against 
bringing RICO charges predicated on tax offenses. To the 
contrary, the RICO charges were brought consistent with Justice 
Department policy and the RICO charges were reviewed and 
approved by the RICO section of the Department of Justice--as 
were the tax charges by the tax section.\387\ As prosecutor 
Sandy Weinberg observed:
---------------------------------------------------------------------------
    \387\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 187 
(Feb. 8, 2001) (testimony of Morris ``Sandy'' Weinberg, Jr., former 
Assistant U.S. Attorney for the S.D.N.Y., Department of Justice).

        If you're away for 20 years and you're fortunate enough 
        to be able to persuade two foreign States not to 
        extradite you, the gloss of time is always going to 
        change the interpretation of the law. You can look at 
        indictments that were brought in 1980, and if you 
        examine them in 2000, the gloss of time is--you're 
        going to find that the courts interpret the laws 
---------------------------------------------------------------------------
        different in 2000 than they did in 1980.

        But you've got to look at the guts of what the case was 
        about and these people. And when you look at the guts 
        of what the case was about and the people, it doesn't 
        make any difference whether or not we would bring a 
        RICO charge today. It is whether or not we would bring 
        a criminal charge today and whether or not it is 
        acceptable to be pardoning folks who have done things 
        like renouncing their citizenship, becoming fugitives, 
        not coming back and making these arguments that they 
        say are so clear. I mean it--was it justified? And you 
        can't come in and say, well, 20 years have passed and, 
        you know, the courts now interpret or the Justice 
        Department interprets the RICO statute 
        differently.\388\
---------------------------------------------------------------------------
    \388\ Id. at 156.

Along similar lines, even former Clinton White House Counsel 
---------------------------------------------------------------------------
Abner Mikva has stated:

        Clearly, a defendant would rather negotiate the 
        unfairness of RICO charges from a comfortable abode in 
        Switzerland than from a hardback chair in the U.S. 
        attorney's office in Manhattan. This is especially true 
        when defendants have been trying, unsuccessfully, to 
        make the same ``unfair'' point about RICO for the last 
        30 years.\389\
---------------------------------------------------------------------------
    \389\ Coming in from the Cold, The Recorder, Mar. 28, 2001, at 5.

    Second, Quinn's argument also fails to address the non-tax 
RICO predicates in the case or the fact that there are money 
laundering statutes available today that were not available in 
---------------------------------------------------------------------------
1980. As prosecutor Martin Auerbach observed:

        I'm afraid that the argument with respect to the change 
        in RICO policy is as disingenuous as I find the 
        argument with respect to fugitivity. While it is true 
        that the Justice Department changed its view with 
        respect to tax counts as a predicate for RICO, it has 
        not changed its view with respect to mail and wire 
        fraud as a predicate to RICO. And as Mr. Quinn knows, 
        as the indictment reflects, there are both mail and 
        wire fraud counts which are predicates for RICO.

        So I believe that the Justice Department might well 
        approve this indictment today. And I, in fact, believe 
        that, were they to review this indictment today, and of 
        course they did review it before it was brought, there 
        would be money laundering charges in this case.\390\
---------------------------------------------------------------------------
    \390\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 156 
(Feb. 8, 2001) (testimony of Martin J. Auerbach, former Assistant U.S. 
Attorney for the S.D.N.Y., Department of Justice).

Therefore, it is likely that if he was charged today, Rich 
would be facing stiffer, not lighter penalties.
    Third, and most importantly, Quinn conveniently ignored the 
fact that the prosecutors tried to reach an accommodation with 
the two fugitives by offering to drop the RICO charges. As 
Robert Fink himself testified to the Committee, he was in 
discussions with prosecutors during which they offered to drop 
the RICO charges if Rich and Green would simply stand trial in 
the United States.\391\ These discussions are reflected in a 
February 10, 2000, e-mail from Robert Fink to Avner Azulay: 
``[a]t those times the office [Southern District of New York] 
offered to do a variety of things, none of which are 
necessarily still on the table. First, I was told at one point 
that they would drop the RICO charge if we wanted if Marc came 
in.'' \392\ Given the willingness of the SDNY to drop the RICO 
charges, Quinn's claim that the RICO charge was ``the 
sledgehammer that brought about the current impasse,'' is 
completely inaccurate and misleading.
---------------------------------------------------------------------------
    \391\ Id. at 469 (testimony of Robert Fink).
    \392\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00697 
(E-mail from Robert Fink to Avner Azulay, Director, Rich Foundation 
(Feb. 10, 2000)) (Exhibit 32).
---------------------------------------------------------------------------
    It appears that even Jack Quinn realized that the arguments 
in the petition were deeply flawed. On December 29, 2000, he 
sent the following e-mail to Kathleen Behan:

        What do you think our chances really are for Marc? the 
        hardest question, i think, is ``if you're right about 
        the weakness of the govts case, why not go to ct and 
        win?'' the answr, i guess is that we couldn't have 
        gotten a fair trial, but that was 18 years ago. 
        couldn't he get one now? isn't that the way this shd 
        go? these are tough questions, but I guess we have 
        decent answers.\393\
---------------------------------------------------------------------------
    \393\ Arnold & Porter Document Production KB00037 (E-mail from Jack 
Quinn to Kathleen Behan, Partner, Arnold & Porter (Dec. 29, 2000)) 
(Exhibit 67).

It is unclear what ``decent answers'' Quinn had to that 
argument or to any of the multiple arguments against the Rich 
pardon.

D. The ``Letters of Support'' in the Petition

    The legal arguments contained in the petition are not the 
only problematic section of the Rich and Green pardon petition. 
The ``letters of support'' in the petition also raise several 
troubling issues. Most of the letters were collected by Avner 
Azulay.\394\ Those letters were a crucial part of the pardon 
petition, as they helped create the impression that Marc Rich 
was a humanitarian who had made a minor mistake but who had a 
positive impact on countless lives. The significance and import 
of the letters presented to President Clinton was compromised 
by several factors, including: (1) many of those who wrote the 
letters in support of the pardon were either themselves, or 
their organizations, given money by Rich; (2) many who wrote 
the letters were misled about the purpose of the letter; and 
(3) their letters were misrepresented to the President. Given 
these facts, the letters of support in the Rich pardon petition 
represent just one more dishonest ploy in Marc Rich's overall 
scheme to obtain a pardon.
---------------------------------------------------------------------------
    \394\ Interview with Kathleen Behan, Partner, Arnold & Porter (Feb. 
27, 2001).
---------------------------------------------------------------------------
            1. Rich Paid a Number of Individuals Who Wrote in His 
                    Support
    The letter written by Abraham Foxman is one of the most 
prominently displayed letters in the petition. As National 
Director of the Anti-Defamation League (ADL), his support of 
clemency for Marc Rich was of obvious importance to the 
application. However, the ADL received $100,000 from Marc Rich 
shortly after Foxman became involved in the pardon effort.\395\ 
In fact, this money was received a few weeks after Foxman flew 
to Paris to meet with Rich aide Avner Azulay.\396\ Moreover, 
Rich has given the ADL a total of $250,000 since he fled the 
country in 1983.\397\ Foxman has publicly denied that Rich's 
contributions to the ADL had anything to do with his help in 
the pardon effort. He stated to a group of reporters, ``I 
really find offensive the idea that Abe Foxman was bought for a 
check for $100,000. If he gave me nothing--or he gave me $10 
million--I would have made the same decision, for which I now 
say I made a mistake.'' \398\
---------------------------------------------------------------------------
    \395\ Michael Isikoff, ``I Made a Mistake''; The ADL's Abe Foxman 
Admits the Jewish Organization Received a $100,000 Grant from Marc Rich 
but Maintains He Wasn't ``Bought,'' Newsweek, Mar. 23, 2001, at 2001 WL 
24138340.
    \396\ Id.
    \397\ Id.
    \398\ Id.
---------------------------------------------------------------------------
    Notwithstanding Foxman's denial of a quid pro quo, the 
payment to the ADL raises the general question of Marc Rich's 
tactics in drumming up support for his pardon application. The 
ADL was not the only organization to which Marc Rich paid money 
or attempted to pay money. In another instance, Marc Rich 
attempted to secure the assistance of the American Jewish 
Congress (AJC) with the promise of a large contribution. A week 
after Foxman's admission, Phil Baum, executive director of the 
AJC revealed that his organization had been approached by a 
representative of Marc Rich who told them, ``that if we were to 
speak favorably of Mr. Rich, we would be the beneficiary of a 
gift.'' \399\ Baum denied that there was any direct quid pro 
quo.\400\ However, Baum went on to state that, ``there was an 
understanding communicated to us[.]'' Baum further stated, ``It 
was not a contract. But these things are communicated in more 
subtle ways. We had reason to hope or expect that if we did 
this thing, we could probably be the recipient of Mr. Rich's 
generous recognition of our importance.'' \401\ The AJC 
ultimately turned down Rich's request.\402\ Committee staff 
attempted to contact Baum to corroborate this account and learn 
other details of the offer from the Rich team. Unfortunately, 
Baum failed to cooperate with the Committee's investigation, 
refusing on three separate occasions to return phone calls from 
Committee staff.
---------------------------------------------------------------------------
    \399\ Beth J. Harpaz, Jewish Group Says Rich Reps Sought Pardon 
Help for Money, Associated Press State and Local Wire, Mar. 28, 2001. 
See also Brian Blomquist, Rich Tried to Tempt Jewish Group, N.Y. Post, 
Mar. 29, 2001, at 14.
    \400\ Beth J. Harpaz, Jewish Group Says Rich Reps Sought Pardon 
Help for Money, Associated Press State and Local Wire, Mar. 28, 2001.
    \401\ Id.
    \402\ Id.
---------------------------------------------------------------------------
    Another example of Rich's efforts includes Birthright 
Israel, an organization that pays for young American Jews to 
travel to Israel. Marc Rich has pledged $5 million to 
Birthright Israel.\403\ The organization was founded by Michael 
Steinhardt, a longtime friend of Rich's who was heavily 
involved in the pardon effort. Steinhardt wrote a letter that 
was included in the petition. In addition, Birthright Israel's 
current North American Chairperson, Marlene Post, also wrote a 
letter supporting Rich's request for clemency.\404\ This letter 
was prominently displayed in the petition. As with the public 
statements of the ADL and the AJC, a spokesman for Birthright 
Israel denied any quid pro quo relating to the $5 million 
pledge to the organization and the organization's support for 
the Rich pardon.\405\
---------------------------------------------------------------------------
    \403\ Beth J. Harpaz, Jews Divided Over Rich Pardon, Associated 
Press, Mar. 29, 2001, at 2001 WL 17989287.
    \404\ Letter from Marlene E. Post, North American Chairperson, 
Birthright Israel, to President William J. Clinton (Dec. 7, 2000) 
(Exhibit 68). The original letter was part of Rich and Green's pardon 
petition.
    \405\ Brian Blomquist, Rich Tried to Tempt Jewish Group, N.Y. Post, 
Mar. 29, 2001, at 14.
---------------------------------------------------------------------------
    Yet another person with a connection to Birthright Israel 
also wrote a letter on behalf of Marc Rich. Rabbi Irving 
Greenberg, Chairman of the U.S. Holocaust Memorial Museum 
Council, wrote a letter on Holocaust Museum Council letterhead 
in favor of clemency for Rich. Rabbi Greenberg is also 
President of the Jewish Life Network, an organization that is a 
partner with Birthright Israel.\406\ However, when Committee 
staff asked Greenberg's lawyer about press accounts of Rich's 
contributions, he stated that Rich had never given any 
contributions to any organization or entity controlled or 
operated by Greenberg.\407\ Greenberg's letter and Rich's 
contributions to Birthright Israel caused seventeen former and 
current members of the Holocaust Museum Council to send a 
letter demanding Greenberg's resignation.\408\ Rabbi Greenberg 
apologized for his letter on behalf of Rich, and ultimately, 
the Council voted to keep him as Chairman.\409\
---------------------------------------------------------------------------
    \406\ Jacqueline Trescott, Holocaust Council Head Urged to Resign, 
Wash. Post, Apr. 5, 2001, at C9.
    \407\ Telephone Interview with Andrew Levander, Partner, Swidler 
Berlin Shereff Friedman (representing Rabbi Greenberg) (May 2, 2001).
    \408\ Jacqueline Trescott, Holocaust Council Head Urged to Resign, 
Wash. Post, Apr. 5, 2001, at C9. Kitty Dukakis also signed the letter.
    \409\ Id.
---------------------------------------------------------------------------
    There are other cases of Rich contributing or attempting to 
contribute to individuals (and their organizations) who wrote 
letters on his behalf. One prominent example is Jerusalem Mayor 
Ehud Olmert, who wrote a letter to President Clinton on 
November 27, 2000, that was included in the petition. According 
to The New York Times, Rich contributed $25,000 to Olmert's 
first mayoral campaign in 1993.\410\ The Committee has not been 
able to determine whether Rich made financial contributions to 
other foreign political officials who supported his pardon. 
However, the Marc Rich team was clearly concerned about 
inquiries along these lines. Shortly after the pardon was 
granted, Avner Azulay sent an e-mail to others on the Rich team 
stating that:
---------------------------------------------------------------------------
    \410\ William A. Orme, Jr., Marc Rich Aided Israeli Official, N.Y. 
Times, Feb. 22, 2001, at A21.

        Pse [sic] keep barak [sic] out of the media. We have 
        enough names on the list other than his. Important to 
        keep all politicians out of the story. Pse [sic] share 
        with me the inclusion of any one on the list. This is 
        election time here and has a potential of blowup. A 
        newsweek reporter here has already asked if there were 
        any political contributions.\411\
---------------------------------------------------------------------------
    \411\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00191 
(E-mail from Avner Azulay, Director, Rich Foundation, to Jack Quinn et 
al. (Jan. 22, 2001)) (Exhibit 69).

    Some of the other letter writers have also mentioned Rich's 
generosity and philanthropy as the reason for agreeing to write 
their letters. For example, several of the letter writers in 
Switzerland have ties to the Doron Foundation, an organization 
of Rich's that gives awards of $63,000 to Swiss groups and 
individuals.\412\ Zurich Mayor Josef Estermann was among that 
group.\413\ Estermann did not return calls from Committee 
staff. He has, however, spoken on the matter in his home 
country, saying, ``I think every person has a right to a 
pardon.'' \414\ To this, one Swiss paper responded, ``Yes, but 
does this right have to be one you can buy?'' \415\ Others with 
connections to the Doron Foundation who wrote letters on Rich's 
behalf include: Pierre de Weck, of UBS Bank; Michael de 
Picciotto, a director of Union Bancaire Privee in Geneva; Kurt 
R. Bollinger, of the Swiss Air Rescue Foundation; and Professor 
Verena Meyer of Zurich University. Michael de Picciotto spoke 
with Committee staff over the phone. When asked if Marc Rich or 
any of his associates had ever given anything of value to him 
or his company in exchange for his letter, de Picciotto 
responded, ``an important man like Mr. Rich does not need to do 
anything like this.'' \416\ The others with connections to the 
Doron Foundation failed to return Committee calls. Kurt 
Bollinger, whose rescue service received an award from Rich's 
foundation in 1992 failed to return the Committee's calls.\417\
---------------------------------------------------------------------------
    \412\ Elizabeth Olson, Pardon in U.S. for Marc Rich Creates Storm 
in Switzerland, N.Y. Times, Feb. 4, 2001, at 11. The Doron Foundation 
has now been folded into the Marc Rich Foundation.
    \413\ Id.
    \414\ Id.
    \415\ Id.
    \416\ Telephone Interview with Michael D. de Picciotto, Managing 
Director, Union Bancaire Privee, Geneva, Switzerland (Apr. 26, 2001).
    \417\ Elizabeth Olson, Pardon in U.S. for Marc Rich Creates Storm 
in Switzerland, N.Y. Times, Feb. 4, 2001, at 11.
---------------------------------------------------------------------------
    Committee staff contacted or attempted to contact almost 
all of those whose letters were included in the section of the 
pardon petition entitled, ``Letters Addressed to the Honorable 
President William J. Clinton Expressing Support for the Pardon 
of Mr. Marc Rich.'' While the Committee does not have 
sufficient evidence to conclude that all of the letters were 
written on a quid pro quo basis, it cannot completely rule out 
the possibility. This is largely because a number of the letter 
writers and intended letter writers failed to cooperate with 
the Committee by not returning phone calls. Nevertheless, there 
does appear to be a pattern of receiving contributions or 
pledges from Marc Rich among many of those who wrote letters. 
The fact that a number of the most prominent letters of support 
for the Rich pardon were tainted with allegations of linkage to 
large financial contributions diminishes Rich's claims to have 
been a great humanitarian. Rather, it appears that many of 
Rich's humanitarian activities were just one part of a lengthy 
strategy to escape criminal prosecution in the U.S.
            2. Some Who Wrote Letters Were Misled About the Purpose
    The significance and import of several of the letters is 
further weakened by the lack of candor of the Rich team in 
soliciting them. Rich's own lawyer, Robert Fink, admitted that 
during the solicitation of the letters, ``[n]ot everyone was 
necessarily told it was going to be for a pardon.'' \418\ 
Professor Verena Meyer, who serves on the board of the Doron 
Foundation, stated that she did not know that her letter would 
be included in a pardon petition.\419\ She thought the letters 
were ``routine'' and ``assume[d] other members of the 
foundation also wrote letters.'' \420\
---------------------------------------------------------------------------
    \418\ Alison Leigh Cowan, Some Used in Pardon Effort Were Unaware 
of Purpose, N.Y. Times, Jan. 26, 2001, at A15.
    \419\ Elizabeth Olson, Pardon in U.S. for Marc Rich Creates Storm 
in Switzerland, N.Y. Times, Feb. 4, 2001, at 11.
    \420\ Id.
---------------------------------------------------------------------------
    Several others who wrote letters on behalf of Rich felt 
even more deceived. Professor Jonathan Halevy, CEO of the 
Shaare Zedek Medical Center in Jerusalem, wrote a letter on 
November 30, 2000, acknowledging contributions from Marc Rich's 
Doron Foundation. Halevy was contacted by Avner Azulay and 
asked to write a letter acknowledging the contribution.\421\ 
According to Halevy, Azulay told him that the letter would be 
used in a ``book in honor of Mr. Rich and the foundation.'' 
\422\ When interviewed about his letter being used in Rich's 
pardon application, Halevy stated, ``I'm obliged, if I got a 
donation from someone, to confirm that I got it in writing. But 
I think it would be very fair to tell me this was the 
purpose.'' \423\ Anthony J. Cernera, President of Sacred Heart 
University, in Fairfield, Connecticut, was similarly misled 
about his letter. Cernera wrote Rich to ``express my deepest 
appreciation for your on-going support for our program of 
Christian-Jewish understanding.'' \424\ When the director of 
public relations for the University discovered that Cernera's 
letter was included in the pardon petition, he was astonished, 
responding, ``Wow. So these letters were used as part of the 
petition for his pardon?'' \425\
---------------------------------------------------------------------------
    \421\ Alison Leigh Cowan, Some Used in Pardon Effort Were Unaware 
of Purpose, N.Y. Times, Jan. 26, 2001, at A15.
    \422\ Id.
    \423\ Id.
    \424\ Letter from Anthony J. Cernera, President, Sacred Heart 
University, to Marc Rich (Nov. 27, 2000) (Exhibit 70).
    \425\ Alison Leigh Cowan, Some Used in Pardon Effort Were Unaware 
of Purpose, N.Y. Times, Jan. 26, 2001, at A15. In fact, when reached by 
The New York Times, only one of six letter writers were aware that 
their letters would be used as part of a pardon effort.
---------------------------------------------------------------------------
    The fact that Avner Azulay and others on the Marc Rich team 
misled individuals to obtain letters of support from them 
suggests a level of dishonesty that calls into question all 
representations made by the Rich pardon team. It also suggests 
that a number of people affiliated with Marc Rich, many of whom 
received his money, would not have written in his support if 
they had known that their letter was being used to get a 
pardon.
            3. Many of the Letters were Misrepresented to the President
    Finally, the letters included in the pardon petition are 
further compromised by the way in which they were presented to 
President Clinton. The second section of the petition 
containing these letters was divided into two parts, one 
entitled ``Letters Addressed to the Honorable President William 
J. Clinton Expressing Support for the Pardon of Mr. Marc 
Rich,'' and another entitled ``Letters Expressing Support for 
the Pardon of Marc Rich.'' Both of these titles are misleading.
    All of the twenty-one letters in the first part of this 
section were addressed to President Clinton. However, several 
of these letters made no mention of Marc Rich's request for a 
pardon or executive clemency. Among the letters that included 
no reference to the pardon issue were those written by Nobel 
Laureate Camilio Jose Cela, Chief Rabbi of France; Rene-Samuel 
Sirat, President of the Jewish Community of Madrid; Issac 
Querub Caro; and President of the Association of Spanish 
Business Enterprises Fernando Fernandez Tapias. These letters 
all refer to Rich's philanthropic contributions over the years. 
But none of them makes any reference to the pardon. It is 
therefore misleading for such letters to be included under the 
cover page indicating that all of the writers are expressing 
their support for a pardon.
    The cover page for the second part of this section of the 
petition is even more problematic. There are fifty-two letters 
included under the title ``Letters Expressing Support for the 
Pardon of Mr. Marc Rich.'' Not one of these letters makes any 
mention of the pardon effort. Almost all of these letters were 
addressed to Marc Rich or Avner Azulay, thanking them for the 
generosity of Marc Rich and his foundations. Furthermore, based 
on the fact that most of these letters were written in late 
November and early December of 2000, it is clear that they were 
solicited by the Rich team for use in the pardon. However, as 
discussed above, their use in the pardon application came as a 
surprise to many of the letter writers. It stands to reason, 
therefore, that most of the writers were not informed of the 
purpose of the letters, let alone that they would be sent to 
President Clinton in such a misleading format.
    There is also disturbing evidence that a more accurate 
title for these letters was considered, but not used, in the 
application. Among the materials produced for the Committee was 
an earlier draft of the same document, containing the same list 
of names, but with a different header reading ``List of Letters 
of Support for Marc Rich and Foundation.'' \426\ The existence 
of this more accurate title makes it much less likely that the 
use of the inaccurate and misleading title was a mere oversight 
by the Rich team. Lawyers billing many hundreds of dollars an 
hour certainly should not make such errors, and circumstantial 
evidence makes it appear that they were simply trying to 
mislead. Given the rejection of an accurate title, and the fact 
that it was replaced with an inaccurate title, there can be no 
other reasonable conclusion. Moreover, when the Committee 
confronted Jack Quinn about the misleading cover page that was 
included in the pardon petition, he stated:
---------------------------------------------------------------------------
    \426\ Compare Jack Quinn Document Production (Document entitled 
``List of Letters of Support for Marc Rich and Foundation'') (Exhibit 
71), with Petition for Pardon for Marc Rich and Pincus Green, Document 
entitled ``Letters Expressing Support for the Pardon of Mr. Marc Rich'' 
(Dec. 11, 2000) (Exhibit 72).

        I don't know who made that change. And I accept 
        responsibility for anything filed in my name. I will 
        tell you that, for the most part, I was not involved in 
        the effort to gather these letters. I became aware 
        after the petition had been filed that some of these 
        letters were simply sought as testimonials to his 
        charitable activities and that some of the people from 
        whom they were sought were not told in advance that 
        these letters were going to be used from a pardon 
        application. I very much regret that. And to the extent 
        that, as a result, any of that was misunderstood or was 
        misleading, I certainly apologize for it.\427\
---------------------------------------------------------------------------
    \427\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 172 
(Feb. 8, 2001) (testimony of Jack Quinn).

    The deceptive tactics used by the Rich team in securing and 
presenting so many of the letters sent to President Clinton in 
the pardon application are disturbing. The Committee is also 
troubled by the fact that the Clinton Administration failed to 
take the time to review these letters and the misleading way in 
which they were presented. However, in the context of the rush 
to grant last-minute pardons, and all of the unfortunate 
decisions made during the pardon process, the dishonest use of 
these letters is not surprising. The misleading presentation of 
the letters is consistent with the misleading legal arguments 
that form the basis of the Rich and Green pardon petition.

IV. LOBBYING FOR THE MARC RICH PARDON

A. The Marc Rich Lobbying Team

    Marc Rich employed much more than Jack Quinn and a 
deceptive petition to obtain his Presidential pardon. Just as 
important to the pardon effort was a carefully orchestrated 
lobbying campaign that used a number of individuals with unique 
access to the Clinton White House. Rich employed private 
attorneys with personal relationships with White House staff, 
personal friends of the President, and foreign leaders to press 
his case with the White House. The key players in the lobbying 
effort included Denise Rich, Beth Dozoretz, Israeli Prime 
Minister Ehud Barak, as well as other Israeli leaders, King 
Juan Carlos of Spain, Michael Steinhardt, Peter Kadzik, and a 
number of other individuals, all working for the same goal, the 
pardon of Marc Rich and Pincus Green.
            1. Denise Rich
    Denise Rich was in many ways the key figure in the effort 
to obtain a pardon for Marc Rich. She enjoyed a close 
relationship with President Clinton, which gave the Rich team 
the access they needed to make their case directly to the 
President. She used this access as much as she could, sending 
two letters to the President, and making her case to him 
personally on at least three occasions. Denise Rich's 
involvement in the pardon effort has raised three serious 
questions: (1) why did Denise Rich agree to help Marc Rich; (2) 
what were the nature of her communications with President 
Clinton; and (3) did she in any way connect the pardon of Marc 
Rich to contributions she had made or would make to the DNC or 
Clinton Library? The Committee has not been able to find 
definitive answers to these critical questions, largely because 
Denise Rich has invoked her Fifth Amendment rights against 
self-incrimination rather than cooperate with the Committee. To 
attempt to understand Denise Rich's role in helping to obtain 
Marc Rich's pardon, the Committee has considered documents 
about the pardon effort, testimony provided by other 
individuals, and even Denise Rich's self-serving media 
appearances.
                a. Denise Rich's Relationship with Marc Rich
    Denise Rich was wealthy before she married Marc Rich. She 
was the daughter of Emil Eisenberg, who founded Desco 
Incorporated, one of the largest shoe manufacturers in the 
United States. In 1966, at the age of 22, Denise married Marc 
Rich, whom she had met six months earlier. Denise Rich was 
married to Marc Rich for the next 25 years, having three 
children. In 1983, when Marc Rich was indicted and fled the 
country, Denise and her children left the United States with 
Marc Rich. Despite the fact that she accompanied her husband 
into exile, and remained with him there for the next eight 
years, Denise Rich claims to have been ignorant of the reasons 
for Rich's indictment and flight:

        Question. In 1980, were you aware that your husband was 
        reportedly trading with Iran after we had an embargo 
        because of the hostages?

        Denise Rich. I really didn't know much about that at 
        all because I was so involved in my life. It's not like 
        he would come home and he would say, ``Hey, I'm trading 
        with the enemy.'' We didn't talk about it.

                                *  *  *


        Question. How did you find out [about the indictment] 
        and what was your reaction?

        Denise Rich. All I really knew was that he spoke to me 
        and he said that ``I'm having tax problems with the 
        government. And--and I think that we are going to have 
        to leave.'' And my response was, ``I am his wife. These 
        are my children. I'm not going to split up the 
        family.'' And, so, I did what I think any wife would 
        do. I left the country.

        Question. Did you understand that by fleeing to 
        Switzerland and refusing to return to this country, 
        that your husband was considered one of the 10 most 
        wanted fugitives in America?

        Denise Rich. That had nothing to do with me because I 
        was . . .

        Question. Yes. It's your husband, Denise. It's the 
        father of your children.

        Denise Rich. Yes, he's the father of my children . . .

        Question. He's a fugitive.

        Denise Rich. . . . and he was my husband, but as far as 
        I knew, it was a tax situation. So I really never 
        understood anything else. And I really didn't--that's 
        all that I knew.\428\
---------------------------------------------------------------------------
    \428\ 20/20 (ABC television broadcast, Apr. 27, 2001).

    While living in exile, Denise began her musical career, 
becoming a successful songwriter. In approximately 1990, Denise 
discovered that Marc Rich had taken up with a younger woman, 
model Gisela Rossi. In 1991, Denise divorced Marc Rich. In the 
ensuing legal battle, she received a substantial sum of money, 
which has never been disclosed by Marc Rich, Denise Rich, or 
their representatives, but is believed to be in the vicinity of 
$500 million.\429\ As a result of the divorce, Denise and Marc 
Rich were reportedly on very poor terms, rarely speaking.
---------------------------------------------------------------------------
    \429\ Some estimates list the amount as high as $900 million. See 
Debunking the Buzz Over Denise, N.Y. Post, Feb. 1, 2001, at 10.
---------------------------------------------------------------------------
    In 1996, however, the Richs' daughter Gabrielle died of AML 
leukemia. Denise Rich has often pointed to Gabrielle's death as 
an important factor in her change of heart regarding her ex-
husband. First, she has claimed that Marc Rich was ``cruelly 
denied the opportunity'' \430\ to return to the U.S. to visit 
her. She has also claimed that the death of Gabrielle caused 
her to forgive her ex-husband for his transgressions:
---------------------------------------------------------------------------
    \430\ Jack Quinn Document Production (Letter from Denise Rich to 
President William J. Clinton (Dec. 6, 2000)) (Exhibit 73).

        Question. Here is what a lot of people don't 
        understand. How do you go from almost hating your 
        husband at the time of the divorce to writing a letter 
        pleading for his clemency and his pardon? What changed 
---------------------------------------------------------------------------
        in your mind?

        Denise Rich. My daughter died. And when you've lost a 
        child, there's nothing more you can say. There are no 
        more questions. When you've lost a child, everything 
        changes, and I felt--I felt in my heart 
        forgiveness.\431\
---------------------------------------------------------------------------
    \431\ 20/20 (ABC television broadcast, Apr. 27, 2001).

This explanation, however, fails to address one fundamental 
issue: should Marc Rich have decided to spend time with his 
daughter, he could easily have done so. Rather, he placed his 
legal jeopardy ahead of his concerns for his family and elected 
to refrain from visiting her. Years later, it appears that he 
and his ex-wife would cynically use the death of his daughter 
to gain sympathy for his earlier transgressions.
                b. Denise Rich's Relationship with President
                    Clinton
    After her divorce from Marc Rich, Denise Rich returned to 
New York, where she purchased what is reportedly the largest 
penthouse on Fifth Avenue, a 28-room triplex filled with works 
of art by Picasso, Miro, Dali, Calder, Warhol, and Chagall, as 
well as a staff of 20 to serve her needs, including two cooks, 
a stylist, and a ``personal healer.'' \432\ Shortly after 
arriving in New York, Denise Rich sought to establish herself 
as a leading figure in New York social circles. Geraldo Rivera, 
a close friend of Denise Rich, observed that ``[t]he people who 
think she wants to be a kind of Pamela Harriman person are not 
off the mark. . . . She wanted a salon, she wanted a Gertrude 
Stein, Paris kind of scene, she wanted to watch the parade of 
contemporary popular cultural life march through her living 
room.'' \433\
---------------------------------------------------------------------------
    \432\ Lloyd Grove, The Reliable Source, Wash. Post, Apr. 27, 2001, 
at C3.
    \433\ Elisabeth Bumiller, Tossed Into a Tempest Over a Pardon; 
Friends See Naivete, Critics a Payoff in a Clinton Fund-Raiser's Acts, 
N.Y. Times, Feb. 2, 2001, at B1.
---------------------------------------------------------------------------
    An important part of becoming a ``kind of Pamela Harriman'' 
was to get involved in political fundraising. Denise Rich began 
making large political contributions and holding lavish 
fundraisers shortly after her return to the United States. 
Denise Rich and her daughters gave over $1.1 million to federal 
political causes between 1993 and 2000, all but $5,000 of that 
to Democrats. Denise Rich's political contributions increased 
as the end of the Clinton Administration neared, with over 
$625,000 of her contributions coming between 1998 and 2000.
    While she was giving and raising vast amounts of money for 
the Democratic Party, Denise Rich developed a close 
relationship with President Clinton:

        When I met him there was so much charisma, and I saw a 
        lot of idealism, and eventually I had a very special 
        relationship with the former President and the former 
        First Lady because they were so compassionate to me 
        when I lost my daughter. And it--and it was as if he 
        understood and . . . could put himself in my 
        shoes.\434\
---------------------------------------------------------------------------
    \434\ 20/20 (ABC television broadcast, Apr. 27, 2001).

This special personal relationship was also manifested in 
Denise Rich's political fundraising, where she became one of 
the Democratic Party's largest and most reliable fundraisers. 
In fact, Denise Rich held the fundraiser that was President 
Clinton's first public appearance after the publication of the 
Independent Counsel's referral in 1998. It raised nearly $3 
million.\435\
---------------------------------------------------------------------------
    \435\ Elisabeth Bumiller, Tossed Into a Tempest Over a Pardon; 
Friends See Naivete, Critics a Payoff in a Clinton Fund-Raiser's Acts, 
N.Y. Times, Feb. 2, 2001, at B1.
---------------------------------------------------------------------------
    Denise Rich's special relationship with President Clinton 
was also manifested in her large contributions to the William 
J. Clinton Presidential Foundation, the charitable foundation 
responsible for building the Clinton Library. Between 1998 and 
2000, Denise Rich gave $450,000 to the Clinton Library.\436\ 
Among these contributions was a $250,000 gift in July 1998, 
which was one of the earliest large contributions to the 
Library, made during one of the darkest times in the Clinton 
presidency.\437\ Because she and her friend Beth Dozoretz have 
used the Fifth Amendment to avoid answering the Committee's 
questions, little is known about Denise Rich's motivations for 
contributing to the Clinton Library. However, one document 
suggests that Denise Rich was seeking ``help'' from Dozoretz. 
On a note accompanying her $100,000 library contribution, 
Denise Rich wrote, ``Dear Beth, Thanks for your help, Lots of 
love, Denise.'' \438\ However, since both Rich and Dozoretz 
have refused to testify on grounds that their testimony would 
incriminate them, the Committee has not been able to develop an 
understanding of this note.
---------------------------------------------------------------------------
    \436\ See William J. Clinton Presidential Foundation Document 
Production WJCPF 0002 (Check from Denise Rich to the Clinton Library 
for $250,000 (July 15, 1998)); William J. Clinton Presidential 
Foundation Document Production WJCPF 0008 (Check from Denise Rich to 
the Clinton Library for $100,000 (Aug. 7, 1999)); William J. Clinton 
Presidential Foundation Document Production WJCPF 0031 (Check from 
Denise Rich to the Clinton Library for $100,000 (May 11, 2000)) 
(Exhibit 74).
    \437\ Id.
    \438\ William J. Clinton Presidential Foundation Document 
Production WJCPF 0037 (Note from Denise Rich to Beth Dozoretz, former 
finance chair, Democratic National Committee) (Exhibit 75).
---------------------------------------------------------------------------
    As Denise Rich helped President Clinton with his charity, 
he helped Denise Rich with hers. In 1998 and 2000, President 
Clinton attended fundraising galas for the G&P Charitable 
Foundation, which Denise Rich established to raise funds for 
cancer research.
                c. Denise Rich's Role in the Marc Rich Pardon
                    Effort
    Little is known about when Denise Rich decided to assist 
the Marc Rich pardon effort, or who asked her to help.\439\ 
Avner Azulay has stated that he personally convinced her to 
write in support of the pardon, telling her that ``everyone in 
the world is supporting this and you can't just stand aside, 
it's embarrassing.'' \440\ The first documentary evidence of 
her support for the effort to resolve Marc Rich's criminal case 
appears in the March 2000 e-mail discussing sending her on a 
``personal mission'' to President Clinton.\441\ The first 
specific references to her role in the late 2000 pardon effort 
come in November 2000, in a meeting agenda prepared by attorney 
Robert Fink. The agenda for that meeting, which included Jack 
Quinn, includes an item ``Maximizing use of D.R. and her 
friends.'' \442\ It appears that the first conversation between 
Denise Rich and the pardon team took place on December 4, 2000, 
when she spoke to Robert Fink.\443\
---------------------------------------------------------------------------
    \439\ There are reports that Denise Rich may have also assisted the 
effort to obtain a pardon for ex-boyfriend Niels Lauersen, a prominent 
New York gynecologist who was convicted of fraudulent billing 
practices. According to one account, though, Rich was approached to 
help with Lauersen's pardon effort, and was willing to help, until she 
was ``reminded that she might be spreading herself thin.'' See James 
Barron with Alison Cowan and Shaila Dewan, A Second Pardon Front, N.Y. 
Times, May 15, 2001, at B2.
    \440\ Rich's Israeli Aide: The Pardon Surprised Us. So Did the 
Furor, Forward, (Feb. 23, 2001), at 1.
    \441\ There is some circumstantial evidence of reconciliation 
between Denise Rich and Marc Rich somewhat earlier, at least in 
November 1999, when Denise Rich and her daughter Danielle traveled to 
Israel to attend the dedication of the Gabrielle Rich wing of the Tel 
Aviv Museum of Art, which was funded by Marc Rich. A photograph of that 
event shows Denise and Danielle Rich posing with one of Marc Rich's 
closest aides, Avner Azulay.
    \442\ Arnold & Porter Document Production A0567-69 (Agenda of Nov. 
21, 2000, Meeting) (Exhibit 76).
    \443\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00021 
(Billing Records for Marc Rich, Dec. 19, 2000) (Exhibit 77).
---------------------------------------------------------------------------
    The Rich legal team did maximize use of Denise Rich. They 
started with a December 6, 2000, letter from Denise Rich to the 
President. This letter was in many ways, the centerpiece of the 
pardon petition. While it appears to have been a heartfelt 
plea, in reality, it was drafted by Marc Rich's lawyers. The 
letter combines inaccurate charges about the indictment with 
emotional pleas about Rich's ``exile:''

        I support his application with all my heart. The pain 
        and suffering caused by that unjust indictment battered 
        more than my husband--it struck his daughters and me. 
        We have lived with it for so many years. We live with 
        it now. There is no reason why it should have gone on 
        so long. Exile for seventeen years is enough. So much 
        of what has been said about Marc as a result of the 
        indictment and exile is just plain wrong, yet it has 
        continued to damage Marc and his family.

                                *  *  *


        My husband and I could not return to the United Sates 
        [sic] because, while the charges were untrue, no one 
        would listen--all the prosecutors appeared to think 
        about was the prospect of imprisoning Marc for the rest 
        of his life. With a life sentence at stake, and press 
        and media fueled by the U.S. Attorney, we felt he had 
        no choice but to remain out of the country.

        Let no one think exile for life is a light burden. The 
        world we cared about was cut off from us. When our 
        daughter was dying from leukemia, Marc was cruelly 
        denied the opportunity to see her by the prosecutors.

        What was this exile for? The charges all relate to old 
        energy regulations, where all of the other people and 
        companies involved in the same kinds of transactions 
        were never charged with a crime. Only my husband was 
        treated differently.\444\
---------------------------------------------------------------------------
    \444\ Jack Quinn Document Production (Letter from Denise Rich to 
President William J. Clinton (Dec. 6, 2000)) (Exhibit 73).

This letter was placed prominently at the front of the stack of 
testimonials in the Marc Rich pardon petition, and it was 
quoted extensively in the petition itself. Of course, the 
arguments in the letter were completely inaccurate.
    After including the letter in the pardon petition, Denise 
Rich took a number of other actions to lobby for the pardon. 
Another letter from her to President Clinton was prepared by 
Marc Rich's lawyers on December 20, 2000. This letter was 
discussed among the Marc Rich legal team, with Robert Fink 
suggesting the following text: ``Because I could not bear it 
were I to learn that you did not see my letter and at least 
understand my special person[al] reasons for being a supporter 
of a pardon, I am sending you an additional copy, and an 
additional request that you wisely use your power to pardon 
Marc.'' \445\ Jack Quinn thought that this language was 
``perfect,'' \446\ and suggested that Denise Rich should ``hand 
it to him [the President] in [a] sealed envelope and mention 
that she is aware I intend to discuss the matter with him 
personally. She shd simply ask him to read it later and let him 
know how strongly we feel that we have the merits on our 
side.'' \447\ After Marc Rich's lawyers had finalized the text 
of the letter, it was presented to Denise Rich for her 
signature. Denise Rich did see the President on December 20, 
2000, at a White House Christmas party. According to one 
witness at the party, Rich wrested the President away from 
Barbra Streisand to press her case about the pardon.\448\
---------------------------------------------------------------------------
    \445\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00068 
(E-mail from Robert Fink to Kathleen Behan, Partner, Arnold & Porter et 
al. (Dec. 19, 2000)) (Exhibit 78).
    \446\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00069 
(E-mail from Jack Quinn to Robert Fink et al. (Dec. 19, 2000)) (Exhibit 
79).
    \447\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00397 
(E-mail from Jack Quinn to Robert Fink et al. (Dec. 19, 2000)) (Exhibit 
80).
    \448\ Alison Leigh Cowan, Documents Show a Complex Campaign to Win 
a Pardon, N.Y. Times, Feb. 10, 2001, at A11.
---------------------------------------------------------------------------
    Little is known about how many other contacts Denise Rich 
might have had with President Clinton during the final month of 
the Clinton Administration. There is evidence that she had at 
least one, and maybe more, telephone calls with the President 
about the pardon. E-mails between Jack Quinn and Robert Fink on 
January 16, 2001, indicate that they wanted Denise Rich to make 
``another call,'' indicating there had been other calls before 
this one. First, Quinn wrote that:

        I am advised that it would be useful if she [Denise] 
        made another call to P. I am in a fannie mae bd mtg, 
        but would like to set this in motion asap. Message shd 
        be simple: ``I'm not calling to argue the merits. Jack 
        has done that, and we believe a pardon is defensible 
        and justified. I'm calling to impress upon you that MR 
        and our whole family has paid a dear price over 18 yrs 
        for a prosecution that shd never have been brought and 
        that singled out MR while letting the oil companies he 
        dealt with go scot free. Please know how important this 
        is to me personally.'' can you or avner call her this 
        morning? \449\
---------------------------------------------------------------------------
    \449\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00167 
(E-mail from Jack Quinn to Robert Fink et al. (Jan. 16, 2000)) (Exhibit 
81).

---------------------------------------------------------------------------
Fink responded:

        I called at 10:30 AM and she is still asleep (she was 
        at her Dad's yesterday and it was a very full day) but 
        I left a message that I had to talk to her before a 
        noon meeting. I expect I will hear from her and I will 
        give her the message.\450\
---------------------------------------------------------------------------
    \450\ Id.

    In the absence of cooperation from Denise Rich, however, it 
is impossible to know exactly how many contacts Rich had with 
President Clinton, and what those contacts were about. An e-
mail from Jack Quinn to Robert Fink's assistant shortly after 
the pardon raises interesting questions. This document was 
withheld from the Committee for over a year, and was produced 
only after a decision from a federal district court judge 
requiring it to be turned over to a grand jury. Quinn wrote the 
following in response to an e-mail titled ``One of the 
---------------------------------------------------------------------------
Reporters' Requests:''

        Shd def confirm it didn't. Is this the moment to say 
        that he asked DR for pol support? Or might DR have said 
        something stupid like that when they spoke. God knows, 
        I hope not.\451\
---------------------------------------------------------------------------
    \451\ Jack Quinn Document Production JQ 02958 (E-mail from Jack 
Quinn to Rosemary Micciulli, Quinn Gillespie & Associates (Jan. 24, 
2001)) (Exhibit 82).

The Committee requested an interview with Jack Quinn after it 
received this e-mail, but he refused. Without further 
illumination from Quinn, this e-mail's meaning is not clear. 
One interpretation suggests that a reporter may have called 
asking whether the President asked Denise Rich for ``political 
support,'' perhaps in the context of their discussions about 
the Rich pardon. It also suggests that Quinn was fearful that 
Denise Rich might have said something like this to the press. 
Quinn's question ``is this the moment to say that he asked DR 
for pol support,'' raises a real question as to whether 
President Clinton asked Denise Rich for ``political support'' 
in the midst of their discussions about the Rich pardon. While 
Quinn has refused to answer questions from the Committee about 
this e-mail, his spokesman has informed the press that the 
``he'' in the e-mail refers to former New York Mayor Rudy 
Giuliani, not President Clinton.\452\ While Quinn's explanation 
is possible, it is troubling that Quinn has refused to provide 
this explanation to the Committee himself. Absent further 
information from Quinn, Denise Rich, or President Clinton, the 
Committee can only speculate as to the meaning of this e-mail.
---------------------------------------------------------------------------
    \452\ Michael Isikoff, Secret E-Mail, Newsweek (Mar. 10, 2002).
---------------------------------------------------------------------------
    It is clear that Denise Rich had frequent opportunities to 
press the pardon case with President Clinton. Rich was 
scheduled to visit the White House 19 times during the Clinton 
presidency, with six of those visits scheduled between May 2000 
and January 2001.\453\ In addition, Rich also called the White 
House on several occasions near the end of the Clinton 
Administration.\454\ However, without cooperation from Denise 
Rich or President Clinton, the Committee is unable to know what 
was discussed during those telephone calls or how many of those 
scheduled White House visits actually occurred.
---------------------------------------------------------------------------
    \453\ National Archives and Records Administration Document 
Production (WAVES records (1994-2000)).
    \454\ See, e.g., Verizon Document Production (Telephone calls from 
Denise Rich to the White House (Dec. 9, 1999)); Qwest Document 
Production (Telephone call from Denise Rich to the White House (Feb. 
16, 2000)).
---------------------------------------------------------------------------
                d. Denise Rich's Motives
    Denise Rich's involvement in the Marc Rich pardon effort 
raises a number of serious questions: (1) why did Denise Rich 
agree to help Marc Rich; (2) did Denise Rich's extremely large 
political contributions play any role in the President's 
decision to grant the pardon of Marc Rich; (3) were additional 
large contributions envisioned or hoped for; (4) what did the 
President and Denise Rich discuss; and (5) was Denise Rich 
making her political contributions with her own money? Due to 
Denise Rich's decision to invoke her Fifth Amendment rights 
against self-incrimination, the Committee is not able to answer 
any of these questions definitively. However, there are a 
number of factors suggesting that Denise Rich's involvement in 
the Marc Rich pardon case is far more complicated than she has 
suggested.
    First, Denise Rich's explanation for why she helped Marc 
Rich obtain the pardon does not withstand full scrutiny. Denise 
Rich has stated that she helped him because, after her daughter 
died, she forgave Marc Rich for his transgressions. She also 
claimed that she helped get the pardon so that her daughters 
could be with their father again. However, the Committee is 
unaware of Rich returning to the United States since he has 
obtained the pardon. Moreover, during Marc Rich's self-imposed 
``exile,'' his daughters were free to visit him in Europe and 
Israel, as they often did. Since Denise Rich's explanations do 
not fully explain her involvement, it is fair to consider other 
possible motivations. One comes from the fact that Rich 
promised to give $1 million a year to the G&P Charitable 
Foundation, at the precise time that he was trying to get 
Denise Rich to help with the pardon effort.\455\ This sum would 
have represented a major influx of cash for the G&P Foundation, 
which raised $2.4 million in 1998 and only $978,000 in 
1999.\456\ Second, the Committee has attempted to examine 
whether Denise Rich and her daughters continue to receive 
financial support from Marc Rich, or would receive enhanced 
financial support in the future, other factors which could have 
influenced their decision to support his pardon. While Denise 
Rich's bank records do not indicate any influx of money from 
Marc Rich, at least one document received by the Committee 
suggests that Rich might have established a Swiss bank account 
for his daughter Ilona. In a December 4, 2000, letter from 
Robert Fink to Ilona Rich, Fink wrote ``here are some banking 
papers to set up the account with UBS for you that need your 
signature. Please execute where indicated and also return these 
to me so I can send them back to Switzerland.'' \457\ While 
this reference is certainly capable of multiple 
interpretations, it at least raises the possibility that Marc 
Rich was providing untraceable funds to his family through 
Swiss bank accounts. This could provide another explanation for 
their support for the pardon.
---------------------------------------------------------------------------
    \455\ Alison Leigh Cowan, Rich Pardon Reportedly Followed Pledge to 
Charity of Former Wife, N.Y. Times, May 1, 2001, at A1. $500,000 of 
this sum would have been given by Marc Rich and the other $500,000 
would have been given by Pincus Green.
    \456\ See Department of the Treasury Form 990-PF, G&P Charitable 
Foundation, 1998; Department of Treasury Form 990-PF, G&P Charitable 
Foundation, 1999 (Exhibit 83). A copy of G&P's tax return for the year 
2000 was unavailable because the Foundation may have received a filing 
deadline extension.
    \457\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00259 
(Letter from Robert Fink to Ilona Rich (Dec. 4, 2000)) (Exhibit 84).
---------------------------------------------------------------------------
    Similarly, the Committee is unable to reach any firm 
conclusions regarding the nature of Denise Rich's 
communications with the President, and specifically whether 
Denise Rich's political contributions and contributions to the 
Clinton Library played any role in the pardon. Absent true 
cooperation from Denise Rich or President Clinton, there is no 
way of knowing what they discussed, or what they were thinking 
about the Marc Rich pardon. However, there are a number of 
pieces of circumstantial evidence that raise the indelible 
appearance of impropriety in this case, which Denise Rich and 
President Clinton have done nothing to refute. First, Denise 
Rich made $1.1 million in political contributions to Democrats, 
including the Clintons, and the contributions increased 
dramatically toward the end of the Clinton Administration. 
Denise Rich also made $450,000 in contributions to the Clinton 
Library, including one of the earliest large contributions to 
the Library. Although this sum has been downplayed, it was in 
fact an appreciable percentage of cash actually advanced to the 
Library. Given the difficulties generally experienced raising 
money after a President leaves office, the individuals who are 
prepared to give large sums--particularly after there are no 
more elections to finance--assume a particular importance. 
Second, Denise Rich used the relationship she had with the 
President, which was built in large part of political 
contributions, to lobby the President to grant the pardon. 
Third, Denise Rich and Beth Dozoretz, the two people who were 
privy to the reasons for Denise Rich's political contributions 
and her discussions with the President regarding the pardon, 
were so concerned about their potential criminal exposure that 
they invoked their Fifth Amendment rights. Were there a benign 
explanation to the events prior to the pardon, there is little 
conceivable reason to have invoked the Fifth Amendment. Fourth, 
the President, Denise Rich, and Beth Dozoretz have offered the 
weakest of justifications for their actions in the Marc Rich 
pardon matter. Given these facts, there is an unmistakable 
appearance of impropriety.
    The Committee had the opportunity to grant Denise Rich 
immunity against prosecution so that it could receive compelled 
testimony from her, but decided not to proceed with a grant of 
immunity for several reasons. First, there was no evidence that 
Denise Rich intended to cooperate with the Committee. After the 
Committee received notice that the Justice Department had no 
objection to a grant of immunity, Committee staff contacted 
counsel for Mrs. Rich, to determine whether they would offer 
the Committee a proffer before the immunity vote. By receiving 
a proffer, the Committee hoped to receive an understanding of 
what Mrs. Rich would testify to if she received immunity. 
Counsel for Mrs. Rich were unwilling to provide a proffer. By 
refusing to provide a proffer, counsel for Mrs. Rich made it 
clear that they had no intent of cooperating with the 
Committee's investigation, and would make obtaining information 
from Denise Rich as difficult as possible.
    Another factor that played a role in the Committee's 
decision not to grant immunity to Denise Rich were Mrs. Rich's 
own public statements about her role in the investigation. When 
Mrs. Rich appeared on the television program 20/20, to the 
extent she made any statements addressing her role in the 
pardon, her statements were difficult to believe. This 
appearance raised real questions as to whether Denise Rich 
intended to provide honest and complete testimony to the 
Committee, even if she were immunized.
            2. Beth Dozoretz
    Together with Denise Rich and Jack Quinn, Beth Dozoretz 
served a key role in lobbying for the pardon of Marc Rich. Like 
Denise Rich, Dozoretz enjoyed a close personal relationship 
with President Clinton that was a mixture of friendship and 
extremely significant political fundraising. Like Denise Rich, 
Dozoretz took advantage of this close relationship to press 
President Clinton about the Rich pardon. Also, much like her 
friend Denise Rich, Beth Dozoretz has invoked her Fifth 
Amendment rights rather than testify before the Committee.
                a. Beth Dozoretz's Relationship with Bill
                    Clinton
    In 1992, Beth Dozoretz attended the Democratic Convention 
in New York City at the urging of her husband, Ron Dozoretz. 
Until that point, Dozoretz had never been significantly 
involved in political events of any type. But at the Democratic 
convention, Dozoretz had an epiphany of sorts, as Hillary 
Clinton passed by:

        On her way to the podium she had to walk by where I was 
        sitting. . . . She was looking around, smiling, and I 
        flattered myself to think that our eyes met. And I 
        blurted something out like, ``I just think you're 
        fabulous!'' And I felt like she looked at me and said, 
        ``Thank you!'' with her big, beautiful smile.\458\
---------------------------------------------------------------------------
    \458\ Lloyd Grove, The A-List's No. 1 Political Partiers; How Beth 
and Ron Dozoretz Made Washington Their Very Own, Wash. Post, Apr. 1, 
1999, at C1.

Beginning with the 1992 convention, Beth Dozoretz began to be 
deeply involved in Democratic politics. She and her husband 
moved to Washington from Norfolk, Virginia, in 1993. First at 
an apartment in Georgetown and then at an estate in Northwest 
Washington, the Dozoretzes began to host high-profile 
fundraising events. Through these events, the Dozoretzes had 
frequent contact with the Clintons, and struck up a warm 
relationship with both the President and First Lady. During the 
course of the Clinton presidency, the Dozoretzes were close to 
the Clintons, vacationing with them, and playing golf with 
them.\459\ Like Denise Rich, Beth Dozoretz remained close to 
the President throughout the Monica Lewinsky scandal. In 
November 1998, the Dozoretzes asked the President to serve as 
godfather to their infant daughter.\460\
---------------------------------------------------------------------------
    \459\ Id. The Dozoretzes had their critics, some of whom suggested 
that their friendship with the Clintons was the result of a deliberate 
plan:
---------------------------------------------------------------------------
        GStarting from the very beginning, they were having 
      dinners and soirees at their apartment in Washington 
      Harbour. . . . The whole program was geared to rising to 
      the top. She had a staff from the very first day. I mean, 
      how many housewives have staffs? She played golf with the 
      president, and she took golf lessons so she could play with 
      him. Her husband obviously is very, very wealthy, and this 
      is something they set out to accomplish. And obviously they 
      have.
Id.
---------------------------------------------------------------------------
    \460\ Id. President Clinton agreed, and he and Hillary Clinton 
attended a high-profile christening at the Dozoretz estate. The star-
studded attendance list for the event also included Jack Quinn. Annie 
Groer and Ann Gerhart, The Reliable Source, Wash. Post, Nov. 12, 1998, 
at C3.
---------------------------------------------------------------------------
    In addition to the close personal relationship she 
maintained with President Clinton, Beth Dozoretz also developed 
a fundraising relationship with the President. In 1994, 
Dozoretz served as co-Chairman of the DNC's large contributor 
program. By 1999, Dozoretz had raised $5 million for various 
Democratic causes.\461\ As a result, in early 1999 Dozoretz was 
appointed, with the President's personal blessing, as Finance 
Chairman of the DNC, the chief fundraiser for the Democratic 
Party. Dozoretz resigned her post in September 1999, to allow 
new DNC Chairman Ed Rendell to appoint his own Finance 
Chairman. However, even after she left her position as Finance 
Chairman, Dozoretz continued to raise funds for the Democratic 
Party, and maintain a warm relationship with President Clinton.
---------------------------------------------------------------------------
    \461\ It was through her fundraising work for the DNC that Beth 
Dozoretz became enmeshed in her first White House scandal. In September 
1997, Dozoretz testified before the Senate Committee on Governmental 
Affairs regarding a controversial White House fundraising coffee 
attended by John Huang and Pauline Kanchanalak. Two witnesses at the 
coffee testified that Huang made an illegal appeal for political 
contributions at the White House coffee. Dozoretz, who was also 
attending the coffee with a prospective donor, denied that Huang made 
the remarks. See ``Investigation into Fundraising Activities During the 
1996 Elections,'' Hearings Before the Senate Governmental Affairs 
Special Investigations Comm., 105th Cong. (Sept. 16, 1997).
---------------------------------------------------------------------------
    In addition to raising funds for the DNC, Beth Dozoretz 
raised money for President Clinton's personal causes. For 
example, she raised money for the President's legal defense 
fund. She also raised money for the Clinton Library. Dozoretz 
solicited Denise Rich for her first contribution to the Clinton 
Library, a $250,000 contribution made in July 1998.\462\ 
Apparently, Rich gave the check to Dozoretz, who sent it on to 
the lawyers for the Library.\463\ In connection with this, or 
one of Denise Rich's other contributions to the Clinton 
Library, Rich drafted a note to Dozoretz reading ``Dear Beth, 
Thanks for your help, Lots of love, Denise.'' \464\ Apparently, 
Denise Rich was a person specifically targeted by Dozoretz to 
solicit for the Clinton Library. Dozoretz gave Peter O'Keefe, 
the chief fundraiser for the Clinton Library, a list of 
individuals Dozoretz intended to solicit, and Denise Rich was 
listed on this document.\465\ In addition to the substantial 
sums she raised from Denise Rich, on May 23, 2000, Beth 
Dozoretz pledged to raise $1 million for the Clinton 
Library.\466\
---------------------------------------------------------------------------
    \462\ William J. Clinton Presidential Foundation Document 
Production WJCPF 0002 (Check from Denise Rich to the William J. Clinton 
Presidential Foundation Library for $250,000 (July 15, 1998)) (Exhibit 
74).
    \463\ William J. Clinton Presidential Foundation Document 
Production WJCPF 0004 (Letter from Janine Werkman, Chief of Staff for 
Beth Dozoretz, to Nicole Seligman (July 17, 1998)) (Exhibit 85).
    \464\ William J. Clinton Presidential Foundation Document 
Production WJCPF 0037 (Note from Denise Rich to Beth Dozoretz, former 
finance chair, Democratic National Committee) (Exhibit 75).
    \465\ William J. Clinton Presidential Foundation Document 
Production WJCPF 0048 (List of Potential Contributors to William J. 
Clinton Presidential Foundation) (Exhibit 86); Interview with Peter 
O'Keefe, Fundraiser, William J. Clinton Presidential Foundation (Apr. 
12, 2001).
    \466\ This information was provided to the Committee in a briefing 
by David Kendall and Nicole Seligman, counsel for the Clinton 
Foundation. See also William J. Clinton Presidential Foundation 
Document Production WJCPF 0024 (Letter from Skip Rutherford, President, 
William J. Clinton Presidential Foundation, to Beth Dozoretz, former 
finance chair, Democratic National Committee (Jan. 4, 2000)) (Exhibit 
87).
---------------------------------------------------------------------------
                b. Beth Dozoretz's Involvement in the Marc Rich
                    Pardon Campaign
    Around Thanksgiving of 2000, Jack Quinn informed Beth 
Dozoretz that he would be filing a pardon petition on behalf of 
Marc Rich. Quinn was close friends with Dozoretz, and also knew 
that she was close to Denise Rich. Quinn testified that he 
``encouraged her to help me be sure that the President himself 
was aware of the fact that the application had been filed with 
the White House Counsel's office.'' \467\ According to Quinn, 
Dozoretz did talk to the President, who told her that Quinn 
should make his case to Bruce Lindsey and the other staff in 
the White House Counsel's office.\468\ Quinn described his 
motivation for involving Dozoretz at the Committee's March 1 
hearing:
---------------------------------------------------------------------------
    \467\ ``President Clinton's Eleventh Hour Pardons,'' Hearing Before 
the Senate Judiciary Comm., 107th Cong. 69 (Feb. 14, 2001) (testimony 
of Jack Quinn).
    \468\ Id.

        I did so because she was a friend of mine, because she 
        had a relationship with Denise Rich, she was in much 
        more frequent communication with the President than I 
        was. I was motivated by two things principally; one, I 
        was hopeful that she could let the President know that 
        I had or was going to file this so that he would be 
        aware it was there; and two, she was another person who 
        I hoped might be in a position to give me the kind of 
        information that I have, as a lawyer, thought would be 
        useful to me to pursue their efforts on behalf of my 
        client vigorously. Now, I want to also tell you have 
        [sic] that in that conversation I had with her again 
        around Thanksgiving time, I cautioned her that it would 
        be very important to make sure that no such 
        conversation was ever connected in any way with any 
        kind of fundraising activity. She reacted to that by 
        kind of looking at me like how could I even suggest 
        that. She said to me, of course I would never do that 
        to him.\469\
---------------------------------------------------------------------------
    \469\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 410-11 
(Mar. 1, 2001) (testimony of Jack Quinn).

It is apparent that Quinn turned to Dozoretz because of her 
access to and influence with the President. Precisely how 
Dozoretz used these skills is a mystery, because of Dozoretz's 
invocation of her Fifth Amendment rights.\470\
---------------------------------------------------------------------------
    \470\ Irving Sandorf, a former colleague of Dozoretz's from the 
clothing industry, noted that ``She has a way of getting into you a 
little bit. She knows how to manipulate people. I don't know if you'd 
call them `people skills.' It's more like `I'll use you, you use me' 
skills.'' See Lloyd Grove, The A-List's No. 1 Political Partiers; How 
Beth and Ron Dozoretz Made Washington Their Very Own, Wash. Post, Apr. 
1, 1999, at C1.
---------------------------------------------------------------------------
    Over the course of the next two months, Beth Dozoretz and 
Jack Quinn were in frequent contact about the Marc Rich pardon 
effort.\471\ Jack Quinn estimated that they spoke between five 
and ten times about the Marc Rich pardon effort. The real 
question is, of course, how many times Beth Dozoretz spoke to 
the President about the Marc Rich pardon, and what they spoke 
about. Because of the Fifth Amendment claims of Dozoretz and 
Denise Rich, the Committee knows little about these 
communications. However, the e-mail discussions of the Marc 
Rich legal team offer some insight into the matter. On January 
10, 2001, Avner Azulay e-mailed Jack Quinn with the following 
message:
---------------------------------------------------------------------------
    \471\ Beth Dozoretz left telephone messages for Jack Quinn on: 
December 8, 2000; January 2, 2001, with the question, ``[A]ny news on 
the matter?''; January 8, 2001; an undated message between January 8 
and January 18, 2001; January 18, 2001; and January 19, 2001, leaving 
her contact information for the rest of that day. Jack Quinn Document 
Production (Telephone Messages from Beth Dozoretz, former finance 
chair, Democratic National Committee, to Jack Quinn) (Exhibit 88).

        2. D[enise] R[ich] called from aspen. Her friend B--who 
        is with her--got a call today from potus--who said he 
        was impressed by J[ack] Q[uinn]'s last letter and that 
        he wants to do it and is doing all possible to turn 
        around the WH counsels. D[enise] R[ich] thinks he 
        sounded very positive but ``that we have to keep 
        praying.'' There shall be no decision this wknd and the 
        other candidate Milik [sic] is not getting it.\472\
---------------------------------------------------------------------------
    \472\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00162 
(E-mail from Avner Azulay, Director, Rich Foundation, to Jack Quinn et 
al. (Jan. 10, 2001)) (Exhibit 89).

When questioned about this e-mail, Quinn confirmed that the 
``B'' referred to by Azulay was indeed Beth Dozoretz.\473\ 
However, Quinn could do little to explain the message, 
including why the President would by trying to convince the 
staff of the need for the pardon, rather than vice-versa. 
Robert Fink responded to this message with an e-mail stating, 
``I said it before, and I say it again, `nice letter.' Keep on 
praying, and, oh, a few phone calls won't hurt.'' \474\
---------------------------------------------------------------------------
    \473\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 246-48 
(Feb. 8, 2001) (testimony of Jack Quinn).
    \474\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00162 
(E-mail from Robert Fink to Jack Quinn (Jan. 10, 2001)) (Exhibit 89).
---------------------------------------------------------------------------
    Dozoretz remained deeply involved in the Marc Rich pardon 
effort through the granting of the pardon. Three e-mail 
messages to Jack Quinn make it appear that Dozoretz was 
urgently trying to reach Quinn on January 17, 2001. At 12:13 
p.m., Quinn's assistant informed him that ``Beth Dozoretz wants 
you to call her on her cell if you get a chance.'' \475\ At 
1:38 p.m., Quinn's assistant told him that ``Beth is very eager 
to talk to you. She called again and knows that you are at the 
WH.'' \476\ A mere 24 minutes later, Quinn's assistant sent 
Quinn an e-mail regarding ``BETH'' stating ``[v]ery sorry to 
bother you with this but she is insistent. Please call her--she 
says that it is URGENT.'' \477\ On January 19, 2001, Dozoretz 
traveled to Beverly Hills, California, with her husband.\478\ 
That day, she called Jack Quinn to let him know her contact 
information, both in her private jet, and at the Peninsula 
Hotel, where she would be staying.\479\ At 10:48 p.m., Quinn 
called Dozoretz at the Peninsula Hotel.\480\ Presumably, Quinn 
informed Dozoretz that he believed Marc Rich was going to 
receive a pardon. Shortly after that call, Dozoretz called the 
White House and spoke to President Clinton.\481\ According to 
one press report, Dozoretz thanked President Clinton, but he 
was so busy that he did not initially understand why Dozoretz 
was thanking him.\482\
---------------------------------------------------------------------------
    \475\ Jack Quinn Document Production JQ 03027 (E-mail from April 
Moore, Secretary to Jack Quinn, Quinn Gillespie & Associates, to Jack 
Quinn (Jan. 17, 2001)) (Exhibit 90).
    \476\ Jack Quinn Document Production JQ 03028 (E-mail from April 
Moore, Secretary to Jack Quinn, Quinn Gillespie & Associates, to Jack 
Quinn (Jan. 17, 2001)) (Exhibit 91).
    \477\ Jack Quinn Document Production JQ 03029 (E-mail from April 
Moore, Secretary to Jack Quinn, Quinn Gillespie & Associates, to Jack 
Quinn (Jan. 17, 2001)) (Exhibit 92).
    \478\ WAVES records from the White House indicate that both 
Dozoretz and Denise Rich visited the White House on January 19, 2001. 
However, it appears that these records are spurious. White House WAVES 
records usually show a scheduled time of entry for any scheduled visit 
to the White House. However, only if a visitor actually shows up at the 
White House is an actual time of entry entered into the WAVES system. 
In this case, the WAVES records show actual times of entry for Rich and 
Dozoretz. The United States Secret Service, has explained, however, 
that a large group of individuals were scheduled to visit the White 
House at one time for a party. Rather than hold up the group of 
individuals who were actually there, the Secret Service waved through 
the entire group. Therefore, the WAVES system shows erroneously that 
everyone who was scheduled for that event actually showed up. Hotel 
records as well as several eyewitnesses confirm the fact that Dozoretz 
was in transit and in California on January 19. The fact that the 
United States Secret Service had no idea of who was actually admitted 
to the White House is obviously troubling.
    \479\ Jack Quinn Document Production (Telephone Message from Beth 
Dozoretz, former finance chair, Democratic National Committee, to Jack 
Quinn (Jan. 19, 2001)) (Exhibit 88).
    \480\ Jack Quinn Document Production (Quinn Gillespie telephone 
bill, Feb. 9, 2001) (Exhibit 93).
    \481\ Peninsula Hotel Document Production (Dozoretz Invoice from 
Peninsula Hotel, Jan. 21, 2001) (Exhibit 94).
    \482\ Corky Siemaszko, Dem Aide Had Early Word of Pardons, N.Y. 
Daily News, Feb. 26, 2001, at 6.
---------------------------------------------------------------------------
    After the pardon was granted, Dozoretz continued her 
contacts with Jack Quinn. Between January 23, 2001, and 
February 5, 2001, Dozoretz called Quinn at least nine times, 
leaving messages of support such as (1) ``NY Times was great 
today!'' \483\ (2) ``You are getting a reputation as the 
smartest lawyer in America;'' \484\ (3) ``Hearing lots of good 
things about you especially hearing that you are brilliant;'' 
\485\ and (4) ``Just had important conversation she would like 
to share with you.'' \486\
---------------------------------------------------------------------------
    \483\ Jack Quinn Document Production (Telephone Message from Beth 
Dozoretz, former finance chair, Democratic National Committee, to Jack 
Quinn (Jan. 25, 2001)) (Exhibit 95).
    \484\ Jack Quinn Document Production (Telephone Message from Beth 
Dozoretz, former finance chair, Democratic National Committee, to Jack 
Quinn (Jan. 29, 2001)) (Exhibit 96).
    \485\ Jack Quinn Document Production (Telephone Message from Beth 
Dozoretz, former finance chair, Democratic National Committee, to Jack 
Quinn (Jan. 31, 2001)) (Exhibit 97).
    \486\ Jack Quinn Document Production (Telephone Message from Beth 
Dozoretz, former finance chair, Democratic National Committee, to Jack 
Quinn (Feb. 1, 2001)) (Exhibit 98).
---------------------------------------------------------------------------
    Beth Dozoretz's efforts to help get Marc Rich's pardon cast 
yet additional doubt on the motives of President Clinton. Like 
Denise Rich, Beth Dozoretz was a close personal friend of 
President Clinton. Also like Denise Rich, and a number of the 
President's other close friends, her friendship was closely 
intertwined with her fundraising relationship for the President 
and Democratic Party.
    Dozoretz's involvement in the Marc Rich pardon effort has 
the indelible appearance of impropriety. Whether or not 
criminal acts were involved is unknown, and can only be 
discovered with facts not available to the Committee--namely 
the truthful testimony of Denise Rich and Beth Dozoretz. 
However, the appearance of impropriety is substantial:

 Beth Dozoretz was herself a major fundraiser for the 
DNC as well as President Clinton's personal causes, including 
his legal defense fund and library. In addition, she was the 
primary solicitor for Denise Rich's contributions to the 
Clinton Library. Therefore, at a minimum, Beth Dozoretz's 
endorsement of a pardon carried particular weight with the 
President.

 The one communication between Dozoretz and President 
Clinton of which the Committee is aware raises serious 
questions. According to the e-mail describing the call, 
President Clinton told Dozoretz that he was ``doing all 
possible to turn around the WH counsels.'' This upside-down 
construction suggests that the President had made up his mind 
to grant the pardon, but was hoping to convince the staff so as 
to improve appearances.

 No acceptable explanation has been made to the 
Committee of why Beth Dozoretz agreed to become involved in the 
pardon effort. Obviously, Dozoretz is friendly with both Denise 
Rich and Jack Quinn. It is possible that she agreed to help 
Rich and Quinn as part of this friendship.\487\ However, given 
the substantial effort that Dozoretz made, and the excitement 
that she showed at the President's decision to grant the 
pardon, the possibility that Dozoretz had some other motivation 
should be considered.
---------------------------------------------------------------------------
    \487\ Of course, there are questions regarding why Denise Rich and 
Jack Quinn were making such great efforts to obtain the pardon. As 
described above, Rich has never adequately explained her motivations, 
leading to speculation that her motivation may have been financial, not 
personal. Jack Quinn's explanations have been even more suspect, as he 
has maintained that he was not expecting any payment for his work on 
the Marc Rich pardon effort. As described above, this suggestion is 
contradicted by common sense, as well as by Marc Rich's primary U.S. 
lawyer, Robert Fink. Fink confirms that Quinn's motivation was likely 
financial, as he was going to receive handsome financial compensation 
for his efforts. Because Quinn and Rich have offered weak reasons for 
their involvement in the Rich pardon effort, the motivations of 
individuals with even less at stake, like Beth Dozoretz, must be 
subjected to even greater scrutiny.

 Rather than cooperate with the Committee's 
investigators, Dozoretz invoked her Fifth Amendment right 
---------------------------------------------------------------------------
against self-incrimination.

    However, absent cooperation from Ms. Dozoretz, the 
Committee is unable to answer these questions.
                c. Jack Quinn's Attempt to Keep Information
                    About Dozoretz from the Committee
    It should be noted that Jack Quinn apparently tried to keep 
the Committee from learning the true nature of Beth Dozoretz's 
role in the pardon effort. When Quinn was asked about the 
January 10, 2001, e-mail at the Committee's February 8, 2001, 
hearing, the Committee did not have any information regarding 
the role of Dozoretz in the pardon effort. When he was asked 
about the e-mail, Quinn did acknowledge that it referred to 
Beth Dozoretz, but he was then quite reticent about explaining 
Dozoretz's role:

        Mr. Barr. Why would the President be sharing this 
        information with the finance chair of the DNC? What do 
        they have to do with it?

        Mr. Quinn. I was on the receiving end of this e-mail, 
        and I don't know the answer to that. I was aware of 
        this e-mail.

        Mr. Barr. Work with me, speculate a little bit, why 
        would the DNC finance chair be involved here?

        Mr. Quinn. Well, I believe--my impression was that 
        Denise and Beth were--have been friends, and that, in 
        fact, they grew--

        Mr. Barr. I suspect so.

        Mr. Quinn. That they grew up in the same town in 
        Massachusetts up north.

                                *  *  *


        Mr. Quinn. But let me be clear, I don't know that he 
        [the President] called her about this.

                                *  *  *


        Mr. Barr. Clearly it was about this.

        Mr. Quinn. I believe that--my impression was that in 
        the course of the conversation they were having she 
        asked him what is happening with these two pardon 
        applications, and apparently was with Denise Rich at 
        the time, which may have motivated her to ask the 
        President in the course of the conversation, but I was 
        not of the impression, I want to be careful to say this 
        accurately, that the call was placed for the purpose of 
        discussing the pardons.\488\
---------------------------------------------------------------------------
    \488\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 248 
(Feb. 8, 2001) (statement of the Honorable Bob Barr and testimony of 
Jack Quinn).

    Quinn's initial testimony on this point was misleading. 
When Representative Barr asked why the President would be 
calling Beth Dozoretz about the Rich pardon, Quinn answered ``I 
don't know the answer to that.'' When Representative Barr asked 
Quinn to speculate about why Dozoretz was involved in this 
matter, the best Quinn could offer was that Denise Rich and 
Beth Dozoretz were friends, and had grown up in the same town 
in Massachusetts. Quinn neglected to mention the more salient 
point that he had personally asked Dozoretz to become involved 
in the pardon effort. Therefore, he knew specifically why she 
was discussing the Rich pardon with the President. However, at 
no time during the Committee's February 8 hearing did Quinn 
disclose the fact that he had specifically asked Dozoretz to 
become involved in the pardon effort, because of her close 
relationship with President Clinton. If the House Government 
Reform Committee and Senate Judiciary Committee had not held 
follow-up hearings on this matter, it is likely that Quinn 
never would have told the truth about Dozoretz's involvement. 
The fact that Quinn tried to conceal this information only adds 
to the appearance that Dozoretz's role in the pardon was 
improper.
            3. Israeli Prime Minister Ehud Barak and Other Israeli 
                    Leaders
    Key players in the lineup of individuals assisting the Marc 
Rich pardon effort were Israeli Prime Minister Ehud Barak and a 
number of other current and former Israeli officials who 
weighed in with the Clinton Administration. President Clinton 
has made much of the influence of Prime Minister Barak's appeal 
in his decision making. This claim can be debated. However, it 
cannot be debated that the Marc Rich team made a substantial 
effort to get these Israeli officials involved. However, much 
like some of the key American players, it is difficult to gauge 
whether these officials were involved because they believed in 
the Rich pardon, or because they received financial support 
from Marc Rich.
    After he fled the United States in 1983, Marc Rich began to 
make large financial contributions to various charities in 
Israel, as well as Jewish charities in Europe and the United 
States. Marc Rich also made political contributions to Israeli 
political candidates. However, since Israeli law does not 
require the public disclosure of these contributions, the 
Committee is not able to determine to whom Rich has 
contributed. Communications among the Marc Rich legal team make 
it clear that they were able to call upon a number of prominent 
Israelis to weigh in on Rich's behalf with President Clinton.
    Marc Rich's pardon petition included a number of letters of 
support from prominent Israelis, including: Shlomo Ben-Ami, the 
Minister of Foreign Affairs and Minister of Public Security; 
Itamar Rabinovich, the former Israeli Ambassador to the United 
States; Yaakov Neeman, the former Minister of Finance and 
former Minister of Justice; Ehud Olmert, the Mayor of 
Jerusalem; Isaac Herzog, the Israeli Government Secretary; and 
Shabtai Shavit, the former Director of the Mossad.\489\ A 
number of these officials received some sort of financial 
contributions from Marc Rich. Olmert received a $25,000 
political contribution from Rich in 1993.\490\ A community 
development organization called Yedid, which was linked to 
Shlomo Ben-Ami, received $100,000 from Rich.\491\ Herzog's wife 
worked for the Rich Foundation.\492\
---------------------------------------------------------------------------
    \489\ See Petition for Pardon for Marc Rich and Pincus Green (Dec. 
11, 2000) (Appendix III).
    \490\ Michael Dobbs, Pardon Smoothed Ties to Israel; Barak, Others 
Aided Rich's Campaign, Wash. Post, Feb. 25, 2001, at A1.
    \491\ Id.
    \492\ Id.
---------------------------------------------------------------------------
    More important than the letters of support, though, were 
telephone calls to President Clinton from some of these Israeli 
leaders. Most importantly, Marc Rich's supporters were able to 
have Prime Minister Ehud Barak raise the Marc Rich pardon with 
President Clinton. Prime Minister Barak described the approach 
to him by Avner Azulay as follows:

        Few months ago [sic] I was approached by the chairman 
        of the Rich Foundation in Israel. The chairman, Mr. 
        Azoulay is a man I know [sic] for many years, who had 
        contributed a lot to the security of the State of 
        Israel. The Rich Foundation is well known and highly 
        appreciated in Israel for its philanthropic activities 
        in the fields of healthcare, education and culture.

        Mr. Azoulay asked me to raise Mr. Rich case with 
        President Clinton. I raised the subject with President 
        Clinton several times (probably three) in the course of 
        routine telephone conversations during the last two or 
        three months of his presidency and made a personal 
        recommendation to him to consider the case.\493\
---------------------------------------------------------------------------
    \493\ Letter from Ehud Barak, Prime Minister, Israel, to the 
Honorable Dan Burton, Chairman, Comm. on Govt. Reform (May 13, 2001) 
(Exhibit 99).

    Avner Azulay's efforts to enlist Israeli officials in the 
pardon effort were helped dramatically when, in early January 
2001, Marc Rich himself flew to Israel to attend a convention 
for Birthright Israel, a recipient of Rich's largesse. While 
Rich was in Israel, he took the opportunity to meet senior 
Israeli political officials as well as Jewish-American leaders. 
During this trip to Israel, Rich met personally with Prime 
Minister Barak, and shortly after that meeting, Barak raised 
the Rich pardon with President Clinton a second time. Azulay 
referred to Rich's scheduled meetings in a January 4, 2001, e-
---------------------------------------------------------------------------
mail to the Rich legal team:

        As I have already mentioned--during this wknd [sic] 
        M[arc] R[ich] is scheduled to meet the P[rime] 
        M[inister], F[oreign] M[inister] & SH[imon] P[eres]--as 
        well as a main vector to E[lie] W[iesel].

        If possible it would be very useful to ask the W[hite] 
        H[ouse] to hold the final decision (unless it is 
        positive!)--until the above have the opportunity to 
        make/repeat their personal appeals.\494\
---------------------------------------------------------------------------
    \494\ Arnold & Porter Document Production A0865 (E-mail from Avner 
Azulay, Director, Rich Foundation, to Jack Quinn et al. (Jan. 4, 2001)) 
(Exhibit 100).

    It also appears that the Rich team attempted to have other 
Israeli officials call the President or his staff. Former 
Israeli Prime Minister Shimon Peres called President Clinton 
about the Marc Rich matter on December 11, 2000,\495\ the day 
that the Rich petition was filed, and the same day that Prime 
Minister Barak spoke to the President. On December 19, 2000, 
Avner Azulay suggested that he ask Knesset Speaker Avraham Burg 
to call the President on Marc Rich's behalf.\496\ It is unclear 
whether Burg actually spoke with President Clinton. Burg 
apparently did write a letter to President Clinton on January 
9, 2001, advocating Rich's pardon.\497\
---------------------------------------------------------------------------
    \495\ Arnold & Porter Document Production A0842 (E-mail from Avner 
Azulay, Director, Rich Foundation, to Jack Quinn et al. (Dec. 25, 
2000)) (Exhibit 101).
    \496\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00071 
(E-mail from Avner Azulay, Director, Rich Foundation, to Kathleen 
Behan, Partner, Arnold & Porter et al. (Dec. 19, 2000)) (Exhibit 102).
    \497\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 
00163-64 (E-mail from Avner Azulay, Director, Rich Foundation, to Jack 
Quinn et al. (Jan. 11, 2001)) (Exhibit 103). While Burg's letter did 
expressly advocate Rich's pardon, it was criticized by Gershon Kekst 
and Bob Fink. Kekst asked Quinn and Fink ``is this a helpful letter?'' 
Id. Fink responded, ``I think Potus will realize that it is intended to 
be helpful. Frankly, I am a little surprised Avner let it go in this 
form, as we pulled one like it from the original petition. Maybe he did 
not see it until after it had gone. I see no reason to rain on anyone's 
parade.'' Id.
---------------------------------------------------------------------------
    Azulay also asked Israel Singer, Secretary General of the 
World Jewish Congress, and Edgar Bronfman, President of the 
World Jewish Congress, to raise the Marc Rich matter with the 
President:

        Israel Singer & Edgar Bronfman (CEO & President of the 
        World Jewish Congress) are scheduled to meet potus on 
        Sunday evening in NY (the Israel Policy Forum--not 
        adequate for a private talk) and on Wednesday for a 
        private seance at the WH. In anticipation of Abraham 
        Burg's meeting, I contacted Singer through Rabbi 
        Rizkin. Burg will give his support only if he knows 
        that Singer and Bronfman will . . [sic] I don't know 
        but suspect that this has to do with JPoll.

        Now Singer wants to be sure that the MRPG petition is 
        on the agenda of potus. I suggest you contact Israel 
        Singer the soonest possible--either to brief him and 
        answer his questions or arrange for a mtg with him 
        before he meets potus.\498\
---------------------------------------------------------------------------
    \498\ Arnold & Porter Document Production A0866 (E-mail from Avner 
Azulay, Director, Rich Foundation, to Jack Quinn et al. (Jan. 5, 2001)) 
(Exhibit 104).

    In his desperation to find prominent Israeli supporters for 
the Marc Rich petition, Jack Quinn even suggested that the 
deceased widow of assassinated Israeli Prime Minister Yitzhak 
Rabin, Leah, call President Clinton. Robert Fink made this 
request to Avner Azulay in an e-mail: ``Oh one more thing. Jack 
asks if you could get Leah Rabin to call the President; Jack 
said he was a real big supporter of her husband.'' \499\ Azulay 
responded the following day: ``Bob, having Leah Rabin call is 
not a bad idea. The problem is how do we contact her? She died 
last November--on the 5th anniversary of her husband's 
murder.'' \500\ In the end, the Rich team settled for the 
Rabins' daughter, who met with Avner Azulay on January 10, 
2001, and informed him that she would call President Clinton on 
Rich's behalf.\501\
---------------------------------------------------------------------------
    \499\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00091 
(E-mail from Robert Fink to Avner Azulay, Director, Rich Foundation 
(Dec. 30, 2000)) (Exhibit 36).
    \500\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00094 
(E-mail from Avner Azulay, Director, Rich Foundation, to Robert Fink 
(Dec. 31, 2000)) (Exhibit 105).
    \501\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00162 
(E-mail from Avner Azulay, Director, Rich Foundation, to Jack Quinn et 
al. (Jan. 10, 2001)) (Exhibit 89).
---------------------------------------------------------------------------
    One of the tactics used by Azulay to enlist Israeli leaders 
was to link the Rich pardon to the Jonathan Pollard matter. The 
Pollard pardon had long been a priority for a number of Israeli 
officials, and Azulay attempted to use the Pollard matter to 
Rich's advantage:

        I can also cfm [sic] the info on J[onathan] P[ollard]. 
        It seems that the topic was discussed in telecons with 
        potus--within the framework of the peace agreement. 
        JP's freedom is considered as a public-political 
        ``sweet pill'' which shall help swallow (or divert 
        public attention from) the more sour pills in the 
        agreement with arafat [sic]. I am sure potus is aware 
        that JP is going to be big trouble with the entire 
        intelligence community and MR could go along with it 
        ``less unnoticed''. On the other hand if he says no to 
        JP--one more reason to say yes to MR.\502\
---------------------------------------------------------------------------
    \502\ Arnold & Porter Document Production A0865 (E-mail from Avner 
Azulay, Director, Rich Foundation, to Jack Quinn et al. (Jan. 4, 2001)) 
(Exhibit 100).

Jack Quinn made the same linkage between Rich and Pollard in 
his appeals to the White House: ``Lastly, I told her [Beth 
Nolan] that, if they pardon JP, then pardoning MR is easy, but 
that, if they do not pardon JP, then they should pardon MR. In 
the last connection, she affirmed that they have heard from 
people in or connected to the GOI [Government of Israel].'' 
\503\
---------------------------------------------------------------------------
    \503\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00111 
(E-mail from Jack Quinn to Avner Azulay, Director, Rich Foundation et 
al. (Jan. 3, 2001)) (Exhibit 106).
---------------------------------------------------------------------------
    It is difficult to gauge whether the efforts of the Marc 
Rich team to link their fate to that of Jonathan Pollard helped 
their cause. Jonathan Pollard certainly feels that the Rich 
pardon was granted at his expense. Pollard made the following 
statement after the Rich pardon:

        I've become disillusioned. This is the hardest thing 
        for me. . . . But what has shaken me to my very bones 
        is to finally realize, after 16 years, that I made a 
        mistake. For 16 years I have been desperately waving 
        the Israeli flag, crying out for help to the Israeli 
        political establishment. But since the Marc Rich 
        campaign, I realize that I made a mistake. All those 
        years I should have waved something else to get their 
        attention. I should have waved a dollar bill in front 
        of them and convinced them that I had a lot of money. 
        That is the depths to which we have sunk as a nation, 
        that an agent has to bribe his own government to rescue 
        him. That is how low we have sunk.

        Esther and I are pinching pennies in order to stay 
        alive. Israel has never assisted us. But this Marc Rich 
        fellow, with all of his millions, he's the one that 
        everyone in Israel is breaking their backs for.

                                *  *  *


        Barak, the politicians, and all those who were 
        involved, were corrupted and debased by Marc Rich's 
        money. Every one of them was corrupted at some level or 
        another. The corruption and the repulsiveness that 
        characterized the Rich pardon campaign is 
        appalling.\504\
---------------------------------------------------------------------------
    \504\ Eran Tiffenbraun and Mody Kreitman, Expose: Using Pollard to 
Get Rich, Yediot Achronot, Feb. 25, 2001 (Exhibit 107).

While Pollard clearly did not deserve a pardon of his own, his 
comments about the Rich pardon may be accurate.
            4. Elie Wiesel
    The Rich team also attempted to recruit prominent Holocaust 
survivor and author Elie Wiesel to their cause. As a prominent 
spokesman for Jewish causes and a close friend to President 
Clinton, Wiesel was a logical candidate for the Rich team to 
turn to. It appears that Gershon Kekst initially identified 
Wiesel as a potential supporter of the Rich pardon. After a 
meeting with Kekst, Avner Azulay informed Behan, Fink, and Marc 
Rich that Kekst ``proposed Elie Wiesel as the ``moral 
authority'' to present the plea. We discussed some ideas how to 
reach him--and that I shall do in the next few days.'' \505\
---------------------------------------------------------------------------
    \505\ Arnold & Porter Document Production A0542 (E-mail from Avner 
Azulay, Director, Rich Foundation, to Kathleen Behan, Partner, Arnold & 
Porter et al. (Nov. 15, 2000)) (Exhibit 108). When asked about this 
document, Kekst said, ``I would not have proposed Elie Wiesel as a 
moral authority to anyone on any subject.'' Interview with Gershon 
Kekst, President, Kekst and Co. (Mar. 15, 2001). Kekst said that he was 
asked, but refused, to request Wiesel's help. As discussed below, Kekst 
has repeatedly denied that he made suggestions and recommendations even 
when they are corroborated by contemporaneous e-mails. Kekst's denials 
are not credible, and appear to be part of an effort to understate his 
role in the Marc Rich pardon effort.
---------------------------------------------------------------------------
    It appears that Azulay followed Kekst's recommendation, and 
attempted to enlist Wiesel. In an e-mail of November 29, 2000, 
Azulay suggested that the Rich team might be obtaining a letter 
of support from Wiesel: ``We shall have a few days to get 
additional letters in New York (Elie Wiesel, Abe Foxman and 
others). I assume by now you are getting letters from 
Switzerland and Spain.'' \506\ When he was interviewed over the 
telephone by Committee staff, Wiesel confirmed that he was 
asked by Avner Azulay to write a letter on behalf of Rich. At a 
November or December 2000 meeting at Wiesel's home in New York 
City, Azulay showed Wiesel other letters written on behalf of 
Marc Rich.\507\ According to Wiesel, although he told Azulay 
that he was impressed by the list of names, he said he could 
not write such a letter for someone he did not know.\508\ 
Wiesel told Committee staff that he also told Azulay that he 
did not believe Rich could legally receive a pardon without 
standing trial.\509\ According to Wiesel, even though Azulay 
assured him that Rich could receive a pardon, Wiesel told 
Azulay that he could not write the letter because he had 
already written a letter requesting a commutation of Jonathan 
Pollard's sentence. Wiesel felt that he could not make another 
request.\510\
---------------------------------------------------------------------------
    \506\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00066 
(E-mail from Avner Azulay, Director, Rich Foundation, to Robert Fink 
and Marc Rich (Nov. 29, 2000)) (Exhibit 109).
    \507\ Telephone Interview with Elie Wiesel (Apr. 2, 2001). Yossi 
Ciecanover, a banker and former high official in Israel, and Danny 
Karavan, who lived in both Paris and Israel, arranged this meeting. 
Wiesel indicated that he was under the impression that Gershon Kekst 
asked Yossi Ciecanover to contact Wiesel on behalf of Azulay.
    \508\ Id.
    \509\ Id.
    \510\ Id.
---------------------------------------------------------------------------
    According to Wiesel, Avner Azulay called him several days 
later to see if he had changed his mind.\511\ Wiesel told him 
that he had not.\512\ While this seemingly would have been the 
end of Wiesel's involvement in the Rich pardon campaign, there 
is evidence that it was not. Several e-mails indicate that 
Wiesel may have lobbied the White House. On December 21, 2000, 
Jack Quinn wrote to Robert Fink and Azulay, responding to 
Azulay's question about ``having another VIP place an 
additional call'' to President Clinton.\513\ As Quinn wrote, 
``I think another call is fine, but it needs to come from 
someone who can get POTUS personally on the line. Did Elie 
Wiesel call?'' \514\ Azulay responded to Quinn's inquiry by e-
mailing, ``I don't know positively if he talked directly to 
potus and if he did what was his reaction. All he told me was 
that `he was at the WH the day potus traveled but he couldn't 
give me any reaction.' '' \515\ Azulay then spoke with Wiesel 
again, and on December 25, 2000, Azulay responded to Quinn in 
an e-mail with the subject line ``elie wiesel,'' stating:
---------------------------------------------------------------------------
    \511\ Id.
    \512\ Id.
    \513\ Arnold & Porter Document Production A0831 (E-mail from Jack 
Quinn to Robert Fink et al. (Dec. 21, 2000)) (Exhibit 110).
    \514\ Id.
    \515\ Arnold & Porter Document Production A0836 (E-mail from Avner 
Azulay, Director, Rich Foundation, to Jack Quinn et al. (Dec. 22, 
2000)) (Exhibit 111).

        I talked to him today. He says that he brought up the 
        topic at the WH on Monday Dec 12th, he refused to 
        disclose who he met. He was told of the difficulties 
        lying ahead in dealing with it (he would explain it 
        only in a face to face meeting) and hopes that they can 
        be surmounted[.] \516\
---------------------------------------------------------------------------
    \516\ Arnold & Porter Document Production A0845 (E-mail from Avner 
Azulay, Director, Rich Foundation, to Jack Quinn et al. (Dec. 25, 
2000)) (Exhibit 112).

    On December 27, 2000, Azulay told Quinn, Kekst, Behan, 
Fink, and Marc Rich that he was looking for some way to have 
Wiesel express his opinion on the Rich pardon in a clear way to 
the President: ``Elie Wiesel--I am still checking if there is a 
way to get from him a straight forward support statement--
direct call to potus.'' \517\ Azulay followed up with another 
e-mail on December 31, 2000, stating that:
---------------------------------------------------------------------------
    \517\ Arnold & Porter Document Production A0851 (E-mail from Avner 
Azulay, Director, Rich Foundation, to Jack Quinn et al. (Dec. 27, 
2000)) (Exhibit 113).

        I was informed today that EW visited the WH last Dec 
        12th. He didn't meet or speak directly with potus. EW 
        had a scheduled mtg [sic] with the ``person responsible 
        for the pardons.'' His original goal was to discuss 
        Pollard--and at the same time raised a question about 
        the MRPG case. He was told that the MRPG case can't be 
        defined as humanitarian because there was no trial, 
---------------------------------------------------------------------------
        conviction or punishment to deal with[.]

        I understand--although he didn't disclose it that he 
        talked with a lawyer, the WH counsel. Perhaps BL.

        This is not new to you. What the lawyers think or 
        thought at the time. However, I think it worthwhile 
        mentioning that EW's mtg [sic] was held in the morniing 
        [sic] hours of Monday, Dec 12th--before xx [sic] before 
        the formal petition was delivered in the afternoon 
        hours. I hope that the lawyers have a different view of 
        the case by now?

        It is clear that EW is reluctant to make a direct 
        appeal to potus--with the uncertainty that he is doing 
        something that doesn't stand a chance. Therefore, it 
        seems plausible that if someone he respects will 
        convince him that he is doing the right thing it might 
        still be possible.\518\
---------------------------------------------------------------------------
    \518\ Arnold & Porter Document Production A0854 (E-mail from Avner 
Azulay, Director, Rich Foundation, to Jack Quinn et al. (Dec. 31, 
2000)) (Exhibit 114).

Despite the assurances that Wiesel had raised the Rich pardon 
with White House staff, Azulay apparently continued his efforts 
to have Wiesel raise it directly with the President. On January 
2, 2001, he e-mailed Fink, Quinn, and Behan to tell them that 
Knesset Speaker Avraham Burg was going to try to recruit Wiesel 
to help with the Rich case.\519\
---------------------------------------------------------------------------
    \519\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00104 
(E-mail from Avner Azulay, Director, Rich Foundation, to Robert Fink et 
al. (Jan. 2, 2001)) (Exhibit 115).
---------------------------------------------------------------------------
    Other than the information that Azulay was able to get from 
Wiesel, Gershon Kekst also told the rest of the Rich team that 
Wiesel had weighed in with the White House on the Rich pardon. 
In a January 9, 2001, e-mail, Kekst wrote that ``[b]y the way, 
please tell marc [sic] that I am `assured' the call has been 
made by elie [sic].'' \520\ Robert Fink responded that he would 
``tell Marc about Elie.'' \521\ When he was interviewed by 
Committee staff, Kekst explained that he discussed Wiesel's 
involvement in the Rich pardon effort with Yossi Ciecanover, a 
former senior Israeli government official.\522\ Ciecanover told 
Kekst that he had been asked by Azulay to ask Wiesel to express 
support for the Rich pardon.\523\ Ciecanover said that Wiesel 
either ``would call'' or ``did call'' the President.\524\
---------------------------------------------------------------------------
    \520\ Piper Marbury Rudnick & Wolfe Document Production PMR&W 00159 
(E-mail from Gershon Kekst, President, Kekst and Co., to Robert Fink 
and Jack Quinn (Jan. 9, 2001)) (Exhibit 116).
    \521\ Id.
    \522\ Interview with Gershon Kekst, President, Kekst and Co. (Mar. 
15, 2001).
    \523\ Id.
    \524\ Id. Associate White House Counsel Eric Angel also suggested 
that he heard that Wiesel raised the Rich matter with President 
Clinton. However, after making this initial assertion, Angel 
backtracked, and said that he was not certain if he recalled hearing 
this before the pardons were granted, or from media accounts after the 
fact. Interview with Eric Angel, former Associate Counsel to the 
President, the White House (Mar. 28, 2001).
---------------------------------------------------------------------------
    Elie Wiesel has denied any involvement in the Marc Rich 
pardon effort, calling such allegations ``pure fantasy.'' \525\ 
Wiesel acknowledged that he did visit the White House in 
December 2000 and January 2001.\526\ However, Wiesel denied 
that he raised any Marc Rich pardon issues with anyone at the 
White House on either of those visits.\527\ He also denied that 
he ever raised any pardon issues with anyone at the White House 
in any other form, other than writing a letter on Jonathan 
Pollard's behalf to the President.\528\ Given the lack of any 
first-hand evidence that Wiesel did actually lobby the 
President on behalf of Marc Rich, the e-mails of Kekst and 
Azulay most likely overstated involvement of Wiesel in the Rich 
pardon effort.
---------------------------------------------------------------------------
    \525\ Telephone Interview with Elie Wiesel (Apr. 2, 2001).
    \526\ Id.
    \527\ Id.
    \528\ Id. 
---------------------------------------------------------------------------
            5. King Juan Carlos
    King Juan Carlos apparently made two contacts with the 
White House over the Rich pardon. The first contact was a 
direct one, when the King called President Clinton personally 
regarding the Rich pardon. On January 13, 2001, Avner Azulay 
sent an e-mail to the Rich legal team indicating that ``we have 
a CFM [confirmation] that the king of spain [sic] talked to 
potus. He reports a positive conversation. No concrete sayings 
[sic].'' \529\ It is unclear why the King took this action on 
Rich's behalf. It is possible that the King was motivated by 
Rich's support of Madrid's Jewish community, but he has not 
offered any explanation for his actions.
---------------------------------------------------------------------------
    \529\ Arnold & Porter Document Production A0881 (E-mail from Avner 
Azulay, Director, Rich Foundation, to Jack Quinn et al. (Jan. 13, 
2001)) (Exhibit 117).
---------------------------------------------------------------------------
    Also in this same time frame, John Podesta heard of King 
Juan Carlos' interest in the Rich pardon. Podesta received a 
telephone call from former Congressman John Brademas, President 
Emeritus of New York University, who is a friend of King Juan 
Carlos.\530\ The King had informed Brademas that he had 
recently met with the Israeli Foreign Minister, Shlomo Ben Ami, 
who had raised the Marc Rich pardon with the King. The King in 
turn called Brademas to see if Brademas could make the King's 
interest in the pardon known to the White House. Podesta told 
Brademas that ``while it was the President's decision, the 
White House Counsel's Office and I were firmly opposed and I 
did not believe that the pardon would be granted.'' \531\ While 
Podesta apparently braced the King for the worst, the King's 
interest in the Rich matter was made known to the President, as 
well as Marc Rich's supporters, who have often mentioned his 
support for the pardon.
---------------------------------------------------------------------------
    \530\ ``The Controversial Pardon of International Fugitive Marc 
Rich,'' Hearings Before the Comm. on Govt. Reform, 107th Cong. 320 
(Mar. 1, 2001) (testimony of John Podesta, former Chief of Staff to the 
President, the White House).
    \531\ Id. at 317.
---------------------------------------------------------------------------
            6. Avner Azulay
    Avner Azulay is a former high-ranking Mossad agent. He 
founded his own security consulting company after leaving the 
Mossad in the early 1990s.\532\ Marc Rich retained his services 
and placed him as the head of the Marc Rich Foundation and the 
Doron Foundation, based in Jerusalem.\533\ These Foundations 
handle all of Rich's philanthropic interests (they were 
recently merged and are now referred to only as the Marc Rich 
Foundation). These foundations also paid significant amounts of 
money to many organizations and persons who wrote letters on 
behalf of Marc Rich that were included in the pardon petition.
---------------------------------------------------------------------------
    \532\ Bo'az Ga'on, Rich as Korach, Ma'ariv Weekend Magazine, Oct. 
1, 1999 (Exhibit 6).
    \533\ Id.
---------------------------------------------------------------------------
    Azulay was a central figure in the pardon effort. His name 
appears on a large number of the e-mails produced to the 
Committee that were sent among the Rich pardon team. Azulay 
played a key role in securing many of the letters included in 
the petition. He traveled throughout Israel, Europe, and the 
United States soliciting the letters for the pardon. Azulay 
also solicited many Jewish leaders for their support of Rich. 
In this effort, Azulay contacted Abraham Foxman, Elie Wiesel, 
and Rabbi Irving Greenberg, among others. As would be revealed 
after the pardon was granted, however, not everyone who was 
approached by Azulay was told that their letter would be used 
in the pardon effort.
    The Committee first sought Avner Azulay's cooperation in 
its investigation in a March 8, 2001, letter asking him to 
participate in an interview with Committee staff.\534\ Azulay 
refused to meet with staff, citing health reasons.\535\ 
Committee staff followed up with a number of telephone calls to 
Azulay's counsel to try to secure an interview, but he made it 
clear that Azulay would not participate in an interview, due to 
health concerns and concerns regarding the ongoing criminal 
investigation by the Southern District of New York. As a close 
advisor to Marc Rich and a key participant in the pardon 
effort, Azulay has a great deal of valuable information that he 
has decided to withhold from the Committee. His lack of 
cooperation appears to be part of a concerted effort by Marc 
Rich and his closest advisers to keep critical information 
about the pardon effort from the American people.
---------------------------------------------------------------------------
    \534\ Letter from the Honorable Dan Burton, Chairman, Comm. on 
Govt. Reform, to Avner Azulay, Director, Rich Foundation (Mar. 8, 2001) 
(Exhibit 118).
    \535\ Letter from Avner Azulay, Director, Rich Foundation, to the 
Honorable Dan Burton, Chairman, Comm. on Govt. Reform (Mar. 15, 2001) 
(Exhibit 119).
---------------------------------------------------------------------------
            7. Michael Steinhardt
    Michael Steinhardt is a prominent hedge fund investor who 
has also been involved in Democratic politics, having served as 
the Chair of the Democratic Leadership Council and the 
Progressive Policy Institute. He first met President Clinton 
while serving in the former position.