CONYERS: Why Nixon Should Have Been Impeached - 1974

Dean of the U.S. House
of Representatives
John Conyers, Jr.

RICHARD NIXON, like the President before him, was in a real sense a casualty of the Vietnam War, a war which I am ashamed to say was never declared. Since the hearings of the House Judiciary Committee began on May 9th, 1974, we have had a professional staff of some 89 men and women gather in great detail over 42 volumes of information that was considered throughout some 57 sessions. My analysis of the evidence clearly reveals an Administration so trapped by its own war policy and a desire to remain in office that it entered into an almost unending series of plans for spying, burglary and wiretapping, inside this country and against its own citizens, and without precedent in American history.

Let us turn back to 1969 when the war was still going on and the President authorized the bombing of infiltration routes that passed through two independent and sovereign nations, Cambodia and Laos. On May 9, 1969, shortly after the bombing began, William Beecher, the Pentagon correspondent for the New York Times, published a story disclosing that "American B-52 bombers in recent weeks have raided several Viet Cong and North Vietnamese supply dumps in Cambodia for the first time." That story triggered the beginning wiretaps and shortly thereafter, the Administration embarked upon a program of illegal surveillance involving both members of the press and of the Government.

And so this secret war in Cambodia, which seemed at first incidental as I studied the record before us, has emerged as the starting point which enables me to understand the tremendous amount of surveillance and spying and burglary that has characterized the evidence and this Administration, and led to eventual impeachment proceedings.

THE JUDICIARY Committee undertook its impeachment inquiry with a clear recognition of the gravity of its responsibility to the Congress and the Constitution. Our task was unique in modern history and complicated by the sheer weight of the evidence to be evaluated. But the process of impeachment is not, and was never intended to be, familiar, convenient, or comfortable. It was framed with the intention that it be used only as a last constitutional resort against the danger of executive tyranny. The Congress should not lightly interpose its judgment between the President and the people who elect him, but we cannot avoid our duty to protect the people from "a long train of Abuses and Usurpations."

The articles of impeachment recommended by the Judiciary Committee, although narrowly drawn, are fully consistent with our constitutional responsibility. There is clear and convincing proof that Richard Nixon violated his oath of office and committed high crimes and misdemeanors which jeopardized the liberties of the people. In calling him to account, we also re-establish the proper parameters of presidential conduct. It is essential, therefore, that the record of our inquiry be complete so that no future president may infer that we have implicitly sanctioned what we have not explicitly condemned.

President Nixon's determination to extend the Vietnam War throughout Indochina led him to conclude that the infiltration of men and supplies through Cambodia and Laos had to be interdicted. This could have been done by bombing North Vietnam, but at the cost of destroying the fragile Paris Peace talks, then in progress. His only recourse, given his assumptions, was to bomb the supply routes in Cambodia which led into South Vietnam At the same time, he apparently realized that public disclosure of such bombing would create a firestorm of Congressional and public protest.

The logic of the White House becomes clear: Vietnamization required the bombing of Cambodia, which in turn required secrecy at all costs. The pressures of concealment led in turn to a spirit of distrust within the administration which spread as the President and his aides became increasingly enmeshed in the snare of lies and half-truths they had themselves created. Having decided that the People and the Congress could not be trusted with the truth, Mr. Nixon's distrust was soon extended to his own foreign policy advisors and assistants.

The authorization and concealment of the Cambodian bombing, and the means he employed to prevent its disclosure, illustrated in the very first months of his administration that the President was prepared to do anything he considered necessary to achieve his objectives. To defend both the bombing and the subsequent wiretapping, he invoked the concept of national security, a convenient rationalization to be used whenever the occasion demanded an explanation for some concealed governmental conduct. The imperial presidency of Richard Nixon came to rely on this claim as a cloak for clandestine activity, and as an excuse for consciously and repeatedly deceiving the Congress and the people.

NIXON TURNED on his critics with a vengeance, apparently not appreciating that others could strenuously disagree with him without being either subversive or revolutionary. He took full advantage of the FBI's willingness to invade people's private lives without legal justification and without regard for their civil liberties. This willingness was documented during Congressional Black Caucus hearings on governmental lawlessness in June, 1972, which revealed that the files of the FBI and the Secret Service are laden with unverified information, often inaccurate and slanderous, on thousands of citizens, particularly blacks, who have had the temerity to speak out against racism, injustice, or the Indochina war. This surveillance of government critics by the FBI began, of course, before Mr. Nixon took office, but his administration gave renewed approval to some of the ugliest abuses of governmental power.

Obsessed by the notion that the disruptive activities of the blacks and students who criticized him were receiving foreign support, he repeatedly demanded that the FBI and CIA conduct extensive investigations to verify this potential conspiracy. But, even with additional authority conferred on these agencies, their reports continually indicated that his fears were unfounded. The inability of the FBI and CIA to substantiate the President's conviction that many of his critics were engaged in subversion or international conspiracy led him to increasingly question their operational efficiency.

Hence, the President's approval of the Huston plan in July, 1970, represented nothing more than an extension of an already demonstrated willingness to harass and spy on his political opponents. Even if the Huston plan itself was subsequently tabled, its spirit lived on in the White House and soon took tangible form with attempts to use the Internal Revenue Service for discriminatory personal and political purposes, and with the activities of the Plumbers unit.

The Plumbers put the essence of the Huston plan into practice and provided the President with his own secret intelligence force to investigate his critics and discredit them by any means possible, without even the most elementary regard for individual privacy or public morality.

With the assistance of the President's closest advisors, the Plumbers violated the charter of the Central Intelligence Agency by seeking CIA assistance to impugn the integrity of Senator Edward Kennedy, and to assess the administration's potential vulnerability from ITT's Dita Beard, whose confidential memo implied that a bribe had been offered to settle the ITT antitrust case.

They sought to discredit the Democratic party by falsifying State Department cables to implicate President Kennedy in the assassination of South Vietnamese President Diem. They broke into the Los Angeles office of Dr. Fielding in an attempt to gain medical information that would defame Daniel Ellsberg and, through him, the critics of the President's war policies.

In these ways, and perhaps in other ways still undisclosed, they violated every canon of morality and legality which stood between them and their goal of discrediting and undermining the President's "enemies".

THESE ACTIVITIES demonstrate that the break-in and bugging of the Democratic National Committee, and the subsequent cover-up specified in Article I, were not inexplicable aberrations from a standing presidential policy of strict adherence to the law. Instead, in proper perspective, the Watergate break-in emerges as only one incident in a continuous course of conduct which had its origins in the first months following President Nixon's inauguration.

The subsequent concealment was intended not merely to protect the White House from its complicity in the Watergate incident itself, but to avoid disclosure of the entire train of illegal and abusive conduct that characterized the Nixon presidency:

-Obstruction of justice;

-Perjury and subornation of perjury;

-Offers of executive clemency;

-Attempts to influence a federal judge;

-Destruction of evidence;

-Disclosure of secret grand jury proceedings;

-Withholding information of criminal activity;

-Impoundment of Congressional appropriations;

-Willful tax evasion;

-Possible bribery in connection with the ITT antitrust and milk price support decisions;

-And interference with the lawful activities of the CIA, FBI, IRS, Special Prosecutor, House Banking and Currency Committee, Senate Select Committee on Presidential Campaign Activities, and finally, the House Judiciary Committee.

In these ways, the President sought to avert disclosure of a seamless web of illegality and impropriety.

That cover-up continued to the end, in that the President attempted to deceive the Congress and the American people by concealing and misrepresenting his knowledge and participation in these activities, and even while resigning, refusing to admit his complicity. Additionally, he withheld necessary information from the Special Prosecutors and fired Special Prosecutor Cox for his efforts to fully discharge his responsibilities. He refused to comply with the legal and proper subpoenas of the Judiciary Committee, as charged in Article III. He mutilated and destroyed evidence in his possession or caused that to happen, and did very nearly everything in his power to impede, delay, and obstruct the proper course of justice.

In my judgment, this course of presidential conduct, outlined above and specified in Articles I, II, and III, provides irrefutable evidence that Richard Nixon was not fit to enjoy the trust and authority which reposes in the Presidency of the United States.

But of at least equal importance is the uncontroverted evidence that Mr. Nixon authorized an illegal war against the sovereign nation of Cambodia, and sought to protect himself from criticism and possible repudiation by engaging in deliberate policies of concealment, deception, and misrepresentation.

On July 30, 1974, I proposed the following article of impeachment:

In his conduct of the office of President of the United States, Richard M. Nixon, in violation of his constitutional oath faithfully to execute the office of President of the United States and, to the best of his ability, preserve, protect, and defend the Constitution of the United States, and in disregard of his constitutional duty to take care that the laws be faithfully executed, on and subsequent to March 16, 1969, authorized, ordered and ratified the concealment from the Congress of the facts and the submission to the Congress of false and misleading statements concerning the existence, scope and nature of American bombing operations in Cambodia in derogation of the power of the Congress to declare war, to make appropriations, and to raise and support armies, and by such conduct warrants impeachment and trial and removal from office.

Although this article was not recommended by the Committee, it is fully supported by the facts and the Constitution.

The President of the United States must exercise only those powers which are legally and constitutionally his to exercise, and, by his actions, he must demonstrate due respect for the democratic rights of the people and the constitutional responsibilities of the Congress. The manner in which the Cambodian bombing was initiated, conducted, and reported clearly exceeded the constitutional powers of the presidency, and presented indisputable evidence of impeachable conduct.

President Nixon unilaterally initiated and authorized a campaign of bombing against the neutral nation of Cambodia. For the next four years, he continually deceived the Congress and the American people as to when the bombing began and how far it extended. In so doing, he exceeded his constitutional power as commander-in-chief. He usurped the power of the Congress to declare war, and he expended monies for a purpose not authorized or approved by the Congress. In so doing, he also denied the people of the United States their right to be fully informed about the actions and policies of their elected officials.

It is important to note that the facts pertinent to the Cambodian bombing are not in question. On 11 February 1969, General Creighton Abrams, Commander of the United States Military Assistance Command Vietnam, recommended and requested authorization to conduct bombing strikes in Cambodia. Between 12 February and 17 March 1969, this request was considered by the President in meetings of the National Security Council. On 17 March 1969, President Nixon authorized the bombing of Cambodia.

The bombing began on 18 March 1969 and continued unabated until 15 August 1973. From 18 March 1969 to 1 May 1970, when the United States initiated ground combat operations in Cambodia, 3,695 B-52 sorties were conducted, during which a total of105,837 tons of bombs were dropped on Cambodia. From the beginning to the end of the bombing campaign in August, 1973,more than 150,000 sorties dropped in excess of 500,000 tons of bombs in Cambodia.

The bombing operations took the form of three different operations, code named "Menu Operation", "Patio", and "Freedom Deal". Under the procedure instituted for reporting "Menu Operation" bombing missions, the regular, operational reports prepared after each mission indicated that the strikes had taken place in South Vietnam rather than in Cambodia. Most "Patio" bombing missions were not reported at all; forty-eight "special" "Patio" strikes were reported as having occurred in Laos, rather than Cambodia. The "Freedom Deal" tactical air strikes began on 30 June 1970, the date on which the last contingent of American ground forces was withdrawn from Cambodia. These strikes were reported as having taken place in Cambodia, but in many cases, the targets of "Freedom Deal" strikes were not those which were authorized and reported.

SIMILARLY, THERE is no dispute that the President made a decision to keep the bombing secret. When President Nixon approved the first bombing strikes in Cambodia, he directed General Earle Wheeler, Chairman of the Joint Chiefs of Staff, to inform General Abrams that the bombing operations were not to be discussed with any unauthorized person, even though this meant circumventing the normal chain of command which would otherwise have included the Secretary of the Army, the Vice Chief of Staff for the Air Force, and the Commander of the Seventh Air Force.

The President's policy of concealment, deception, and misrepresentation was consistently reflected in his own public statements and in the Congressional testimony of his military and civilian subordinates.

In a nationally televised address on 14 May 1969, two months after the bombing in Cambodia began, the President stated, "1 have tried to present the facts about Vietnam with complete honesty, and I shall continue to do so in my reports to the American people."

At a news conference on 8 December 1969, the President asserted that the people of the United States were entitled to know everything they could with regard to any involvement of the United States abroad.

At another news conference on 21 March 1970, President Nixon declared that the United States would continue to "respect Cambodia's neutrality."

On 30 April 1970, when the President announced the American invasion of Cambodia, he reviewed previous American policy toward Cambodia in the following terms:

American policy since then has been to scrupulously respect the neutrality of the Cambodian people. We have maintained a skeleton diplomatic mission of fewer than 15in Cambodia's capitol, and that only since last August. For the previous 4 years, from1965 to 1969, we did not have any diplomatic mission whatever in Cambodia. And for the past 5 years, we have provided no military assistance whatever and no economic assistance to Cambodia. For 5 years, neither the United States nor South Vietnam has moved against these enemy sanctuaries because we did not wish to violate the territory of a neutral nation. Even after the Vietnamese Communists began to expand these sanctuaries 4 weeks ago, we counseled patience to our South Vietnamese allies and imposed restraints on our own commanders.

On 30 June 1970, the President released a report entitled "The Cambodian Operation" which stated in part:

For five years. North Vietnam has used Cambodian territory as a sanctuary from which to attack allied forces in South Vietnam. For five years, American and allied forces - to preserve the concept of Cambodian neutrality and to confine the conflict in Southeast Asia - refrained from moving against these sanctuaries.

The evidence is unmistakeable, therefore, that President Nixon personally and directly lied to the American people by repeatedly concealing the fact that the United States had begun to bomb Cambodia in March, 1969.

THE PRESIDENT'S public assurances were complemented by the erroneous and misleading statements made to the Congress by his civilian and military subordinates. Such statements were made by the Chief of Staff of the Air Force, the Secretary of State, the Secretary of the Army, the Secretary of Defense, and the Secretary of the Air Force in testimony before the Senate Committee on Armed Services, the Senate Committee on Foreign Relations, the Senate Committee on Appropriations, and the House Committee on Appropriations.

For example, on 27 April 1970, Secretary of State Rogers testified before the Senate Foreign Relations Committee, declaring that, "Cambodia is one country where we can say with complete assurance that our hands are clean and our hearts are pure . . . Our best policy is to be as quiet as possible, to avoid any action which appears to violate the neutrality of Cambodia."

For example, on 16 April 1970, Secretary of the Army Resor testified before the Senate Appropriations Committee that there had been no "U.S. military aid and no Army support for Cambodia" since January, 1964.

For example, on 31 March 1971, Secretary of the Air Force Seamans was requested by the Senate Armed Services Committee to submit a report on American bombing missions in Indochina. Seamans subsequently submitted a classified report which indicated that no bombing strikes had been conducted in Cambodia prior to 1 May 1970, even though bombing strikes had actually begun in March, 1969.

It was not until 16 July 1973 that Secretary of Defense Schlesinger was forced to confirm earlier disclosures to the Senate Armed Services Committee that the United States had bombed Cambodia, a sovereign and neutral nation, before May, 1970.

Richard Nixon authorized the bombing of Cambodia. In a series of subsequent public statements, he deliberately and intentionally lied to the American people. And in their testimony before duly authorized committees of the Congress, his civilian and military subordinates failed to testify fully and accurately. Whether his subordinates deceived the Congress intentionally or unintentionally, the fact remains that the President must have known that they testified inaccurately, and he made no attempt to correct the record.

BY HIS SECRET bombing of Cambodia, President Nixon unquestionably exceeded his powers as commander-in-chief, for not even the most tortured interpretation of Article II, Section 2 could support a war begun and pursued in secrecy. He also violated Sections 7 and 8 of Article I, which give to the Congress the authority to make appropriations and declare war. For the "power of the purse" to have any meaning, the Congress must know how the money it appropriates is spent.

By conducting a war without the knowledge of the Congress, President Nixon further eroded whatever remains of the constitutional power of the Congress to decide when and where the United States shall be at war. We cannot sanction such a policy of deliberate deception, intended to nullify the constitutional powers of the Congress to legislate for the people we represent.

By the same policies of secrecy and deception, Richard Nixon also violated a principal tenet of democratic government: that the President, like every other elected official, is accountable to the people.

For how can the people hold their President to account if he deliberately and consistently lies to them? The people cannot judge if they do not know, and President Nixon did everything within his power to keep them in ignorance. In all good conscience, we must condemn his deception regarding Cambodia with the same fervor and outrage we condemn his deception regarding Watergate.

The difficult question is not whether the secret bombing of Cambodia constitutes impeachable conduct. That is too obvious to require further argument.

Instead, the question we must ponder is, why the Congress has not called Mr. Nixon to judgment for the bombing of Cambodia? The painful answer is that condemning the Cambodian bombing would also have required us to indict previous administrations and to admit that the Congress has failed to fully meet its own constitutional obligations.

WHETHER INTENTIONALLY or not, the Congress has participated in the degeneration of its power to declare war. Although a War Powers Act was passed recently, over the veto of President Nixon, no legislation is self-executing. Whatever its limitations and faults, this legislation, and the constitutional provisions on which it is based, will only have meaning to the extent that the Congress invests them with meaning. Instead of merely ratifying the decisions and recommendations of the executive branch, the Congress must demonstrate that it is once again prepared to play an active and constructive role in the formulation of foreign policy - in the creation of policies which will direct this nation toward war or peace.

If this is truly to be a representative government, then the people's representatives in Congress must no longer allow any one person to decide unilaterally when, where, and why Americans shall die violent deaths or kill others. The Congress may not be subject to impeachment, but it is subject to emasculation.

We must directly confront the fact that the secret bombing of Cambodia is only the most recent and egregious illustration of the disintegration of the war power of Congress, and that the Congress has participated in this process, wittingly or unwittingly.

If, during the impeachment proceeding, we have failed to learn this lesson, then we deserve the obloquy, not the gratitude, of the people of the United States. If we do not now fully dedicate ourselves to regaining every bit of constitutional ground we have surrendered, then - to paraphrase one of the President's men - we shall have lost our constitutional and moral compass.

IT HAS FREQUENTLY been argued during the past weeks that the Committee's inquiry and the President's subsequent resignation demonstrate that "the system works." But such satisfaction or complacency is misguided. We must recognize that we were presented with a seemingly endless series of public revelations and presidential actions which did more to undermine Mr. Nixon's position than any independent investigation undertaken by this Committee or its staff.

The Congressional inquiry has been the beneficiary of literally years of work by investigative reporters, the Special Prosecutor's office, and the Senate Select Committee on Presidential Campaign Activities. And most importantly, the President himself documented his words and actions through his secret taping system, without which our inquiry might never have even been begun. The President himself did more than anyone or anything to insure his removal from office.

If the system has worked, it has worked by accident and good fortune. It would be gratifying to conclude that the House, charged with the sole power of impeachment, exercised vigilance and acted on its own initiative. However, we would be deluding ourselves if we did not admit that this inquiry was forced on us by an accumulation of disclosures which, finally and after unnecessary delays, could no longer be ignored.

Perhaps, ironically, and certainly unintentionally, we have ourselves jeopardized the future of the impeachment process. Before this inquiry, the prospect of impeaching a president was disquieting because it had not been attempted in more than a century. Now with our inquiry as a precedent, future Congresses may recoil from ever again exercising this power. They may read the history of our work and conclude that impeachment can never again succeed unless another President demonstrates the same, almost uncanny ability to impeach himself.

If this is our legacy, our future colleagues may well conclude that ours has been a pyrrhic victory, and that impeachment will never again justify the agony we have endured. It is imperative, therefore, that we speak to them clearly: impeachment is difficult and it is painful, but the courage to do what must be done is the price of remaining free.

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U.S. Senate Judiciary Committee Examines Special Counsel Under Watergate

During the Nixon administration, the Ethics in Governance Act of 1978 was created to establish the U.S. Office of Government Ethics and Special Counsel appointment procedure during Watergate investigation.

Conference report filed in House (10/11/1978)

(Conference report filed in House, H. Rept. 95-1756)

Ethics in Government Act - 

=Title I: Legislative Personnel Financial Disclosure Requirements=

- Requires each Member of Congress, each Congressional officer and employee who is compensated at a rate equal to or more than the pay rate for grade GS-16, and any candidate for the office of Member to file an annual financial disclosure report (hereinafter referred to as "report") containing specified information including: (1) sources amounts of income, gifts, and reimbursements; (2) the identity and approximate value of property held and liabilities owed; (3) transactions in property, commodities, and securities; and (4) certain financial interests of a spouse or dependent.

Provides that such report be filed with the Clerk of the House of Representatives or the Secretary of the Senate, for the employee's respective House. Directs the Clerk and the Secretary to: (1) send a copy of each report of a Member or candiate to the appropriate State officer of their State; (2) submit each report for review by either the Committee of Official Conduct of the House or the Select Committee on Ethics of the Senate; and (3) make such reports generally available to the public.

Prohibits the use of information from such reports for commercial, credit, or solicitation purposes, or for any unlawful purpose.

Authorizes the Attorney General to bring civil actions in any appropriate district court against individuals who knowingly and willfully falsify or fail to file or report specified information required under this Act.

Authorizes such courts to assess against such individuals civil penalties not to exceed $5,000.

Requires the Comptroller General to report to Congress on the effectiveness of the implementation of this Title and the feasibility of conducting random audits of such reports.

=Title II: Executive Personnel Financial Disclosure Requirements=

- Requires the President, Vice President, each presidential or vice- presidential candidate, each military officer rated at 0-7 or higher, each presidential appointee whose Senate confirmation is pending, and each employee of the Executive branch who is compensated at a pay rate equal to or greater than that for grade GS-16 to file such report as described in Title I of this Act which shall include additional information regarding positions held with business entities, and agreements with respect to future employment and continuation of payments by former employers.

Excludes political campaign funds, including campaign receipts and expenditures, from such reports.

Authorizes the Attorney General to bring civil actions and district courts to assess civil penalties similar to those in Title I against individuals for failure to file or falsifying reports. Requires the head of each agency, each Secretary concerned, and the Director of the Office of Government Ethics to refer to the Attorney General the name of any individual they have reasonable cause to believe has willfully failed to file a report or willfully falsified or failed to file required information. Authorizes the President, the Vice President, the Secretary concerned, and the head of each agency or the Civil Service Commission to take appropriate personnel or other action in accordance with applicable law or regulation against any individual failing to report information required to be reported.

Requires that such reports be made generally available to the public, with specified exceptions for certain individuals involved in intelligence activities.

Prohibits the use of information from such reports as described in Title I. Authorizes the Attorney General to bring civil actions against persons who obtain or use such reports for such prohibited purposes. Authorizes courts in which such actions are brought to assess against such persons penalties not to exceed $5,000 in any one case. Stipulates that such remedy shall be in addition to any other remedy available under statutory or common law.

Requires that reports be reviewed within 60 days of filing. Establishes procedures to notify individuals of their noncompliance and to assist them in complying with the requirements of this Act.

Permits the President to require officers and employees in the executive branch not covered by this title to submit confidential reports.

Permits the Director of the Office of Government Ethics to require by rule disclosure of gifts received by dependent children of reporting individuals if such information does not exceed that required of spouses.

Requires that the Comptroller General have access to executive personnel financial disclosure reports in order to carry out statutory responsibilities.

=Title III: Judicial Personnel Financial Disclosure Requirements=

- Requires the Chief Justice and the Associate Justices of the Supreme Court, each Federal court judge, judges of the courts of the District of Columbia, any presidential nominee for judicial office whose Senate confirmation is pending, and each judicial employee who is compensated at a pay rate equal to or greater than that for grade GS-16 to file such report as described in Title II.

Directs the Judicial Conference of the United States to establish a Judicial Ethics Committee to: (1) receive such reports of judicial personnel; (2) monitor compliance with this Title; (3) provide for the availability of such reports to the public; (4) develop the method of determining the value of assets required to be disclosed under this Title; and (5) review such reports to ascertain possible violations of conflict of interest laws.

Authorizes the Attorney General to bring civil actions and the courts to assess civil penalties similar to those in Title I and II against individuals failing to file or falsifying reports. Requires the Committee to refer the names of such individuals to the Attorney General.

Prohibits the use of information from such reports as described in Title I. Authorizes the Attorney General to bring civil actions against persons who obtain or use such reports for such prohibited purposes. Authorizes courts in which such actions are brought to assess against such persons penalties not to exceed $5,000 in any one case. Stipulates that such remedy shall be in addition to any other remedy available under statutory or common law.

=Title IV: Office of Government Ethics=

- Establishes in the Office of Personnel Management the Office of Government Ethics, with a Director to be appointed by the President, by and with the advice and consent of the Senate.

Requires the Director to provide overall direction of executive branch policies related to preventing specified conflicts of interest on the part of officers and employees of any executive agency. Stipulates certain responsibilities of the Director.

Requires the Director to consult, when appropriate, with affected executive agencies and the Attorney General in the development of policies, rules, regulations, procedures, and forms.

Requires the Director to develop and recommend and the Office of Personnel Management to promulgate a regulation establishing a method for readily determining, without the necessity for expert appraisal, the fair market value of assets required to be disclosed by this Act.

Directs each executive agency to: (1) make its services, personnel, and facilities available to the Director to the greatest practicable extent for the performance of functions under this Act; and (2) except when prohibited by law, furnish to the Director all necessary information and records in its possession.

Requires the Commission to issue its rules and regulations pertaining to financial disclosure, conflict of interest, and ethics in the Executive branch in accordance with the Administrative Procedure Act. Allows any person to seek judicial review of any such rule or regulation.

Authorizes the appropriation to carry out this Title of $2,000,000 for each of five fiscal years beginning with fiscal year 1979.

=Title V: Post-Employment Conflict of Interest=

- Extends from one to two years the period of prohibition on appearances before an agency by former Federal employees or officials or commissioned officers in the uniformed services at specified salary levels on matters that were under such persons responsibilities. Includes within such prohibition informal as well as formal contacts. Prohibits formal and informal contacts with such agencies by former employees on other matters for a period of one year after the end of such employment.

Exempts from the prohibition on contact with their former agency: (1) scientific personnel, if their communication is solely to furnish scientific and technical information; and (2) persons in specified positions designated by the Director of the Office of Government Ethics.

=Title VI: Amendments to Title 28, United States Code=

- Requires the Attorney General to investigate all specific allegations of Federal criminal law violations other than petty offenses, by specified individuals, including: (1) the President, Vice President, individuals at specified salary levels in the Executive Office of the President and the Department of Justice, any Assistant Attorney General, the Director and Deputy Director of Central Intelligence, and the Commissioner of the Internal Revenue Service; (2) all such specified individuals who held office during the incumbency of the President or during the period the last preceding President held office, if such preceding President was of the same political party as the incumbent President; and (3) any officer of the principal national campaign committee seeking the election or reelection of the President.

Requires the Attorney General to decide within 90 days whether the matter warrants further investigation or prosecution and if so, directs him to apply to the division of the U.S. Courts of Appeals responsible for the appointment of a special prosecutor.

Enumerates the authority and duties of a special prosecutor. Gives a special prosecutor all the investigative and prosecutorial functions and powers of the Department except those which specifically require the Attorney General's personal action.

Authorizes the special prosecutor to make public or send to Congress any statements or reports on his activities as special prosecutor he deems appropriate. Requires the special prosecutor to report to the division of the court at the conclusion of such special prosecutor duties.

Permits the special prosecutor to advise the House of Representatives of any substantial and credible information which may constitute grounds for impeachment of the President, Vice President, or a justice or judge of the United States.

Provides a procedure whereby specified Members of Congress can request that a special prosecutor may only be removed from office by impeachment and conviction, or by the Attorney General for extraordinary improperieties, physical disability, mental incapacity, or any other condition that substantially impairs performance. Permits the division of the court to terminate an office of special prosecutor at any time on the grounds that the investigations and prosecutions of such prosecutor have been completed.

Requires the Department of Justice to suspend all investigations and proceedings regarding any matter which is in the prosecutorial jurisdiction of a special prosecutor or which has been accepted by a special prosecutor under this Title, except to the extent required by this Title or insofar as such special prosecutor agrees in writing that such investigations or proceedings may be continued.

Allows the Attorney General or the Solicitor General to make a presentation as amicus curiae to any court as to issues of law raised by any case or proceeding or appeal in which a special prosecutor participates.

Terminates the provisions of this Act which pertain to a special prosecutor five years after the date on which this Act takes effect.

Authorizes to be appropriated such sums as may be necessary to be held by the Department as a contingent fund for the use of any special prosecutor appointed pursuant to this Act.

Requires the Chief Justice of the United States to assign three judges or justices for two-year periods to a division of the court to be the court for the appointment of special prosecutors. Requires the Chief Justice to assign three circuit court judges or justices, one of whom shall be a judge of the U.S. Court of Appeals for the District of Columbia, to such division of the court.

Requires the Attorney General to promulgate rules requiring any officer or employee of the Department, including a United States Attorney, to disqualify himself from participation in a particular investigation or prosecution if such participation may result in a personal, financial, or political conflict of interests or the appearance of such conflict.

Requires the Attorney General to report annually to Congress on the activities and operations of the Public Integrity Section and related investigations and prosecutions by any other units of the Department of Justice.

=Title VII: Senate Legal Counsel=

- Establishes an Office of Senate Legal Counsel.

Sets forth procedures for the appointment of a Senate Legal Counsel and a Deputy Senate Legal Counsel.

Makes the Office directly accountable to the Joint Leadership Group established under this Act.

Directs the Office to defend the Senate, a Member, officer, or employee of the Senate, or any agency or committee of the Senate if so authorized by a two-thirds vote of the Joint Leadership Group or by the adoption of a resolution by the Senate. Directs the Office to bring a civil action to enforce a Senate or committee or subcommittee subpoena only when directed to do so by the adoption of a resolution by the Senate. Directs the Office to intervene or appear as amicus curiae in the name of the Senate or of an officer, committee or subcommittee (or chair thereof) of the Senate. Directs the Office to serve as the duly authorized representative, in obtaining an order granting immunity under the Organized Crime Control Act, of: (1) the Senate, by an affirmative vote of a majority of Members present; or (2) a Senate committee or subcommittee, by an affirmative vote of two-thirds of the Members of the full committee.

Provides that the expenses of the Office shall be paid from the contingent fund of the Senate.

Ethics in Government Act of 1978 by Beverly Tran on Scribd

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CONYERS & BLUMENTHAL File Amicus Brief Supporting Citizens For Responsibility And Ethics In Washington

Conyers and Blumenthal are the lead plaintiffs in Congressional action to hold President Trump accountable for violations of the Constitution’s anti-corruption Foreign Emoluments Clause

[WASHINGTON, DC] – U.S. Senator Richard Blumenthal (D-CT) and U.S. Representative John Conyers, Jr. (D-MI) filed an amicus brief today in support of Citizens for Responsibility and Ethics in Washington’s (CREW) effort to hold President Trump accountable for his ongoing violations of the Foreign Emoluments Clause. Blumenthal and Conyers are the lead plaintiffs in a separate effort to compel the President to comply with the Constitution’ critically important anti-corruption measure.

Yesterday, the Washington Post reported that Trump International Hotel has already turned a $1.97 million profit in 2017. Those profits include payments from foreign governments which have housed their officials in rooms or hosted events at the hotel.

Dean of the U.S.
House of
Representatives
John Conyers, Jr.

“The Constitution’s Foreign Emoluments Clause is clear. Federal officials, including the President, cannot accept benefits of any kind from foreign states unless Congress consents.  President Trump, however, continues to violate this key anti-corruption provision, which was meant to ensure that the Nation’s leaders put the national interest above their personal interests,” said Conyers.

“The payments from foreign governments that President Trump’s hotel is raking in are just one example of how President Trump is thumbing his nose at the Constitution and the American people. The immense magnitude of President Trump's vast business empire is no excuse for his disregard for the Constitution and disrespect for the American people. No one – not even the President – is above the law,” said Blumenthal.

The full text of the lawmakers’ amicus brief is below.

Blumenthal and Conyers are the lead plaintiffs in Blumenthal, Conyers, et al. v. Trump, the lawsuit brought by nearly 200 members of Congress against President Trump for his violations of the Foreign Emoluments Clause.

The Foreign Emoluments Clause requires that all elected officials, including the president, seek the “Consent of the Congress” before receiving any gifts, payments, or benefits from foreign governments. The Constitution’s Framers included such a requirement to protect against foreign influence on U.S. officials, and to ensure that those officials act in the national interest, instead of their own.

Because President Trump has refused to disclose his business dealings abroad, the full scope of his potential Constitutional violations is unknown. Independent reporting has shown that President Trump has received the following foreign emoluments during his presidency among others:

·         Payments from foreign governments housing their officials in rooms or hosting events at Trump’s Washington, D.C. hotel after Inauguration Day;

·         Entities owned by foreign states paying rent at Trump Tower in New York City; and

·         The Chinese government granting forty trademarks to the Trump Organization.

While President Trump continues to accept benefits from foreign governments, Congress has no choice but to seek a remedy through the courts.

A Congressional Research Service analysis of suits by members of Congress found no larger action.

Conyers & Blumenthal Amicus Brief Supporting Citizens for Responsibility and Ethics Washington by Beverly Tran on Scribd

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CONYERS, CUMMINGS, CONNOLLY & CICILLINE Request Documents about President Trump’s Regulatory Task Forces’ Secret Meetings and Conflicts of Interest

Washington, D.C. (August 7, 2017)—Today, Reps. John Conyers, Jr., Ranking Member of the House Committee on the Judiciary, Elijah E. Cummings, Ranking Member of the House Committee on Oversight and Government Reform, Gerry Connolly, Ranking Member of the Subcommittee on Government Operations, and David Cicilline, Ranking Member of the Subcommittee on Regulatory Reform, Commercial and Antitrust Law, sent a letter, below, to Office of Management and Budget Director Mick Mulvaney and Office of Information and Regulatory Affairs Administrator Neomi Rao expressing grave concerns about the secrecy of the Regulatory Reform Task Forces and requesting information about the nature of their meetings.

“We write to express our alarm concerning the lack of transparency, accountability, and independence of the Regulatory Reform Task Forces,” the Members wrote. “We believe that the interests of the American public must be paramount when reviewing the worthiness of regulations. Therefore, these Task Forces must have an effective and transparent guard against conflicts of interest, especially those in which industry lobbyists seek to overturn environmental and health protections for financial gain. It appears that the current Task Forces are already failing on this front, and instead are actively hiding their members and their meetings from public view.”

The Democrats explained that press reports indicate these Task Forces appear to have operated in private without public input, and some agencies have refused to release basic information about their activity or maintain a record of their meetings as required by the Federal Records Act.

“Withholding the names and titles of Task Force participants may also violate the Freedom of Information Act (FOIA),” the Members wrote. “Simply put, it is unacceptable for federal agencies to operate in such a clandestine and unaccountable manner especially when the result could be the undoing of critical public health and safety protections.”

The Members also expressed concern that several employees stand to profit from their work on the Task Force. For example, the wife of one Task Force member at the Environmental Protection Agency is the top lobbyist for a large oil company.

“Rather than ‘drain the swamp,’ these conflicts threaten to influence the outcome of the review process against hardworking Americans and in favor of regulated industries and agency staff,” the Members wrote.

The Members requested documents and information, including a description of every Task Force created pursuant to the executive order, a list of the names and titles of every member of each Task Force, and communications related to non-governmental entities participating in Task Force meetings.

Congressional Letter To OMB On Executive Order On Regulatory Task Force 2017-08-7 by Beverly Tran on Scribd

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CONYERS: President Trump, follow the Constitution

Dean of the U.S. House
of Representatives
John Conyers, Jr.

My colleagues and I have taken the extraordinary step of filing a federal lawsuit against President Donald Trump for his violations of the U.S. Constitution’s Foreign Emoluments Clause. Article I, Section 9 of the Constitution forbids federal officeholders, including the President, from accepting “any present, Emolument, Office, or Title of any kind whatever, from any King, Prince, or foreign state” without the consent of Congress.

The Framers included the Emoluments Clause in the Constitution because they were deeply concerned about foreign powers gaining influence over our leaders through the promise of personal financial gain. They feared that our experiment in self-government would fail if the American people could not be assured that their elected officials made decisions based on the best interests of the nation rather than the best interests of their pocketbooks. “[I]f we do not provide against corruption, our government will soon be at an end,” George Mason of Virginia warned in 1787. 

At the Constitutional Convention in Philadelphia, the Framers debated for days how best to ensure the undivided loyalty of elected officials. “[N]othing was more to be desired than that every practicable obstacle should be opposed to cabal, intrigue, and corruption,” Alexander Hamilton explained in the Federalist Papers.  They eventually settled on the Emoluments Clause, which by its broad terms assumes that a financial benefit provided to a federal officeholder by a foreign power should be suspect and therefore subject to Congressional approval.

Since taking office, however, President Trump has&nbsp' refused to divest his business empire and has financially benefited from the actions of foreign powers that may be attempting to curry favor. To name but a few examples:  The governments of China, the United Arab Emirates, and Saudi Arabia lease properties in Trump office buildings; China swiftly granted President Trump’s businesses 38 trademarks following the election, after the Trump Organization spent a decade litigating the issue in court to no avail.  Trump International Hotel in Washington, D.C. actively courts foreign diplomats, some of whom have hosted events or stayed at his hotel since the Inauguration.  In January 2017, a lobbying firm working for Saudi Arabia spent $270,000 on rooms and other expenses at President Trump’s Washington hotel after Inauguration Day.

As one Asian diplomat boasted to the Washington Post for a November article, “Why wouldn’t I stay at [Trump’s] Hotel blocks from the White House, so I can tell the new president, ‘I love your new hotel,’” and another Middle Eastern diplomat acknowledged, “Believe me, all the delegations will go there.”

In January, President Trump’s attorney Sheri Dillon assured Americans that President Trump would “donate all profits from foreign government payments made to his hotels to the United States Treasury.” Nevertheless, in response to a request from the House Oversight Committee for documentation identifying foreign profits, the Trump Organization refused via  a single glossy brochure to “fully and completely identify all patronage” because it would be “impractical.”  Compounding the problem is the complete lack of transparency by the Administration or any form of oversight by the Majority in Congress. We learned that the “White House is telling federal agencies to blow off Democratic lawmakers oversight requests,” as Politico reported last month. 

President Trump’s actions demonstrate that he has no plans to voluntarily submit to Congressional approval of his financial benefits derived from foreign governments. By failing to do this, the President violates one of the Constitution’s most critical anti-corruption commands, and deprives Congress of its constitutionally assigned role in assessing what financial benefits from foreign states the president may accept.

No elected officeholder may be above the law, especially if he or she claims to be the sole judge of his or her own integrity. The Framers reasoned that if Congress were to decide which financial benefits a president may receive, the chances of corruption and foreign influence would be diminished because each transaction would be open to public examination. 

In deciding for himself what constitutes an emolument, President Trump is denying Congress its constitutional authority to grant – or withhold – its consent. And in our system of government, the judicial branch has the ultimate responsibility to interpret the Constitution, not the executive.   

Congress alone cannot force President Trump to comply with the Constitution. In the face of his continued defiance, therefore, we and our colleagues must ask the courts to help enforce this critical anti-corruption provision in the Constitution and direct President Trump to do what the Constitution requires. 

Our lawsuit is not just about protecting our institutional prerogative, but also to ensure that the Office of the President is not under any undue foreign influence. We owe this duty to uphold the Constitution to all Americans.

To learn about the history of Conyers enacting the constitutional mechanism of the Emoluments Clause, follow this link or just keep coming back.

Congress Emoluments Clause suit by New Mexico Political Report on Scribd

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CONYERS: Committee Democrats To Chairman Goodlatte: House Judiciary Must Do Its Job

Washington, D.C. – Today, sixteen Democratic members of the House Committee on the Judiciary sent a letter, below, to Chairman Bob Goodlatte (R-VA) to request that he schedule hearings immediately “to examine events that now extend well beyond any investigation into Russian influence—including the firing of FBI Director James Comey, allegations of obstruction of justice, and the inconsistent application of the Attorney General’s recusal from these and related matters.”

Today’s letter, led by Ranking Member John Conyers, Jr. (D-MI) and Rep. Sheila Jackson Lee (D-TX), addressed each of Chairman Goodlatte and the Majority’s usual explanations for not conducting oversight of the Department of Justice.  “With our Committee on the sidelines, the situation [at the Department] grows more perilous by the day,” the Members wrote.

The letter makes reference to a CRS report, below, that documents nearly a century of precedent where congressional investigations have overlapped with ongoing investigations at the Department of Justice.

On March 10th, every Democrat on the Committee called on Chairman Goodlatte to “get moving on Trump oversight” by holding formal committee hearings on Russia’s interference with the election and related matters. 

On May 11^th, Democrats on the House Committee on the Judiciary sent a letter to Chairman Bob Goodlatte, urging him to conduct immediate hearings into the firing of James Comey. 

On May 16^th, all 33 Democratic Members of the House Committee on Oversight and Government Reform and the House Committee on the Judiciary, sent a detailed letter to their respective Republican Chairmen outlining their demand for an immediate investigation into the actions of President Donald Trump, Attorney General Jeff Sessions, and top White House aides.

The House Judiciary Committee has jurisdiction over the Department of Justice and the Federal Bureau of Investigation. It also has jurisdiction over the Foreign Agents Registration Act and the Foreign Intelligence Surveillance Act.

Letter to U.S. House Judiciary Chairman Goodlatte To Hold Hearings On Obstuction Of Justice (6.21.17) by Beverly Tran on Scribd

CRS - Investigations of DOJ 1920-2012 by Beverly Tran on Scribd

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CONYERS & BLUMENTHAL Lay Out The Constitutional Case For Complelling President Trump To Obey Anti-Corruption Foreign Emoluments Clause

In the week since nearly 200 Members of Congress filed a lawsuit to compel President Trump to comply with the Constitution, public reporting has revealed new evidence of foreign benefits

[WASHINGTON, DC] – House Judiciary Committee Ranking Member John Conyers, Jr. (D-MI) and U.S. Senator Richard Blumenthal (D-CT) held a press conference at 12:30 PM in the Capitol Visitors Center (SVC-215) to outline the Constitutional case for compelling President Trump to obtain the consent of Congress before accepting payments, benefits, or gifts from foreign states. 

Last week, nearly 200 Members of Congress filed a complaint, below, in the U.S. District Court for the District of Columbia against President Trump, whose ongoing failure to disclose his foreign business dealings violates one of the Constitution’s critical anti-corruption provisions: the Foreign Emoluments Clause.

In the week since the lawsuit was filed, public reporting has revealed that President Trump has received additional foreign benefits – including new trademarks in China– and is brokering business deals in Saudi Arabia and the Persian Gulf while regional tensions escalate.

“We are joining in this action to prevent Donald Trump from thumbing his nose at the Constitution and the American people. The Constitution clearly states that no elected official - including the President - may receive gifts, payments, or benefits from foreign governments without disclosing them to Congress and seeking our consent,” Senator Blumenthal said. “The immense magnitude of President Trump's vast business empire is no excuse for his disregard of the Constitution and disrespect for the American people.”

“For generations,” Representative Conyers said, “presidents of both parties have complied with the Foreign Emoluments Clause by either divesting their business and financial holdings, or coming to Congress to seek approval prior to receiving any foreign government payment or other benefits. Our current President has done neither. This course of conduct is keeping Americans in the dark – leaving us to speculate if he’s acting on behalf of the American people or for his own financial benefit. Today’s legal action is designed to help lift our Nation out of this morass of conflicts and restore faith in our government, just as the founders intended.”

Because President Trump has refused to disclose his business dealings abroad, the full scope of his potential Constitutional violations is unknown. Independent reporting has shown that President Trump has received the following foreign emoluments during his presidency among others:

·         Payments from foreign governments housing their officials in rooms or hosting events at Trump’s Washington, D.C. hotel after Inauguration Day;

·         Entities owned by foreign states paying rent at Trump World Tower in New York City; and

·         The Chinese government granting thirty-nine trademarks to the Trump Organization.

U.S. Senators Patrick Leahy (D-VT), Tom Udall (D-NM), and Tammy Duckworth (D-IL) and U.S. Representatives Jerry Nadler (D-NY), Katherine Clark (D-MA) and Steve Cohen (D-TN) will also attend Tuesday’s press conference. They will be joined by Elizabeth Wydra, President of the Constitutional Accountability Center, the public interest organization whose attorneys are representing Members of Congress.

U.S. Congressman John Conyers, Jr. (D-MI)
U.S. Senator Richard Blumenthal, (D-CT)
U.S. Senator Patrick Leahy (D-VT)
U.S. Senator Tom Udall (D-NM)
U.S. Senator Tammy Duckworth (D-IL)
U.S. Representative Jerry Nadler (D-NY)
U.S. Representative Katherine Clark (D-MA)
U.S. Representative Steve Cohen (D-TN)
Elizabeth Wydra, President, Constitutional Accountability Center

Congress v. Donald Trump Lawsuit in Violation of the Constitution’s anti-corruption Foreign Emoluments Clau... by Beverly Tran on Scribd

Trump, Donald J 2017 Financial Disclosure Report by Neetzan on Scribd

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CONYERS: Why I Am Suing President Trump

AMY GOODMAN: We turn right now back to Capitol Hill, which remains in shock after House Majority Whip Steve Scalise of Louisiana and four other people were wounded Wednesday when a gunman opened fire at a baseball field in Alexandria, Virginia, the lawmakers practicing for a charity congressional game that will take place tonight.

NERMEEN SHAIKH: We’re joined by the longest-serving member of Congress, Democrat John Conyers of Michigan. He’s served in Congress since 1965.

AMY GOODMAN: Congressman Conyers, welcome to Democracy Now! It’s great to have you back with us, but on a very sad day. Right now your fellow congressman, Steve Scalise, is in critical condition as a result of this shooting. The game will go on tonight, with Republicans and Democrats standing together. But your thoughts today?

REP. JOHN CONYERS: Well, I am deeply disturbed by Steve Scalise’s problems. And we are all praying for his speedy recovery and hope that this will all soon be past.

We’ve got an important commitment here, and I think it’s very important that emoluments are prevented from spoiling what should be an important consideration. The Constitution says no emoluments, gifts.

AMY GOODMAN: Congressman Conyers, let’s explain what it is that you’re talking about, since no one knew what the word "emoluments" was anyway. But it involves this lawsuit that you’re involved with against President Trump. You and nearly 200 congressmembers—

REP. JOHN CONYERS: Exactly.

AMY GOODMAN: —from the Senate and the Congress, 196 overall, are suing President Trump, accusing him of violating the Emoluments Clause of the Constitution by accepting millions of dollars in payments from foreign governments to Trump’s companies while serving as U.S. president, the lawsuit alleging Trump has accepted foreign emoluments, payments, which benefit him directly, without going to Congress first to get its consent. I want to turn to Elizabeth Wydra, who is president of the Constitutional Accountability Center, which filed the lawsuit on behalf of you and the 195 other members of Congress. This is what she says.

ELIZABETH WYDRA: President Trump has received billions of dollars from foreign governments leasing space in his properties, placing diplomats in his hotels. He has received very valuable trademarks from foreign governments. And this is just the tip of the iceberg, the benefits that we know that he’s received from foreign governments in violation of the Constitution. So what we need to do is have a transparent process. That’s what the Constitution envisions. That’s what it requires. And we’re going into court today to make sure that the president abides by the Constitution.

AMY GOODMAN: Among the violations cited in the lawsuit, Trump accepting intellectual property rights when he was granted trademarks by the Chinese government, and accepted payments from foreign governments by leasing space in his properties and placing diplomats in his hotels—representatives of Saudi Arabia, Turkey and Kuwait have all stayed at Trump International Hotel in D.C., which is located right near the White House—the lawsuit involving more congressional plaintiffs than any legal action ever taken against a president. Congressmember John Conyers, you are one of the leaders in this lawsuit. Why?

REP. JOHN CONYERS: Well, because it’s simply a constitutional violation that’s pure and simple, Amy. This is something that we can’t sit by and let happen as if it doesn’t matter. It does matter. And it’s not complicated or complex or anything else. And that’s why we have so many congressmen and senators working with us on it.

NERMEEN SHAIKH: And, Congressman Conyers, can you explain why it’s so significant that you say that Trump has violated the Emoluments Clause? Why is that so important?

REP. JOHN CONYERS: Well, it says that emoluments are money, benefits or other awards that can’t be used in the legislative process. Without the Emoluments Clause, Amy, the government and the lawmakers are subject to all kinds of offers, bribes, inducements. And so it’s really a waste of the democratic process if we don’t do something about it. And so, that’s why we are. We’ve got 160 congressmen and 30 senators, as well, all joined with us.

AMY GOODMAN: Now, so far, the 196 of you—you and Senator Blumenthal of Connecticut are leading the charge here in this lawsuit—are all Democrats. Among others, the president’s spokesperson, Sean Spicer, has said that these attacks on Trump around the Emoluments Clause are all partisan. Will any Republicans be joining your ranks in this lawsuit?

REP. JOHN CONYERS: We’ll find out today, because we’re inviting them to come in. We didn’t want to get in—we didn’t want to start off with a debate about what provisions should be allowed, what emphasis and how this should be written. We decided to just start with the people that we knew would join immediately. And now we’ll be working on Republicans. And we want them to come in. We hope that they—that some of them do. And I think a few of them will.

AMY GOODMAN: Well, it’s an honor to have you with us, Congressman John Conyers, representing Michigan’s 13th Congressional District, which includes Detroit, the current ranking member and former chair of the House Judiciary Committee. Thank you so much for joining us from the Capitol.

Congress v. Donald Trump Lawsuit in Violation of the Constitution’s anti-corruption Foreign Emoluments Clau... by Beverly Tran on Scribd

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