Tom DeLay Investigation Dropped

As everyone is undoubtedly aware, the Justice Department has told attorneys for Tom DeLay that its investigation into him has quietly ended. This is obviously very disappointing development to the ACR Blog, but it should not be interpreted as an exoneration of our former Congressman. There is some sort of partisan Rosarch test related to scandals involving elected officials. Typically, people only see scandal on the other side. Democrats will invariably deny that Bill Clinton's made false statements under oath since he was never held criminally accountable for that. Apologists on the other side will declare that Mr. DeLay's relationship with Jack Abramoff was above-board because he will not be held accountable for them.

One consultant to the ACR Blog has repeated told us that he appreciated the blog because the acts of many of the Congressional staffers in this scandal are documented most thouroughly on these pages. It was never the intent of the ACR Blog to be a court of law, but we did intend to collect facts about the players in this scandal. We're fully aware that for many of the staffers, a post on the ACR Blog could immediately top a Google search for that staffer. That fact instilled a great amount of responsibility for the author of this blog, and we believe we risen to the challenge.

Given the announcement about Mr. DeLay, the primary purpose of this blog has ended. Arguably, the purpose of this blog ended when Mr. DeLay announced his resignation back in April 2006. This blog has required an inordinate amount of time to maintain. Like a nicotine addiction, we've tried to end it more than once before without success. We plan a post on Mr. DeLay's comments this week that are inconsistent with things he's said in the past, and we've got a few unpublished posts that will likely come out in the next few days, but for the most part, like the Justice Department investigation, the blog is over.

As for the remaining criminal cases, we have mixed feelings about those, too. Fraser Verrusio is the only World Series defendant who refuses to hold himself accountable. (And we still wonder why he paid a female co-worker $300 for "shoe cleaning".) Since Mr. Verrusio refuses to hold himself accountable, we hope the Justice Department does.

Kevin Ring is a more complicated case. We believe that Mr. Ring's decision to go to trial stymied the Justice Department's investigation into Rep. John Doolittle (R-Calif.). On the other hand, Mr. Ring's behavior was objectively a lot less corrupt than some of his Greenberg Traurig co-workers who took a far more transactional approach to their lobbying work. Based on what we've read of Mr. Ring's book proposal, we actually do believe that he recognizes that his behavior crossed some sort of ethical line. Even though the ACR Blog believes the evidence is strong enough to convict Mr. Ring, we also acknowledge that reasonable people could come to the opposite conclusion. The ACR Blog was a place were the opposing sides could discuss these conflicting views without the typical ad hominem internet riff-raff. For that, we thank our readers and commenters. Our readers and commenters are what truly made the ACR Blog an informative site covering the Abramoff scandal.

The author of the ACR Blog still intends to monitor the remaining Abramoff-related cases (Kevin Ring exhibit list due tomorrow), but not with the same intensity and without writing about it.

Again, the author of the ACR Blog is humbled by the attention given to this blog by a wide variety of individuals. We wish to thank everyone who has given us documents, tips and encouragement. We may be biased, but we think that this blog uniquely covered the Abramoff scandal, and credit is due to the readers as much (if not more) than the author.

Thank you for a great 4-year run!

Greg
gregintx22-at-yahoo-dot-com

Status Report

From time to time, the ACR Blog likes to give a quick update on all Abramoff-related cases that have yet to reach sentencing ....

Ring, Kevin (1:08-cr-274-ESH)
Status: Mistrial; Retrial pending
Last action date: August 5, 2010
Next action date: August 20, 2010
Next action item: Government Exhibit List due

Verrusio, Fraser (1:09-cr-64-RWR)
Status: Pled not guilty
Last action date: August 12, 2010
Next action date: September 1, 2010
Next action item: Motions Hearing

Albaugh, John (1:08-cr-157-ESH)
Status: Guilty
Last action date: July 14, 2010
Next action date: October 21, 2010
Next action item: Status Conference

Blackann, Trevor (1:08-cr-325-RWR)
Status: Guilty
Last action date: May 24, 2010
Next action date: August 18, 2010
Next action item: Status Report

Boulanger, Todd (1:09-cr-25-RWR)
Status: Guilty
Last action date: July 27, 2010
Next action date: November 3, 2010
Next action item: Status Report

Copland, Ann (1:09-cr-43-RWR)
Status: Guilty
Last action date: June 8, 2010
Next action date: September 8, 2010
Next action item: Status Report

Hirni, James (1:08-cr-348-RWR)
Status: Guilty
Last action date: June 15, 2010
Next action date: September 13, 2010
Next action item: Status Report

Rudy, Tony (1:06-cr-82-ESH)
Status: Guilty
Last action date: July 29, 2010
Next action date: November 2, 2010
Next action item: Status Conference

Scanlon, Michael (1:05-cr-411-ESH)
Status: Guilty
Last action date: July 9, 2010
Next action date: October 14, 2010
Next action item: Sentencing

Zachares, Mark (1:07-cr-106-ESH)
Status: Guilty
Last action date: July 22, 2010
Next action date: November 22, 2010
Next action item: Sentencing

Bingo, Bango, Bongo!

1994 Region II Playoffs
John Tyler v. Plano East

Our favorite season of the year is football season. With the 2010 football season upon us, we'd like to share the best game of all time, OF ALL TIME, with you.

We pick up the action with 2:42 left in the game and John Tyler (white) leading Plano East (black) 41-17. Since we're sharing the game with you, which team do you think won? You're probably wrong.

Mark Zachares and the New HSF

Mark Zachares
Over the past few posts, we've discussed the post-Skilling world of Honest Services Fraud (HSF). Today, we use our knowledge to examine how this affects Mark Zachares, a former aide to Rep. Don Young (R-Ak.) who has pleaded guilty to HSF related to the Abramoff scandal.

A couple of weeks ago, Roll Call's Jennifer Yachnin wrote an article highlighting how the Kevin Ring case will shape HSF. Ms. Yachnin reported that Zachares' attorney says his client may want to challenge the "validity" of his plea deal:

Zachares’ defense attorney, Ed MacMahon, raised questions last week over the validity of his client’s plea agreement and sought permission to submit a brief to the court on the issue.

“We couldn’t sentence Mr. Zachares for something that after Skilling wouldn’t be a crime,” MacMahon said.

To our knowledge, Mr. MacMahon has not yet briefed the court on this matter; it isn't even clear that U.S. District Judge Ellen Huvelle has authorized such a brief. The ACR Blog is very curious about the legal arguments that Mr. MacMahon intends to raise. Mr. MacMahon's statements were made before Judge Huvelle determined that a jury may infer a corrupt agreement based on the evidence. Mr. MacMahon would likely try a different course of action due to that decision.

In the meantime, let's see if we can infer a corrupt agreement based on Mr. Zachares' Factual Basis for Plea (Paragraph 11).

ZACHARES joined a conspiracy involving Abramoff and others, using mail and interstate wire communications, to deprive the public of the honest services of ZACHARES. That is, ZACHARES solicited and accepted a stream of things of value from Abramoff and others with the intent to be influenced in his official actions and to agree to take official actions at Abramoff s request. Abramoff and others provided the stream of things of value knowing that it was received by ZACHARES with the intent to be influenced in his official action and to deprive the House of Representatives and the public of his honest services.

Given that Mr. Zachares admits that he "accepted a stream of things of value from Abramoff and others with the intent to be influenced in his official actions and to agree to take official actions at Abramoff s request", a reasonable jury could infer that an agreement existed. In fact, it seems to us that Mr. Zachares' Factual Basis actually says that an agreement existed.

The Justice Department undoubtedly plans to support Zachares' HSF conviction. Even Judge Huvelle suggests that Mr. Zachares should consider alternatives to vacating his plea:

Huvelle noted that Zachares could select from a range of options, including vacating his plea or amending the agreement.

“There are ways to redo something like this simply,” Huvelle said.

The judge raised the possibility that Zachares could even enter a plea related to his financial disclosure forms if he failed to accurately report gifts or other items.

“There are a lot of ways you can address this,” she later added.

We'll continue to monitor this case for any developments. Mr. Zachares is currently scheduled to be sentenced on November 22, 2010.

A Corrupt Agreement

[B]ribery requires a specific intent to give or receive something of value in exchange for an official act. We note that evidence of a quid pro quo can be implicit, that is, a conviction can occur if the Government shows that [the defendant] accepted payments or other consideration with the implied understanding that he would perform or not perform an act in his official capacity. As we have recognized, the official and the payor need not state the quid pro quo in express terms, for otherwise the law’s effect could be frustrated by knowing winks and nods.

--U.S. v. Kemp (p. 41); Case law cited with approval in Skilling v. United States. Internal citations and quotes omitted.

===
For the past few days, we've examined the post-Skilling environment for Honest Services Fraud (HSF) with an emphasis on how Skilling affects U.S. v. Kevin Ring. We've learned that although the Supreme Court's decision in Skilling found HSF cases built on a Failure-to-Disclose a conflict of interest to be unconstitutional, the top court's opinion hasn't created any visible changes to HSF involving bribery and kickback schemes. U.S. District Judge Ellen S. Huvelle has ruled that a jury may infer that Mr. Ring entered into a corrupt agreement with public officials based upon the evidence -- the government need not show an explicit corrupt agreement.

Today we look at the plea documents of two public officials, Ann Copland and John Albaugh, to see if we can infer that the public officials themselves understood that things of value (TOVs) were being exchanged for official acts.

Ann Copland

From Ms. Copland's Factual Basis for Plea (Paragraph 5):

[F]rom March 2002 through May 2004, defendant COPLAND took and agreed to take a variety of official actions at the request of Abramoff, Boulanger, Ring and others working with them. Defendant COPLAND took these official actions based in part on the fact that she was receiving and wanted to continue receiving things of value from Abramoff, Boulanger, and Ring. Defendant COPLAND understood that by taking official action which was beneficial to the lobbyists and their clients, she would continue to receive and enjoy these things of value. Defendant COPLAND also understood that the lobbyists were providing her things of value in order to influence her in the performance of her official actions.

Uhh. Not a whole lot of inferring need be done here. Ms. Copland admits that she "understood" that the TOVs were dependent on her performance of official acts.

John Albaugh

OK. So Ms. Copland's Factual Basis lined up nicely to prove our point. What about Mr. Albaugh's Factual Basis (Paragraph 8)?

ALBAUGH solicited and accepted a stream of things of value from Lobbyist C [Kevin Ring] and others with the intent to be influenced in his official actions and to agree to take official actions at Lobbyist C's request. ALBAUGH understood Lobbyist C and others provided the stream of things of value with the intent to influence or reward ALBAUGH for his official actions and to deprive the House of Representatives and the public of his honest services.

Did that say Mr. Albaugh accepted TOVs with the intent to agree to take official actions? Ouch. And again, we don't have to infer that Mr. Albaugh "understood" that TOVs were meant to influence or reward his official acts -- he admits it.

===
Judge Huvelle's interpretation of the law was consistent with precedent when she determined that a jury could infer that Mr. Ring entered an agreement to exchange TOVs for official acts. This should be pretty easy for the jury to do. After all, Mr. Ring's co-conspirators admit that they understood that the TOVs were linked to official acts.

Appealing HSF Convictions

The Washington Post's Amanda Becker writes that many Honest Services Fraud (HSF) defendants would, unsurprisingly, like to use the Supreme Court's recent Skilling decision to evade accountability:

The Supreme Court's decision earlier this summer to narrow the scope of a federal law often used by prosecutors to target fraud has led to a string of dropped charges and new trials in "honest services" cases that will likely keep area white-collar practices busy.

The court in Skilling v. United States ruled that a provision in a 1988 federal wiretap statute that criminalizes any scheme to "deprive another of the intangible right of honest services" was unconstitutionally vague. Rather than strike down the law, the justices redefined it as applying to cases involving bribes and kickbacks and sent the three honest-services appeals it considered back to lower courts. Now, others convicted of honest-services fraud and those still awaiting trial are asking courts to reconsider their cases.

"You're going to see a flurry of people trying to reopen their cases," said Amy R. Sabrin, a partner in Skadden, Arps, Slate, Meagher & Flom's Washington office.

We know that Kevin Ring didn't find any relief in Skilling. The only other defendant we're aware of who has tried to find solace in Skilling is Mark Zachares. An anonymous reader provided the text of a Roll Call article about the Zachares case in the comments of this post:

Zachares’ defense attorney, Ed MacMahon, raised questions last week over the validity of his client’s plea agreement and sought permission to submit a brief to the court on the issue.

“We couldn’t sentence Mr. Zachares for something that after Skilling wouldn’t be a crime,” MacMahon said.

Huvelle noted that Zachares could select from a range of options, including vacating his plea or amending the agreement.

“There are ways to redo something like this simply,” Huvelle said.

The judge raised the possibility that Zachares could even enter a plea related to his financial disclosure forms if he failed to accurately report gifts or other items....

In an apparent reference to other outstanding plea agreements, Huvelle also twice encouraged (federal prosecutor Richard) Pilger to be “creative” and suggested the government should avoid using the same tactic in each of the honest service cases to avoid a domino effect should a higher court reject any District Court ruling.

Our reading of this article suggests that Judge Huvelle is not prepared to toss out Zachares' plea. Not only did Judge Huvelle suggest several alternatives to vacating the plea, she also encouraged the DoJ to employ several different tactics in dealing with HSF plea agreements to make sure that at least some survive the appeals process.

The ACR Blog believes that the popular perception of Skilling's impact is a bit flawed. Last year, we described two distinct varieties of HSF: (1) The Bribery Theory; and (2) The Failure-to-Disclose a Conflict of Interest Theory. In Skilling, the Supreme Court found the Failure-to-Disclose a Conflict of Interest Theory to be unconstitutionally vague. In contrast, the Supreme Court specifically said that HSF cases could be based upon bribery and kickback schemes. All Abramoff-related HSF cases involve bribery and kickback schemes. Ms. Becker is correct that the Supreme Court "narrow[ed] the scope" of HSF, but this primarily means that cases can no longer be built on the Failure-to-Disclose theory of HSF. The impact on bribery/kickback HSF isn't so great.

This isn't to say that Skilling can't touch bribery and kickback HSF. Defense lawyers are now questioning what bribery means in a "bribery scheme". Last week's denial of Kevin Ring's Motion for Judgment of Acquitally was the first on-topic substantive decision of the contours of post-Skilling HSF. Judge Huvelle accepted the DoJ's position on what constitutes HSF bribery. Her decision against Mr. Ring and her comments in Mr. Zachares' case suggest that Abramoff scandal defendants will have an uphill battle in escaping justice based on Skilling. While the Supreme Court found Failure-to-Disclose HSF unconstitutional, bribery/kickback HSF, up until this point, has remained unchanged.

===

COMING SOON: A review of plea documents of a few individuals convicted of HSF to determine if we can infer a corrupt agreement to exchange things of value for official acts.

Character Matters

Regular readers know that the author of the ACR Blog was a McCainiac in 2008. At that time, we listed our top voting issues:

1. Integrity and Character ...
2. National Security (win the War on Terror)
3. Fiscal policy (lower spending and growth-oriented tax cuts -- I'm a supplysider)

I'm pro-life and pro-immigration.

As a result, it shouldn't be a surprise that Sen. John McCain's latest campaign ad against Abramoff "Republican" J.D. Hayworth appeals to us.



Yes indeed. Character matters.

Quid pro Quo Agreement

Kevin Ring
July 1, 2000

Kevin Ring's defense team has argued that the government must prove that Mr. Ring entered into a corrupt agreement to exchange things of value (TOVs) for official acts. Without such an agreement, the defense says, the government cannot prove Mr. Ring had corrupt intent and he must be found not guilty.

Last week, U.S. District Judge Ellen S. Huvelle rejected Mr. Ring's argument. She said that a jury could "infer" a bribery-style quid pro quo agreement from the evidence.

Let's review some of the evidence on which such an inference could be drawn:

1. A March 14, 2002 email from Mr. Ring to John Albaugh, a staffer to Rep. Ernest Istook (R-Okla.):

You're going to eat free off of our clients. Need to get us some abstinence money.¹

:::
2. A February 10, 2004 email from Mr. Ring to Laura Blackann, a staffer to Rep. John Doolittle (R-Calif.). Mrs. Blackann had been helping Mr. Ring with some tax legislation benefiting a Team Abramoff Client:

Mrs. Blackann: [J]ust earning my Sigs^[*] Sushi ;)
Mr. Ring: Exactly. I will keep you occupied.
Mrs. Blackann: Keep it coming -- this is the fun stuff.

[*] This is an apparent reference to Signatures, the restaurant owned by Jack Abramoff.
:::
3. A March 16, 2002 email from Mr. Ring to a fellow Team Abramoff lobbyist who had treated Justice Department official David Ayers to an NCAA basketball tournament game. Mr. Ring needed Mr. Ayers' assistance in securing funding for the full $16.3 million grant for the Choctaw jail:

Glad he got a chance to relax. Now he can pay us back.

:::

One simple question, gentle readers: Do you infer than Mr. Ring intended to exchange things of value for official acts?

===

¹ The above wording comes from the Kevin Ring indictment (paragraph 33). Another government filing (p. 2) offers this slightly different verbiage: “You are going to eat free off our clients. Now get us some abstinence money.”

Kevin Ring Suffers Devastating Legal Setbacks

Channing Turner of Main Justice is the first to report on a hearing today in U.S. v. Kevin Ring:

A judge denied a motion to dismiss the heart of the government’s corruption case against former Abramoff-associate Kevin Ring Thursday, clearing the way for prosecutors to proceed to a second trial.

In a motion filed last month, Ring had argued new restrictions imposed on prosecutors’ use of the honest services fraud statute made their case untenable. But U.S. District Judge Ellen Segal Huvelle of the District of Columbia disagreed with a whole-sale dismissal.

In our opinion, the reports from today's proceeding suggest that Judge Huvelle had a whole-sale disagreement with Mr. Ring's legal defense. Here are a couple of things we gleaned from today's hearing:

Quid pro Quo Agreement

[Judge Huvelle] rejected the defense’s argument that prosecutors must prove direct quid-pro-quo exchanges — the new criteria for honest services fraud. Instead, she allowed prosecutors to present evidence that could “infer” a quid-pro-quo exchange.

The prosecution and defense presented two different theories on the government's requirement to show a quid pro quo exchange. The defense insisted that in order to show a quid pro quo arrangement that the government was required to show an explicit agreement to exchange things of value (TOVs) for official actions. The defense claims that Mr. Ring and the public officials he lobbied never made such an explicit agreement. The government says that its evidence shows that such an agreement in fact did exist. In more than one plea agreement signed by public officials (John Albaugh, Ann Copland), the public officials admit performing official acts for TOVs. To our knowledge, no public official has stated that an explicit agreement existed, though.

When Judge Huvelle says that a jury may "infer" a quid pro quo exchange, she seems to be saying that a jury could infer that an implicit quid pro quo agreement existed and that this implicit agreement is sufficient to support an Honest Services Fraud (HSF) conviction. The jury may even conclude that an explicit quid pro quo agreement existed even though no one will admit to it. Either way, Judge Huvelle's ruling means that the government doesn't have to provide documents or solicit testimony that Mr. Ring explicitly tied TOVs to official acts.

Material Misrepresentation

[Judge Huvelle] pointed to the [Supreme] court’s silence on material [mis]representation — or intent to deceive the public — which she said could be expanded to include Ring’s alleged actions.

Fraud cases, including HSF, require an element of material misrepresentation or intentional concealment. In other words, in order to support a fraud conviction, the government must show that the defendant lied by commission (material misrepresentation) or omission (intentional concealment).

The defense has argued that Mr. Ring never committed an act of material misrepresentation. Mr. Ring, they argue, performed his lobbying activities out in the open and did not deceive anyone. Therefore, the government can't show the element of material misrepresentation and can't prove a violation of HSF.

The government counters that it will show material misrepresentation. Specifically, the government says it will show that Mr. Ring's bribery scheme involved "public officials who made material misrepresentations, concealed or omitted material facts, made false statements, or committed fraudulent pretenses as part of the scheme to defraud."

See what's going on here? The government's position is that there had to be a material misrepresentation in the bribery scheme, not that Mr. Ring personally made the material misrepresentation.

Unfortunately, today's reporting doesn't make it clear where Judge Huvelle sees a potential material misrepresentation. We're guessing that Judge Huvelle accepted the government's position in its entirety. It seems to us that the public officials made the material misrepresentation (or intentional concealment) when they did not disclose that the reason they were performing official acts was due to the fact that they were receiving things of value from Mr. Ring. If this is accurate, virtually all bribery schemes satisfy the material misrepresentation element; we can't imagine the situation where a public official openly acknowledges that his performance of an official act was largely influenced by bribes. We shall see.

:::

While we maintain that Judge Huvelle's decisions were devastating to Mr. Ring, we don't mean to imply that they weren't close calls. We believe they were. These are complicated legal matters -- Judge Huvelle even said as much. Both of today's decisions must have been difficult to make. As Judge Huvelle said in court today, "This case is filled with challenges ... We have excellent lawyers who don’t agree on anything."

Meanwhile, more definitional challenges remain. Mr. Turner reports that "prosecutors must prove Ring and the public officials he interacted with violated their “lawful duty” to the public — a term Huvelle and both counsels struggled to define." We won't even venture a guess as to how "lawful duty" will eventually be defined. The judge and attorneys in this case are far smarter than the author of this blog. We'll let them have first shot at solving that problem.

Legal Juggernaut Leads Prosecution of PMA Figure

When the U.S. Department of Justice prosecutes its toughest cases, it sends in its toughest prosecutors. This afternoon, we came across this Justice Department press release:

WASHINGTON – Paul Magliocchetti, the founder and president of PMA Group Inc. (PMA), a lobbying firm in Arlington, Va., was arrested today on charges of making illegal campaign contributions and making false statements to a federal agency, announced Assistant Attorney General Lanny A. Breuer of the Criminal Division, U.S. Attorney Neil H. MacBride of the Eastern District of Virginia and Assistant Director Shawn Henry of the FBI’s Washington Field Office.

A federal grand jury returned the indictment on Aug. 4, 2010, which was unsealed today in U.S. District Court in Alexandria, Va., following Magliocchetti’s arrest by FBI agents. He will make an initial appearance this afternoon before U.S. Magistrate Judge T. Rawles Jones Jr., in federal court in Alexandria.

Good. The DoJ had to pursue criminal charges in the PMA Group case. The PMA Group corruption is the most significant since Team Abramoff's activities.

We had to hang around until the second-to-last paragraph to notice this, though:

This case is being prosecuted by Trial Attorneys M. Kendall Day, Justin V. Shur and Kevin O. Driscoll of the Criminal Division’s Public Integrity Section, and by Assistant U.S. Attorney Mark D. Lytle of the U.S. Attorney’s Office for the Eastern District of Virginia. The case is being investigated by the FBI.

Emphasis added

M. Kendall Day, huh? We wondered what that paragon of justice was up to. It is good to see Mr. Day take the lead on another high profile corruption case.

While we obviously wish Mr. Day all the best on his new assignment, we are simultaneously concerned. The resources allocated to prosecuting the Jack Murtha fork of corruption are well spent. We just hope that this doesn't mean that the DoJ is giving up on our cases.

Don Young Walks

Richard Mauer of the Anchorage (Ak.) Daily News is the first to report that Abramoff Republican Don Young (R-Pork Barrel) has escaped accountability:

Rep. Don Young's office has announced that the long-running criminal investigation of him by the FBI and the U.S. Justice Department's Public Integrity Section has concluded and that no charges will be filed.

Meredith Kenny, the press secretary for Young, R-Alaska, said Young's attorneys in Washington received a call this morning that the Justice Department had decided against prosecuting Young.

We've been disappointed with the Public Integrity Section a lot lately, and this news just continues that bad experience. While nearly every House Republican has shunned Washington's big-spending ways by embracing a voluntary ban on earmarks, Mr. Young is one of four Republicans unable to give up the destructive practice cherished by Kevin Ring and the rest of Team Abramoff. (Brazoria County Rep. Ron Paul, R-Brazosport, is another of the four who can't give up the addiction.)

A year ago, when Mr. Young announced his re-election bid, we hoped that Alaskans wouldn't nominate the flawed Congressman. Mr. Young is being challenged by a Tea Party candidate Sheldon Fisher, but a recent poll suggests that Mr. Fisher's candidacy is a long shot. If we were a member of the Alaska electorate, we know that we'd cast our ballot for Mr. Fisher.



From his support for fiscal responsibility to his personal commitment to ethics, there's a lot to like about Mr. Fisher.

Despite this undesirable development, the ACR Blog notes that our own former Congressman, Tom DeLay (R-corrupt Ft. Bend County) hasn't preened that the DoJ has declined to prosecute him. We infer that the Public Integrity Section is keep that door open .... for now.

:::

***UPDATE***
9:58 p.m. CDT

An email from Don Young's campaign has been forwarded to us. Sara Schwan, Mr. Young's campaign manager, gloats that her boss has evaded accountability. She also writes:

If you’d like to wish the Congressman well in his upcoming primary, he will be at the Alaska Republican Party picnic tomorrow from 5pm to 8pm at the Kincaid Outdoor Center, 9401 W. Raspberry Road, Anchorage.

An Anti-Corruption operative tells us that he hopes to attend. Let's hope he has a good digital camera!

:::

***UPDATE***
August 5, 2010

Our Anti-Corruption operative in Alaska submits the following photo from today's event to the ACR Blog. Our source tells us that Don Young appeared to be a happy man as the two shook hands. Smart money says our operative is still unlikely to vote for the Abramoff-linked Young.