HomeMy WebLinkAbout1-L McCombsIn Re: Leslie McCombs,
Respondent
File Docket:
X -ref:
Date Decided:
Date Mailed:
Before: Louis W. Fryman, Chair
John J. Bolger, Vice Chair
Donald M. McCurdy
Nicholas A. Colafella
Mark Volk
07 -001 L
Order No. 1 -L
7/22/09
8/4/09
This is a final adjudication of the State Ethics Commission.
Procedurally, the Investigative Division of the State Ethics Commission conducted
an investigation regarding possible violation(s) of Pennsylvania's lobbying disclosure law
( "Lobbying Disclosure Law "), 65 Pa.C.S. § 13A01 et seq., by the above -named
Respondent. At the commencement of its investigation, the Investigative Division served
upon Respondent written notice of the specific allegations. Upon completion of its
investigation, the Investigative Division issued and served upon Respondent a Findings
Report identified as an "Investigative Complaint." An Answer was filed and a hearing was
requested by the Investigative Division. A Stipulation of Findings and a Consent
Agreement waiving an evidentiary hearing were subsequently submitted by the parties to
the Commission for consideration. The Stipulated Findings are set forth as the Findings in
this Order. The Consent Agreement has been approved.
This adjudication of the State Ethics Commission is issued under the Lobbying
Disclosure Law and will be made available as a public document thirty days after the
mailing date noted above. However, reconsideration may be requested. Any
reconsideration request must be received at this Commission within thirty days of the
mailing date and must include a detailed explanation of the reasons as to why
reconsideration should be granted in conformity with 51 Pa. Code § 21.29(b). A request
for reconsideration will not affect the finality of this adjudication but will defer its public
release pending action on the request by the Commission.
The files in this case will remain confidential in accordance with the Lobbying
Disclosure Law.
McCombs, 07 -001 L
Page 2
I. ALLEGATIONS:
That Leslie McCombs, in her capacity as a lobbyist, violated Section 13A01 et seq.
of the Lobbying Disclosure Law, 65 Pa.C.S. § 13A01 et seq., when she failed to register as
a lobbyist for Lionsgate, a California production company, and subsequently engaged in
lobbyist activities before the Pennsylvania General Assembly and /or the Pennsylvania
Governor's Office on behalf of Lionsgate; and when she filed a deficient Lobbyist
registration form for the University of Pittsburgh Medical Center.
II. FINDINGS:
1. Leslie Merrill McCombs has been employed by the University of Pittsburgh Medical
Center (UPMC) since March 7, 2005.
a. McCombs held the position of Director of Public Relations for UPMC Health
Plan from March 7, 2005, until approximately May 2006.
b. McCombs has held the position of Senior Consultant with the Government
Relations Department of UPMC [from] approximately May 2006 through the
present.
2. In 2007, while in the position of Senior Consultant, McCombs began serving as a
lobbyist for UPMC.
a. McCombs' compensation as a lobbyist for UPMC for the year 2007 exceeded
$2,500.00 by January 26, 2007.
3. As a lobbyist for UPMC in 2007, McCombs was required to register with the Division
of Lobbying Disclosure of the Pennsylvania Department of State pursuant to the
requirements of the Lobbying Disclosure Law.
4. McCombs filed a Lobbyist Registration Statement as a lobbyist for UPMC on
January 8, 2007.
a. The registration confirmed McCombs lobbying on behalf of UPMC effective
January 2, 2007.
b. McCombs was assigned Registration No. L00513.
5. McCombs listed the principal(s) she represented on the Lobbyist Registration
Statement filed on January 8, 2007, as follows:
a. University of Pittsburgh Medical Center
200 Lothrop Street Forbes Tower Ste. 10013
Pittsburgh, PA 15213
1. McCombs did not list a daytime telephone number for UPMC on her
registration statement.
2. This deficiency resulted in the Division of Lobbying [Disclosure]
deeming the filing as incomplete.
3. Staff of the Division of Lobbying [Disclosure] attempted to have the
issue corrected, but McCombs did not reply to contacts made by that
department.
6. Dawn Keezer serves as the Director of the Pittsburgh Film Office (PFO).
McCombs, 07 -001 L
Page 3
a. The Pittsburgh Film Office is a 501 (c)(3) non - profit corporation that provides
support to a 10 county area of Southwestern Pennsylvania in helping to
facilitate film, television, and video productions.
b. Keezer is the main point of contact for the PFO in dealing with the film
industry.
c. Keezer as the Director is responsible for attracting film companies to
produce movies and television series in the Pittsburgh region.
7 In or around the summer of 2006 Keezer contacted Mark Manuel of Lions Gate
Entertainment Corp. (Lionsgate) regarding the potential of Lionsgate filming
projects in the Pittsburgh region.
a. Manuel serves as Executive Vice - President for Structured Finance with
Lionsgate.
8. Lionsgate, a Canadian entertainment company, was founded in Vancouver, British
Colombia, and is now headquartered in Santa Monica, California.
a. Lionsgate produces motion pictures, television programming, home video,
family entertainment, video -on- demand, and digital distribution.
9. During discussions Keezer had with Manuel about filming projects in Pittsburgh, a
film tax credit in Pennsylvania similar to a tax credit program in the state of New
Mexico was discussed.
a. In 2006 the State of New Mexico passed a 25% tax rebate on all direct
production expenses for feature films, television, regional and national
commercials, documentaries, video games and post production.
1. There was no minimum spending requirement, no cap and no sunset
clause.
b. Manuel informed Keezer that if Pennsylvania had a similar program, the
state would become more desirable to the film industry.
10. Manuel met with Keezer in Pittsburgh during the summer of 2006 to determine if a
meeting could be arranged with Governor Edward Rendell to discuss a film tax
credit.
a. Manuel was interested in filming both a television series and a major motion
picture in the Pittsburgh area, but wanted tax credits similar to those being
offered by New Mexico.
11. In order to expedite a meeting with Governor Rendell, Keezer contacted Leslie
McCombs to obtain assistance in arranging a meeting with Governor Rendell.
a. Keezer requested the assistance of McCombs because of McCombs'
friendship with Governor Rendell.
b. Keezer and McCombs were friends, and as a result of that friendship,
Keezer became aware that McCombs was a friend of Governor Rendell and
had his personal cellular telephone number.
c. Keezer introduced McCombs to Manuel during a Manuel visit to Pittsburgh.
McCombs, 07 -001 L
Page 4
12. In or around October 2006, McCombs helped to arrange a meeting with Governor
Rendell which included McCombs, Dawn Keezer, Mark Manuel, and Sharon
Pinkenson, Executive Director of the Philadelphia Film Office.
a. The meeting occurred in Philadelphia.
b. The discussion at the meeting included the grant fund program to support
film and television production activities in Pennsylvania and a film tax credit.
13. On October 19, 2006, a press conference was held in Pittsburgh, Pennsylvania,
announcing the launch of the Lionsgate partnership in Pittsburgh; amongst those in
attendance were: McCombs, Keezer, Pinkenson, Manuel, Jane Saul, Director of the
Pennsylvania Film Office, Allegheny County Chief Executive Dan Onorato and
Pittsburgh Mayor Luke Ravenstahl.
a. Keezer personally thanked McCombs for her assistance in developing the
partnership.
14. In October 2006, following the meeting with Governor Rendell, Lionsgate decided to
film an eight part mini - series in the Pittsburgh area titled, "Kill Pit."
15. On October 10, 2006, Governor Rendell sent a letter to Mark Manuel regarding
Lionsgate Productions in Pittsburgh and noted the following:
a. If re- elected, the Governor would propose increasing the film grant program
during budget negotiations from $10 million to $20 million.
b. If Governor Rendell was successful in increasing the film grant program, he
was committing up to $3.5 million to support Lionsgate production activities
in the City of Pittsburgh.
c. Governor Rendell offered a grant to Lionsgate in the amount of $100,000 to
help defray costs of production.
16. Subsequently on November 28, 2006, J. Mickey Rowley, Deputy Secretary for the
Department of Community and Economic Development (DCED) advised Mark
Manuel by letter of funding that would be provided through the Pennsylvania Film
Production Grant Initiative.
a. Rowley advised Manuel that his application dated September 7, 2006, for
Creativity in Focus Grant had been preliminarily approved for $437,186,
which represented 20% of their projected production expenses in
Pennsylvania for the first episode.
1. The grant was for the television series Kill Pit.
17. McCombs continued to assist Lionsgate throughout the remainder of 2006 and into
2007.
a. McCombs assisted Lionsgate in securing filming locations in Pittsburgh and
with street closings when filming for Kill Pit began.
b. McCombs also assisted Lionsgate in obtaining state funding for Kill Pit,
which was the subject of the Rowley letter dated November 28, 2006.
1. In an e-mail dated February 15, 2007, to UPMC CEO Jeffrey Romoff,
McCombs, 07 -001 L
Page 5
McCombs advised in part:
... I've already assisted them (Lionsgate) with obtaining state funding
which has enabled them to produce Pittsburgh's first television
services, Kill Pit, which will begins [sic] shooting on March 21.
c. McCombs also met with and discussed with Manuel strategies to obtain a
film tax credit from the Commonwealth.
18. On January 12, 2007, Mark Manuel sent an e-mail to McCombs, Dawn Keezer and
John Valentine, a Production Finance Analyst with Lionsgate, concerning his
agenda for a proposed Pittsburgh visit.
a. Manuel was to be in Pittsburgh February 5, 2007, through February 7, 2007,
and would be traveling with John Valentine.
b. Manuel's agenda as outlined in the e -mail included the following:
1. Check on production.
2. Follow -up meetings on the approach to a film fund as he was going to
invite Mickey Rowley of DCED.
3. Work with Leslie and Dawn on drafting the parameters of the
Pennsylvania /New Mexico treaty.
4. Work with McCombs and Keezer on assisting with the language on
the legislation for the new film tax credit.
19. Manuel's January 12, 2007, e-mail also included the following regarding McCombs
lobbying the Governor on behalf of Lionsgate for the film tax credit:
Leslie, I know Gary is going to see the Governor before this date, if it is OK
with you we would rather have you and Dawn present the details of treaty
and the overall scope of the Lionsgate biz in Penn to the Governor (after we
have a chance to sit down and discuss these things with both of you on the
next trip).
The treaty is a corporate initiative I am working on with our Vice - Chairman
directly with Bill Richardson of which Gary is not that involved with (as Gary
is strictly a TV exec). I have full confidence you will relay to the Governor
the right message after we download it to you.
20. On January 12, 2007, a Certificate of Organization was filed with the Corporation
Bureau with the Pennsylvania Department of State on behalf of McCombs for LHLT,
LLC, a limited liability company.
a. The limited liability company was established for Leslie McCombs by the law
firm Eckert, Seamans, Cherin & Mellott, LLC.
b. McCombs was listed as the President of the LLC.
c. The address for LHLT, LLC was identified as [an address used by] Leslie
McCombs.
d. McCombs used LHLT, LLC as the entity for Lobbying activities on behalf of
Lionsgate.
McCombs, 07 -001 L
Page 6
21. On January 19, 2007, McCombs sent an e-mail to Jeffrey Romoff, President and
CEO of UPMC and carbon copies to various officials of UPMC including Robert
Cindrich, Chief Counsel regarding the Lionsgate TV series and to confirm that she
helped Lionsgate with some state funding and other issues.
22. Manuel sent e-mails to McCombs on January 23, 2007, and again on January 25,
2007, regarding efforts to secure a film tax credit in Pennsylvania.
a. On January 23, 2007, Manuel sent an e-mail to McCombs and Keezer
attaching the New Mexico legislation for that state's film tax credit program.
1. The purpose of Manuel forwarding the New Mexico legislation to
McCombs was to assist McCombs in advancing that tax credit in
Pennsylvania.
b. On January 25, 2007, Manuel sent an e-mail to McCombs and Keezer with
suggestions that should be made to Governor Rendell on the proposed film
tax credits for Pennsylvania including:
1. A 30% transferable credit.
2. No Cap as you cannot implement a cap with a transferable tax credit.
3. Suggested putting a sunset provision of 3 years to make sure this
works for both the State and film companies.
4. If the new legislation was deemed to be attractive, Lionsgate would
be happy to join press releases with Governor Rendell and affirming
the attractiveness of the new program and their desire to produce in
Pennsylvania over the long term.
23. On January 25, 2007, McCombs sent an e-mail to Manuel and Keezer advising that
McCombs was giving the information regarding the film tax credits to Governor
Rendell on that date.
a. As of this date McCombs had already registered as a Lobbyist for UPMC
and had been compensated in excess of $2,500.00 by UPMC.
24. By February 2, 2007, Lionsgate established a corporation in Pennsylvania for
purposes of filming the TV Series "Kill Pit."
a. Articles of Incorporation were established under the name Kill Pit
Productions on February 2, 2007.
25. Between February 5 and 7 of 2007, McCombs had meetings along with Keezer,
Manuel and Valentine of Lionsgate regarding the film tax credit.
26. By February 14, 2007, Manuel and McCombs had more discussions finalizing
McCombs' role as a lobbyist on behalf of Lionsgate. On February 14, 2007, Manuel
directed an e-mail to McCombs which included the following:
First off, I will try and send you the legislative proposal today for the new PA
entertainment tax credit.
Have you heard whether or not you can be hired as a "supervisory lobbyist"
by Lionsgate?
McCombs, 07 -001 L
Page 7
For the 27 I hope I am going to see you in PhiIly, I definitely want to be at
the premiere.
Seats are scarce so I need everyone's names down. So far I have you (plus
1), Dennis (plus 1) and the Governor (plus 4).
Is there anyone else I absolutely need to have on the list? I was not sure if
Dawn was going to be in Philly.
a. The term "supervisory lobbyist" was used by Manuel and McCombs to
describe McCombs' role as a lobbyist for Lionsgate.
27. McCombs sought authorization from UPMC CEO and President Jeffrey Romoff to
serve as a Lobbyist for Lionsgate in an e-mail dated February 15, 2007, which
included the following:
As per our conversation, an opportunity has arisen with Lionsgate, the
largest independent producer and distributor of motion pictures and
television in the country. As I mentioned to you I've already assisted them
with obtaining state funding, which has enabled them to produce Pittsburgh's
first television series, Kill Pit, which will begin shooting on March 21. (UPMC
signs will be prominently featured throughout the series.) By the way, this
will economically impact the city with approximately 100 -150 million.
I've also assisted them with locations, negotiating contracts, introducing
them to Dan and Luke, setting up bank account, etc... just with a few phone
calls and a Pitt basketball game... (nights and weekends only.)
There are some additional changes to be made with the PA entertainment
tax credits, in order for them to be able to call Pennsylvania home for many
other projects, much larger than Kill Pit. They have offered me a full time
job, in which I am not interested. They have also asked me to be their
lobbyist, and of course I told them that I wouldn't have time to do that. And
since they've insisted on compensating me for the work I've done thus far,
and they know that I can probably get the legislation changed without too
much effort, they would like to pay me to be a "supervisory lobbyist." They
would hire someone else in Harrisburg, and I would be available to this
person in a very minimal supervisory role. I would be able to do this on my
own time, as I have done thus far, and there would be no conflicts with
UPMC.
I will await your advice.
28. On February 15, 2007, Romoff sent McCombs an e-mail advising McCombs that
after conferring with legal counsel, it was Romoff's belief that it would not be a
conflict.
29. On February 15, 2007, McCombs sent Manuel an e-mail advising him that it was
permissible for McCombs to accept the lobbyist supervisor position.
a. McCombs also informed Manuel that she was meeting with the Governor at
2:00 p.m. to confirm the 27 .
1. On February 27, 2007, the movie "Pride" premiered in Philadelphia
where various officials from Lionsgate, including Mark Manuel, were
present along with Pennsylvania officials, including Governor
McCombs, 07 -001 L
Page 8
Rendell, and McCombs.
30. On March 1, 2007, Mark Manuel sent an e-mail to McCombs that included
attachments of a draft lobbying contract between McCombs and Lionsgate, and
attachments outlining legislative objectives Lionsgate wanted to pursue in
Pennsylvania.
31. The Memorandum of Agreement dated March 1, 2007, between Leslie McCombs,
LHLT, LLC and Mark Manuel, Lionsgate contained the following language:
This Agreement is between Leslie Merrill McCombs (LHLT, LLC) and
Lionsgate Entertainment (Client). Ms. McCombs will lobby legislation for
Client from March 1, 2007 through February 29, 2008 at the Pennsylvania
Legislature on matters pertaining to the motion picture industry, taxes and
other matters. Ms. McCombs will be paid [for her lobbying services] plus
reasonable out pocket [sic] expenses, pre- approved by Lionsgate, for all
services rendered for Client as result of this agreement. Payments are to be
paid as follows:
2 equal payments . payable in March and April 2007. Reimbursed
expenses will paid [sic] monthly as billed for the term of this contract.
A bonus of Ten Thousand Dollars ($10,000) will also be paid upon
successful passage of legislation, which will be agreed upon.
This Agreement incorporates all agreements and understandings between
parties.
32. The Memorandum Agreement was later amended to delete the $10,000.00 bonus
clause.
a. Contingent compensation is prohibited under Section 13A07(e) of the
Lobbying Disclosure Law.
b. No bonus was paid to McCombs.
33. In the e -mail Manuel sent to McCombs on March 1, 2007, Manuel included the
Pennsylvania Legislative Initiatives Filmed Entertainment Objectives.
1) To change the current grant program, with a cap of $10MM, to a
Transferable Tax Credit program with either:
a) a cap of $50MM
b) No cap
2) The transferable Tax Credit program will have the same definition of
qualifying expenses as the current Grant program. However, we would
propose that the credit rate be increased to 25% of qualified expenditures,
as opposed to the current rate of 20 %.
"Approved qualified film production expense." A qualified film production that
(i) has been incurred prior to the effective date or shall be incurred by the
production company during the Contract Activity period; and (ii) is set forth in
an itemized list of such expenses submitted to an [sic] approved by the
Department and set forth in Appendix A hereto and incorporated by
reference herein.
"Pennsylvania production expense." A production expense incurred in this
McCombs, 07 -001 L
Page 9
Commonwealth. The term included only wages and salaries on which the
taxes imposed by Article III or IV of the Tax Reform Code of 1971, as
amended will be paid or accrued.
"Production expense." An expense incurred in the production of a film. The
term includes the aggregate amount of wages and salaries of individuals
each of whom received Tess than $1,000,000 exclusive of fringe benefits and
per diems, and are employed in the production of the film; the costs of
construction, operations, editing, photography, sound synchronization,
lighting, wardrobe and accessories; and the cost of rental facilities and
equipment. The term does not include expenses incurred in purchasing story
rights, music rights, developing costs, marketing or advertising a film.
3) The per project cap of tax credits should be $10MM. [T]his cap applies to
the amount of tax credit a project can receive, not the cost base the tax
credit will be estimated on.
4) TV series should be defined separately from feature films. A Project in
TV should be defined as one season of a series. A season is defined as a
group of episodes produced continuously.
5) To ease the fear that Pennsylvania legislators may have draining the
resources of the Commonwealth, we propose putting a sunset provision on
this Transferable Tax Credit Program of 3 years. This will give the
Commonwealth ample opportunity to gauge the financial success of the
program, while capping the downside with a near term potential exit strategy.
6) There should be no limit on the number of transfers on these tax credits.
In other words, production companies should be able to sell these credits to
financing agents, and not be limited to dealing solely with end users.
7) An extra 5% tax credit should be applied on all of the labor associated
with Trainees. Trainees will be defined as someone with less than a
specified amount of hourly work experience. This extra credit is designed to
build up the crew base of Pennsylvania.
34. On March 5, 2007, McCombs sent Manuel an e-mail informing him that she had
received and reviewed the lobbying contract.
a. McCombs requested that Manuel sign the contract and fax the contract back
to McCombs.
b. McCombs used the name of her limited liability company LHLT, LLC in the
correspondence McCombs had with Manuel regarding the lobbying contract.
c. McCombs also inquired if Manuel was "still planning on hiring another
lobbyist."
35. McCombs and Manuel both executed the final form of the Memorandum of
Agreement, which was effective March 1, 2007.
36. On or around March 26, 2007, Governor Rendell discussed with McCombs
arranging a meeting with legislators and representatives from the film industry to
discuss the film tax credit in Harrisburg on April 17, 2007.
a. McCombs confirmed the meeting and her conversation with Governor
Rendell in a March 26, 2007, e-mail to Mark Manuel and Dawn Keezer.
McCombs, 07 -001 L
Page 10
37. Between March 26, 2007, and April 15, 2007, McCombs coordinated with Manuel
and the Governor's Office via e-mail, a meeting with the Governor and legislative
leaders scheduled for April 17, 2007.
38. On April 17, 2007, a Meeting /Luncheon was held at the Governor's Residence in
Harrisburg to discuss the Film Tax Credit Legislation. Attendees at this meeting
included Governor Rendell, McCombs, and representatives of the film and
television industry, including representatives of Lionsgate.
a. McCombs attended the Meeting /Luncheon in her capacity as a lobbyist for
Lionsgate.
b. McCombs discussed the film tax credit legislation with legislators and
legislative staff.
c. Mark Manuel spoke at the meeting on the benefits the film tax credit
legislation could bring to the Commonwealth of Pennsylvania.
39. On or around June 11 and 12, 2007, McCombs, Keezer, Pinkenson, Manuel, and
other Lionsgate lobbyists, met with various legislators and legislative staff to
discuss the film tax credit.
40. On June 14, 2007, McCombs sent an e-mail to Manuel, Pinkenson, Nora
Winkelman from the Office of the Chief Counsel for Governor Rendell, Keezer,
Nicole Shiner, and other Lionsgate lobbyists, which noted the following:
I spoke with the Gov and he said everyone should do absolutely nothing
regarding the language in the legislation. It's critical that the Republicans
feel that they've won something in the end, so we'll let them come up with
the suggested change of a transferable credit rather than a refundable
credit. Please don't say a word to anyone about this. Thanks.
41. In 2007 various pieces of legislation were introduced in both the Pennsylvania
House and Senate in relation to film tax incentives.
a. Representative Michael Sturla was the prime Sponsor of House Bill 1528
introduced in the Pennsylvania House on June 19, 2007, that was referred to
as the Film Tax Credit Bill.
1. The bill would have increased State Film Grant Program from $10
Million to $15 Million.
2. On or around June 25, 2007, the Film Tax Credit Bill was referred
back to the House Appropriations Committee due to the number of
unrelated amendments being added to the bill.
b. State Senator James Ferlo introduced legislation similar to the Sturla bill
(H.B. 1528) under Senate Bill 1008 on June 26, 2007, increasing the Grant
Program for the film and television industry from $10 million to $15 million.
1. The bill would have provided a 25% tax credit to filmmakers with a
budget of over $2 Million.
42. Senate Bill 97 was introduced by State Senator Donald White on February 15,
2007, and later became the film tax credit bill.
McCombs, 07 -001 L
Page 11
a. Senate Bill 97 was amended by Senator Gibson Armstrong on June 25,
2007, July 3, 2007, and July 7, 2007.
b. The Senate Bill was a $75 Million Film Tax Credit Program requiring 60% of
the expenditures to be made in state.
43. McCombs participated in lobbying the sponsors of these pieces of legislation
between June and July 2007.
a. McCombs, Manuel, Pinkenson and other Lionsgate lobbyists, met with
Representative Sturla on or around June 11, 2007, while lobbying legislators
for the film tax credit legislation.
b. On or around July 1, 2007, McCombs participated in a meeting by way of a
telephone conference call with Governor Rendell, Greg Fajt, Governor
Rendell's Chief of Staff, State Senator Gibson Armstrong, Chairman of the
Senate Appropriations Committee, and Chris Latta, Senator Armstrong's
Chief of Staff.
Mark...
L
1. McCombs' participation in the meeting was arranged by a telephone
call placed to her by Governor Rendell.
2. The purpose of the meeting was to discuss the legislation regarding
the film tax credit, particularly Senate Bill 97 as amended by Senator
Armstrong.
44. McCombs, Manuel, Keezer, Pinkenson, and other Lionsgate lobbyists exchanged
numerous e -mails from July 1, 2007, through July 17, 2007, on how Senate Bill 97,
the film tax credit legislation, was progressing along during the budget negotiations
of 2007.
a. McCombs' actions also included telephone [communication] with Governor
Rendell.
45. On July 15, 2007, McCombs forwarded an e-mail to Manuel on the status of the film
tax legislation as follows:
Its over... transferable with 15m salary cap.
Dawn and the Gov have some great ideas for selling the tax credits, and with
Dennis Yablonsky's help, we may be just as good as if it were refundable. Plus,
with the Visa program, you'll be in good shape we think. It's not perfect, but the
Gov guaranteed that Lionsgate will be taken care of.
46. Senate Bill 97 was approved in the House of Representatives on July 17, 2007, and
in the Senate on July 19, 2007.
a. The bill was presented to Governor Rendell on July 19, 2007, and signed
into law by Governor Rendell on July 25, 2007, as Act 55 of 2007.
b. Act 55 of 2007 became known as the Film Production Tax Credit.
1. Effective July 1, 2007, Pennsylvania provided a 25% film production
McCombs, 07 -001 L
Page 12
tax credit for film production expenses incurred in the Commonwealth
of Pennsylvania.
2. The credit was a transferable credit and it was available for feature
films, TV shows and series, and commercials intended for a national
audience.
3. To qualify for the tax credit, 60% of the total production expenses had
to [be incurred] in Pennsylvania and no more than $75 million per
year could be awarded.
47. Leslie McCombs was compensated as a lobbyist by Lionsgate for her services in
relation to lobbying the Governor, the Governor's staff and the members and staff of
the Pennsylvania General Assembly for the passage of a film tax credit.
48. Lionsgate compensated McCombs for lobbying services rendered on [its] behalf.
a. McCombs' compensation for services rendered to Lionsgate was in excess
of the threshold reporting amount of $2,500.00.
49. Leslie Merrill McCombs maintains a Money Market Account with PNC Bank in
association with LHLT, LLC.
a. The account at PNC bank was documented as a Business Premium Money
Market Account.
1. The account was opened on March 23, 2007, and Leslie Merrill
McCombs was listed as the Authorized Signature.
50. The payments McCombs received from Lionsgate for the lobbying work and the
expenses McCombs incurred while lobbying for Lionsgate were deposited into the
Business Premium Money Market Account at PNC bank.
51. Leslie McCombs utilized tickets to sporting events purchased by UPMC Health Plan
to entertain Lionsgate and Commonwealth of Pennsylvania Officials.
a. The tickets were available to employees of UPMC Health Plan to entertain
individuals in the performance of their duties.
52. The UPMC Health Plan purchased season tickets in 2007 for the Pittsburgh Pirates
Baseball Team totaling $61,440.00* which included the price of the tickets, seat
license, and parking.
ML . Description Unit Price Total
a. 2 Share Plan 1 and 3 18 K 1 -4 $ 8,800.00 $17,600.00
b. 2 Share Plan 2 and 4 17 G 3 -6 $10,800.00 $21,600.00
c. 4 Opening day Tickets 19 H 1 -4 $ 135.00 $ 540.00
d. 1 Seat License $20,000.00 $20,000.00
e. 1 Red Lot 6 Parking $ 1,500.00 $ 1,500.00
Subtotal $61,440.00*
*[sic]. [There is a minor error in the calculation that does not affect the outcome of
this case.]
53. McCombs periodically used UPMC Health Plan tickets to entertain either
DATE
TEAM
REQUESTED
USED BY
BUSINESS
BY
NAME /COMPANY
PURPOSE
4/28/07
Cincinnati
Reds
Leslie
McCombs
Leslie McCombs
Todd Harthan /Kill Point
Bill Hill /Kill Point
Tim Iacofano /Kill Point
Other
5/2/07
Chicago Cubs
Leslie
McCombs
Leslie McCombs
Kevin
Kinross /Governor's
Rep for SWPA
Kinross guest
Kinross guest
Other
5/18/07
Arizona
Diamondbacks
Leslie
McCombs
John Paul
Jones /Department
Government Services
Other
5/29/07
San Diego
Padres
Leslie
McCombs
Nora Dowd
Eisenhower /Secretary
of Aging
Tom
Snedden /Executive
Director, PACE + 3
staffers
Other
6/4/07
Los Angeles
Dodgers
Leslie
McCombs
Lionsgate
Other
6/12/07
Texas Rangers
Leslie
McCombs
Lionsgate
Other
6/14/07
Texas Rangers
Leslie
McCombs
Lionsgate
Other
6/15/07
Chicago White
Sox
Leslie
McCombs
Governor Rendell,
Judge Rendell, Mr.
Romoff, and Stefania
Romoff
Other
6/16/07
Chicago White
Sox
Leslie
McCombs
Governor Rendell,
Judge Rendell, Jessie
Rendell
Other
6/17/07
Chicago White
Sox
Leslie
McCombs
Governor + 4 guests
Other
6/30/07
Washington
Nationals
Leslie
McCombs
Tim Iacofano /Kill Point
Producer /Director
Other
7/3/07
Milwaukee
Brewers
Leslie
McCombs
Tom Sneddon /PACE
Other
7/17/07
Colorado
Rockies
Leslie
McCombs
Governor Rendell,
Doug Romoff, Louis
LaRose
Other
7/22/07
Houston Astros
Leslie
McCombs
Chuck Ardo /Governor
Rendell Press
Secretary
Other
8/4/07
Cincinnati
Reds
Leslie
McCombs
Katy Gresch /Governor
Rendell's
correspondence office
Other
8/14/07
New York Mets
Leslie
McCombs
Gov. Rendell, Rendell
Guest, Dr. Larry
Wechsler, Leslie
Other
McCombs, 07 -001 L
Page 13
Commonwealth of Pennsylvania Officials including Governor Rendell or Lionsgate
Officials as follows:
McCombs, 07 -001 L
Page 14
54. McCombs entertained Governor Rendell, State Officials, and Lionsgate Officials
with the baseball tickets while lobbying the Pennsylvania Governor's Office for
Lionsgate when discussions were taking place regarding the film tax credit
legislation.
a. Governor Rendell attended five Pittsburgh Pirate Baseball games as a guest
of McCombs using tickets paid for by the UPMC Health Plan.
55. Governor Rendell subsequently reimbursed McCombs for the costs of the tickets for
the games that the Governor attended.
a. On September 18, 2007, Governor Rendell made a payment to McCombs in
the amount of $245 and on November 11, 2007, another payment was made
in the amount of $715.
1. McCombs subsequently returned the money to the UPMC Health
Plan.
56. McCombs filed a Lobbyist Registration Statement with the Pennsylvania
Department of State dated August 29, 2007, which identified Lionsgate as a
Principal that she represented.
a. McCombs reported that her lobbying for Lionsgate commenced on June 11,
2007.
57. McCombs had been providing lobbyist services on behalf of Lionsgate as early as
January 25, 2007.
a. McCombs provided tax credit language and information to Governor Rendell
on or about January 25, 2007.
b. McCombs received approval from UPMC by February 15, 2007, to act as a
compensated Lobbyist for Lionsgate.
c. The executed contract with Lionsgate was dated March 1, 2007.
d. McCombs received payments from Lionsgate on April 19, 2007, and April 27,
2007, for lobbying services performed during March 2007 and April 2007.
58. On September 5, 2007, Mark Manuel filed an online Principal Registration
Statement for Lionsgate with the Division of Lobbying Disclosure for the
Pennsylvania Department of State.
a. The registration number assigned to Lionsgate was P05761.
b. Leslie McCombs, amongst others, were identified as lobbyists lobbying on
behalf of Lionsgate.
c. Manuel reported that McCombs' affiliated start date with Lionsgate was
March 1, 2007, and an affiliated end date was July 15, 2007.
McCombs
8/16/07
New York Mets
Leslie
McCombs
Kevin
Kinross /Governor
Rendell's Office
Other
8/28/07
Cincinnati
Reds
Leslie
McCombs
Mark Manuel /Lionsgate
Other
McCombs, 07 -001 L
Page 14
54. McCombs entertained Governor Rendell, State Officials, and Lionsgate Officials
with the baseball tickets while lobbying the Pennsylvania Governor's Office for
Lionsgate when discussions were taking place regarding the film tax credit
legislation.
a. Governor Rendell attended five Pittsburgh Pirate Baseball games as a guest
of McCombs using tickets paid for by the UPMC Health Plan.
55. Governor Rendell subsequently reimbursed McCombs for the costs of the tickets for
the games that the Governor attended.
a. On September 18, 2007, Governor Rendell made a payment to McCombs in
the amount of $245 and on November 11, 2007, another payment was made
in the amount of $715.
1. McCombs subsequently returned the money to the UPMC Health
Plan.
56. McCombs filed a Lobbyist Registration Statement with the Pennsylvania
Department of State dated August 29, 2007, which identified Lionsgate as a
Principal that she represented.
a. McCombs reported that her lobbying for Lionsgate commenced on June 11,
2007.
57. McCombs had been providing lobbyist services on behalf of Lionsgate as early as
January 25, 2007.
a. McCombs provided tax credit language and information to Governor Rendell
on or about January 25, 2007.
b. McCombs received approval from UPMC by February 15, 2007, to act as a
compensated Lobbyist for Lionsgate.
c. The executed contract with Lionsgate was dated March 1, 2007.
d. McCombs received payments from Lionsgate on April 19, 2007, and April 27,
2007, for lobbying services performed during March 2007 and April 2007.
58. On September 5, 2007, Mark Manuel filed an online Principal Registration
Statement for Lionsgate with the Division of Lobbying Disclosure for the
Pennsylvania Department of State.
a. The registration number assigned to Lionsgate was P05761.
b. Leslie McCombs, amongst others, were identified as lobbyists lobbying on
behalf of Lionsgate.
c. Manuel reported that McCombs' affiliated start date with Lionsgate was
March 1, 2007, and an affiliated end date was July 15, 2007.
McCombs, 07 -001 L
Page 15
59. On September 11, 2007, Jessica Myers, Chief of Campaign Finance and Lobbying
Disclosure, Pennsylvania Department of State forwarded correspondence to
McCombs regarding lobbyist registration forms filed by McCombs.
a. A Lobbyist Registration Statement for McCombs was received in her office
on January 11, 2007, but was not processed due to the phone number of
McCombs' principal, UPMC missing from the form. McCombs' original
registration, L00513 was rejected until the phone number was entered into
the system.
b. On September 4, 2007, the Division of Lobbying Disclosure received another
Lobbyist Registration Statement from McCombs, and McCombs was
assigned a new registration number (L05751) with a date lobbying
commencing [sic] on June 11, 2007, but this was subsequently changed as it
was treated as an amendment to L00513 and L05751 was terminated
effective September 11, 2007.
c. McCombs' registration check in the amount of $100 was returned.
d. McCombs' original fee was received and processed and McCombs was to
include registration number L00513 on all correspondence, reports or
registration amendments.
60. On September 18, 2007, Mark Manuel filed Lobbying Disclosure Quarterly Expense
Reports for Lionsgate that included the first three quarters of 2007.
a. The lobbyists identified as lobbying for Lionsgate were Leslie McCombs and
an additional lobbying firm.
b. The only quarter of 2007 that Lionsgate identified expenses for [its] lobbyists
was for the quarter of April -June and the costs amounted to $31,130.22.
61. On or around October 1, 2007, McCombs filed an Amended Lobbyist Registration
Statement with the Division of Lobbying Disclosure.
a. McCombs noted on the Amended Lobbyist Statement that McCombs was
amending the date lobbying commenced for Lionsgate to March 1, 2007.
b. A handwritten entry on the Amended Statement stated that out of
abundance of caution, I am amending the date of commencement of
lobbying."
62. On or around November 28, 2007, McCombs filed an online Lobbyist Registration
Statement identifying the Principals McCombs represented as UPMC and
Lionsgate.
a. The affiliated start date McCombs listed on the registration statement for
Lionsgate was March 1, 2007.
63. McCombs did not amend her individual Lobbyist Registration Statement when she
began to lobby for Lionsgate.
a. McCombs performed lobbyist activities on behalf of Lionsgate as early as
January 25, 2007, by providing Governor Rendell with proposed language
for a tax credit bill.
McCombs, 07 -001 L
Page 16
1 McCombs had an understanding with Lionsgate as of February 15,
2007, that she would act as the lobbyist for Lionsgate in relation to
the tax credit issue.
2. McCombs' understanding was formalized by way of a contract with
Lionsgate dated March 1, 2007.
3. The first compensation payment received by McCombs from
Lionsgate occurred on April 19, 2007.
b. Between March 1, 2007, and October 1, 2007, McCombs engaged in
lobbying activity regarding Lionsgate while not properly registered.
1. McCombs' lobbying on behalf of Lionsgate while not properly
registered under the Lobbying Disclosure Law spanned 201 days.
i. McCombs could have amended her lobbying registration
between March 1, 2007, and March 14, 2007, per the Lobbying
Disclosure Law.
ii. McCombs was not in violation of the Lobbying Disclosure Law
for failure to register until March 15, 2007 [March 15, 2007 —
October 1, 2007 = 201 calendar days.]
64. LHLT, LLC has not, to date, registered as a lobbying firm with the Pennsylvania
Department of State.
III. DISCUSSION:
The allegations are that Respondent Leslie McCombs (hereinafter also referred to
as "Respondent," "Respondent McCombs," and "McCombs "), in her capacity as a lobbyist,
violated the Lobbying Disclosure Law when she failed to register as a lobbyist for
Lionsgate, a California production company, and subsequently engaged in lobbyist
activities before the Pennsylvania General Assembly and /or the Pennsylvania Governor's
Office on behalf of Lionsgate; and when she filed a deficient lobbyist registration form for
the University of Pittsburgh Medical Center.
Section 13A04 of the Lobbying Disclosure Law, pertaining to registration by
lobbyists, lobbying firms and principals, provides in pertinent part as follows:
§ 13A04. Registration.
(a) General rule. -- Unless excluded under section 13A06
(relating to exemption from registration and reporting), a
lobbyist, lobbying firm or a principal must register with the
department within ten days of acting in any capacity as a
lobbyist, lobbying firm or principal. Registration shall be
biennial and shall begin January 1, 2007.
(b) Principals and lobbying firms.- -
(1) A principal or lobbying firm required to register under
subsection (a) shall file a single registration statement
setting forth the following information with the
department:
(i) Name.
McCombs, 07 -001 L
Page 17
(ii) Permanent address.
(iii) Daytime telephone number.
(iv) E -mail address, if available.
(v) Name and nature of business.
(vi) Name, registration number and acronym of any
affiliated political action committees.
(vii) Name and permanent business address of each
individual who will for economic consideration
engage in lobbying on behalf of the principal or
lobbying firm.
(viii) Registration number when available.
(2) A lobbying firm shall include in its statement under
paragraph (1) the following information for each
principal it represents:
(i) Name.
(ii) Permanent business address.
(iii) Telephone number.
(iv) Registration number when available.
A principal that is an association or organization shall
include in its statement under paragraph (1) the number
of dues - paying members of the association or
organization in the most recently completed calendar
year.
(3)
(c) Lobbyist. - -A lobbyist who is required to register under
subsection (a) shall file a single registration statement setting
forth the following information with the department:
(1) Name.
(2) Permanent business address.
(3) Daytime telephone number.
(4) E -mail address, if available.
(5) A recent photograph of the lobbyist.
(6) Name, permanent business address, daytime telephone
number and registration number when available of each
principal for whom the lobbyist will engage in lobbying.
McCombs, 07 -001 L
Page 18
(7) Name and registration number when available of any
lobbying firm with which the lobbyist has a relationship
involving economic consideration.
(8) Name, registration number and acronym of any
affiliated political action committees.
(9) Name, registration number and acronym of any
candidate political committee of which the lobbyist is an
officer who must be included in a registration statement
under section 1624(b)(2) and (3) of the act of June 3,
1937 (P.L.1333, No.320), known as the Pennsylvania
Election Code.
(d) Amendments.- -
(1) If there is a change of information required for the
registration statement under subsection (b)(1) or (2) or
(c), an amended registration statement shall be filed
with the department within 14 days after the change
occurs.
(2) When there is a change in information required for the
registration statement under subsection (b)(3), an
amended registration statement shall be filed with the
department within 14 days of the end of the year in
which the change occurs.
65 Pa. C. S. § 13A04 (a) -(d).
The following terms are defined in the Lobbying Disclosure Law as follows:
§ 13A03. Definitions.
"Lobbying." An effort to influence legislative action or
administrative action in this Commonwealth. The term
includes:
(1) direct or indirect communication;
(2) office expenses; and
(3) providing any gift, hospitality, transportation or lodging
to a State official or employee for the purpose of
advancing the interest of the lobbyist or principal.
"Lobbying Firm." An entity that engages in lobbying for
economic consideration on behalf of a principal other than the
entity itself.
"Lobbyist." Any individual, association, corporation,
partnership, business trust or other entity that engages in
lobbying on behalf of a principal for economic consideration.
The term includes an attorney at law while engaged in
lobbying.
McCombs, 07 -001 L
Page 19
"Principal." An individual, association, corporation,
partnership, business trust or other entity:
(1) on whose behalf a lobbying firm or lobbyist engages in
lobbying; or
(2) that engages in lobbying on the principal's own behalf.
65 Pa.C.S. § 13A03.
As noted above, the parties have submitted a Consent Agreement and Stipulation of
Findings. The parties' Stipulated Findings are set forth above as the Findings of this
Commission. We shall now summarize the relevant facts as contained therein.
From approximately May 2006 through the present, Respondent McCombs has
been employed as a Senior Consultant with the Government Relations Department of the
University of Pittsburgh Medical Center (UPMC).
In 2007, Respondent served as a lobbyist for UPMC. Respondent's compensation
as a lobbyist for UPMC for the year 2007 exceeded $2,500.00 by January 26, 2007. This
is significant because, by earning more than $2,500.00 in a quarter for lobbying,
Respondent became subject to the registration and reporting requirements of the Lobbying
Disclosure Law. She was required to file a Lobbyist Registration Statement with the
Department of State and to amend it as needed. 65 Pa.C.S. §§ 13A04(a), (d)(1).
On January 8, 2007, Respondent filed a Lobbyist Registration Statement with the
Department of State as a lobbyist for UPMC. The Lobbyist Registration Statement
confirmed that Respondent was lobbying on behalf of UPMC effective January 2, 2007.
However, Respondent failed to list a daytime telephone number for UPMC on the Lobbyist
Registration Statement. This information was required by Section 13A04(c)(6) of the
Lobbying Disclosure Law. The deficiency resulted in the Pennsylvania Department of
State, Division of Campaign Finance and Lobbying Disclosure (also referred to herein as
the "Division of Lobbying Disclosure ") deeming the filing incomplete. Respondent did not
reply to contacts made by staff members of the Division of Lobbying Disclosure, who were
seeking to have the problem corrected.
In January 2007 Respondent was also involved with Dawn Keezer ( "Keezer "),
Director of the Pittsburgh Film Office ( "PFO "), and Mark Manuel ( "Manuel "), Executive
Vice - President for Structured Finance of Lionsgate, in an ongoing effort to advance film tax
credit legislation in Pennsylvania. Respondent first became involved with the effort in
2006, when she helped to arrange a meeting with Governor Rendell that included
Respondent, Keezer, Manuel, and Sharon Pinkenson ( "Pinkenson "), Executive Director of
the Philadelphia Film Office. Respondent also assisted Lionsgate in obtaining a state
grant in 2006.
In January 2007 Respondent continued to assist Lionsgate without compensation
and without any understanding that she would be compensated. This is significant
because the Lobbying Disclosure Law does not require an individual to register as a
lobbyist for a principal when the lobbying services are provided without "economic
consideration." See, 65 Pa.C.S. § 13A03 (definition of "lobbyist ").
In January 2007 Respondent formed a limited liability company named "LHLT, LLC."
Respondent was President of LHLT, LLC. (Respondent would eventually use LHLT, LLC
for lobbying activities on behalf of Lionsgate.)
On January 12, 2007, Manuel sent an e-mail to Respondent, Keezer, and John
Valentine ( "Valentine ") of Lionsgate, requesting that Respondent and Keezer relay a
McCombs, 07 -001 L
Page 20
message to the Governor relating to the scope of the Lionsgate business in Pennsylvania
and the details of a certain Lionsgate corporate initiative.
On January 23, 2007, Manuel sent an e-mail to Respondent and Keezer attaching
the legislation for New Mexico's film tax credit program. The purpose of Manuel forwarding
the New Mexico legislation to Respondent was to assist Respondent in advancing that tax
credit in Pennsylvania.
On January 25, 2007, Manuel sent an e-mail to Respondent and Keezer with
suggestions that should be made to Governor Rendell on the proposed film tax credits for
Pennsylvania.
On January 25, 2007, Respondent sent an e-mail to Manuel and Keezer advising
that Respondent was giving the information regarding the film tax credits to Governor
Rendell on that date.
From February 5 -7, 2007, Respondent had meetings with Keezer, Manuel and
Valentine regarding the film tax credit.
By February 14, 2007, Manuel and Respondent had more discussions finalizing
Respondent's role as a lobbyist on behalf of Lionsgate. On February 14, 2007, Manuel
directed an e-mail to Respondent, indicating that he would try to send Respondent the
legislative proposal for the new Pennsylvania entertainment tax credit later that day, and
inquiring as to the number of guests, including the Governor, who would need seats for a
premiere in Philadelphia on February 27, 2007. The e -mail posed the following question to
Respondent: Have you heard whether or not you can be hired as a `supervisory lobbyist'
by Lionsgate ?" Fact Finding 26. The term "supervisory lobbyist" was used by Manuel and
Respondent to describe Respondent's role as a lobbyist for Lionsgate.
On February 15, 2007, Respondent exchanged e -mails with the UPMC
President /CEO and received authorization to serve as a supervisory lobbyist for Lionsgate
on her own time. Later that same day, Respondent sent an e-mail to Manuel advising that
it was permissible for her to accept the lobbyist supervisor position. Respondent also
informed Manuel that she was meeting with the Governor at 2:00 p.m. to "confirm the 27 ."
Fact Finding 29 a. On February 27, 2007, the movie "Pride" premiered in Philadelphia.
Various officials from Lionsgate, including Manuel, were present along with Pennsylvania
officials, including Governor Rendell, and Respondent.
On March 1, 2007, Manuel e- mailed to Respondent a draft lobbying contract and
legislative objectives for the tax credit program that Lionsgate wanted to pursue in
Pennsylvania. The final form of the contract, which was between Respondent /LHLT, LLC
and Lionsgate, was executed by Respondent and Manuel and was effective March 1,
2007. It provided for Respondent /LHLT, LLC to be compensated for lobbying legislation
on behalf of Lionsgate commencing March 1, 2007. See, Fact Finding 31. It also provided
for a "success bonus," which was later deleted as being contrary to the Lobbying
Disclosure Law. The parties have stipulated that no bonus was paid to Respondent.
On or around March 26, 2007, Governor Rendell discussed with Respondent
arranging a meeting with legislators and representatives of the film industry to discuss the
film tax credit in Harrisburg on April 17, 2007. Respondent confirmed the meeting and her
conversation with Governor Rendell in a March 26, 2007, e-mail to Manuel and Keezer.
Respondent coordinated with Manuel and the Governor's Office to arrange the meeting.
On April 17, 2007, the Meeting /Luncheon was held at the Governor's Residence in
Harrisburg to discuss the Film Tax Credit Legislation. Attendees included Governor
Rendell, Respondent, and representatives of the film and television industry, including
representatives of Lionsgate. Respondent attended the Meeting /Luncheon in her capacity
McCombs, 07 -001 L
Page 21
as a lobbyist for Lionsgate. Respondent discussed the film tax credit legislation with
legislators and legislative staff. Manuel spoke at the meeting regarding the benefits the
film tax credit legislation could bring to Pennsylvania.
On or around June 11 and 12, 2007, Respondent, Keezer, Pinkenson, Manuel, and
others who were Lionsgate lobbyists met with various legislators and legislative staff to
discuss the film tax credit.
On June 14, 2007, Respondent sent an e-mail to Manuel, Pinkenson, Nora
Winkelman from the Office of the Chief Counsel for Governor Rendell, Keezer, Nicole
Shiner, and others who were Lionsgate lobbyists, regarding a particular aspect of the
proposed legislation. Fact Finding 40.
In 2007 various pieces of legislation were introduced in both the Pennsylvania
House and Senate in relation to film tax incentives.
Representative Michael Sturla was the prime Sponsor of House Bill 1528 introduced
in the Pennsylvania House on June 19, 2007. The bill would have increased the State Film
Grant Program from $10 Million to $15 Million. On or around June 25, 2007, the bill was
referred to the House Appropriations Committee due to the number of unrelated
amendments being added to the bill.
On June 26, 2007, State Senator James Ferlo introduced Senate Bill 1008 seeking
to increase the Grant Program for the film and television industry from $10 million to $15
million and provide a 25% tax credit to filmmakers with a budget of over $2 Million.
Senate Bill 97 was introduced by State Senator Donald White on February 15,
2007, and later became the film tax credit bill. Senate Bill 97 was amended by Senator
Gibson Armstrong on June 25, 2007, July 3, 2007, and July 7, 2007.
Respondent participated in lobbying the sponsors of these pieces of legislation
between June and July 2007. Respondent, Manuel, Pinkenson and others who were
Lionsgate lobbyists met with Representative Sturla on or around June 11, 2007, while
lobbying legislators for the film tax credit legislation. On or around July 1, 2007,
Respondent participated in a meeting by way of a telephone conference call with Governor
Rendell, Greg Fajt, Governor Rendell's Chief of Staff, State Senator Gibson Armstrong,
Chairman of the Senate Appropriations Committee, and Chris Latta, Senator Armstrong's
Chief of Staff. Respondent's participation in the meeting was arranged by a telephone call
placed to her by Governor Rendell. The purpose of the meeting was to discuss the
legislation regarding the film tax credit, particularly Senate Bill 97 as amended by Senator
Armstrong.
Respondent, Manuel, Keezer, Pinkenson, and others who were Lionsgate lobbyists
exchanged numerous e -mails from July 1, 2007, through July 17, 2007, regarding how
Senate Bill 97 was progressing during the 2007 budget negotiations. Respondent also
communicated by telephone with Governor Rendell.
On July 15, 2007, Respondent forwarded an e-mail to Manuel on the status of the
film tax legislation as detailed at Fact Finding 45.
Senate Bill 97 was approved in the House of Representatives on July 17, 2007, and
in the Senate on July 19, 2007. The bill was presented to Governor Rendell on July 19,
2007, and was signed into law by Governor Rendell on July 25, 2007, as Act 55 of 2007.
Respondent was compensated as a lobbyist by Lionsgate for her services in relation
to lobbying the Governor, the Governor's staff and the members and staff of the
Pennsylvania General Assembly for the passage of a film tax credit.
McCombs, 07 -001 L
Page 22
The Stipulated Findings note that while Respondent was lobbying the Pennsylvania
Governor's Office for Lionsgate, and discussions were taking place regarding the film tax
credit legislation, Respondent entertained Governor Rendell, State officials, and Lionsgate
officials at Pittsburgh Pirates baseball games as detailed in Fact Findings 52 -54 a.
Governor Rendell subsequently reimbursed the costs of the tickets for the games that he
attended. We parenthetically note that the reimbursements by the Governor occurred prior
to the promulgation of the Regulations to implement the Lobbying Disclosure Law, which
Regulations provide that a hospitality item that is fully reimbursed to the registrant within
30 days of the date of receipt need not be reported under the Lobbying Disclosure Law,
see, 51 Pa. Code § 55.1(k)(1).
On September 5, 2007, Manuel filed a Principal Registration Statement for
Lionsgate, which identified Respondent as a lobbyist for Lionsgate commencing March 1,
2007. Manuel subsequently filed Quarterly Expense Reports for Lionsgate for the first
three quarters of 2007, identifying Respondent as one of the lobbyists for Lionsgate.
As noted above, McCombs' first Lobbyist Registration Statement, which had been
filed in January 2007, had not been processed due to lack of a daytime telephone number
of UPMC. McCombs filed another Lobbyist Registration Statement with the Pennsylvania
Department of State dated August 29, 2007, which listed Lionsgate as a principal that she
represented and reported that her lobbying for Lionsgate commenced on June 11, 2007.
McCombs' second Lobbyist Registration Statement was ultimately treated as an
amendment to the first. On or around October 1, 2007, McCombs filed an Amended
Lobbyist Registration Statement that amended the date lobbying commenced for Lionsgate
to March 1, 2007. On or around November 28, 2007, McCombs filed a Lobbyist
Registration Statement identifying both UPMC and Lionsgate as principals McCombs
represented, with the affiliated start date for Lionsgate listed as March 1, 2007.
The parties have agreed that McCombs was not in violation of the Lobbying
Disclosure Law for failure to register as a lobbyist for Lionsgate until March 15, 2007. The
parties have stipulated that McCombs' lobbying on behalf of Lionsgate while not properly
registered spanned 201 days. To date, LHLT, LLC has not registered as a lobbying firm
with the Pennsylvania Department of State.
Having highlighted the Stipulated Findings and issues before us, we shall now apply
the Lobbying Disclosure Law to determine the proper disposition of this case.
The parties' Consent Agreement sets forth a proposed resolution of the allegations
as follows:
3. The Investigative Division and Leslie McCombs, by and through her counsel,
will recommend the following conclusions in relation to the above
allegations:
a. That Leslie McCombs, in her capacity as a lobbyist,
violated Section 13A04(c)(6) of the Lobbying Disclosure
Law, 65 Pa.C.S. § 13A04(c)(6), when she failed to
timely amend a Registration Statement filed with the
Pennsylvania Department of State to identify Lionsgate
Entertainment Corp. as a principal on whose behalf
McCombs would engage in lobbying for economic
consideration.
b. That Leslie McCombs violated Section 13A04(b) of the
Lobbying Disclosure Law, 65 Pa.C.S. § 13A04(b), when
she failed to register LHLT, LLC, a Limited Liability
McCombs, 07 -001 L
Page 23
Company, as a lobbying firm with the Pennsylvania
Department of State within ten days of acting in the
capacity as a lobbying firm.
c. That a technical violation of the Lobbying Disclosure
Law, Section 13A04(c)(3) of the Lobbying Disclosure
Law, 65 Pa.C.S. § 13A04(c)(3), occurred when Leslie
McCombs failed to list a daytime telephone number on
a Registration Statement filed by her with the
Pennsylvania Department of State regarding her
employment as a lobbyist for the University of
Pittsburgh Medical Center.
d. That the transgressions of the Lobbying Disclosure Law
outlined in paragraphs a through c above are deemed
to be negligent in nature.
e. The lobbying activities engaged in by Leslie McCombs
operating either individually or as LHLT, LLC, are
deemed to have been initiated on March 1, 2007, at
which time she had an understanding with
representatives of Lionsgate Entertainment Corporation
that she would engage in lobbying on their behalf for
economic consideration.
f. That Leslie McCombs would have been required to
register LHLT, LLC as a lobbying firm on behalf of
Lionsgate Entertainment Corporation within ten days of
March 1, 2007, or by March 11, 2007.
That Leslie McCombs would have been required to
amend her previously filed Lobbyist Registration to
disclose her lobbying activities on behalf of Lionsgate
within fourteen (14) days of March 1, 2007, or by March
15, 2007.
h. Leslie McCombs was deficient in her individual Lobbyist
Registration forms for a period of 201 days (March 15,
2007, through October 1, 2007).
g.
4. McCombs agrees to pay an administrative penalty in the amount of
$5,025.00 (201 days x $25.00 per diem) in settlement of this matter
payable to the Commonwealth of Pennsylvania and forwarded to the
Pennsylvania State Ethics Commission within thirty (30) days of the
issuance of the final adjudication in this matter.
5. McCombs agrees to file a Registration Statement for LHLT, LLC for
the years that said entity engaged in lobbying activity within thirty (30)
days of the issuance of the final adjudication in this matter.
6. McCombs agrees to file an amended Registration Statement listing
the daytime telephone number for UPMC within thirty (30) days of the
issuance of the final adjudication in this matter.
7 The Investigative Division will recommend that the State Ethics
Commission take no further action in this matter; impose no further
sanctions and make no specific recommendations to any law
McCombs, 07 -001 L
Page 24
enforcement or other authority to take action in this matter as to either
Leslie McCombs or LHLT, LLC. Such, however, does not prohibit the
Commission from initiating appropriate enforcement actions in the
event of Respondent's failure to comply with this agreement or the
Commission's order or cooperating with any other authority who may
so choose to review this matter further.
Consent Agreement, at 1 -3.
In considering the Consent Agreement, we shall begin by reviewing the
recommended conclusions at paragraphs 3 (e) -(h) of the Consent Agreement.
We initially note that Section 13A04(a) of the Lobbying Disclosure Law requires a
lobbyist or lobbying firm to register with the Pennsylvania Department of State within ten
days of "acting in any capacity" as a lobbyist or lobbying firm. 65 Pa.C.S. § 13A04(a). The
Regulations that have been promulgated pursuant to the Lobbying Disclosure Law clarify
that unless one of the exemptions at Section 13A06 of the Lobbying Disclosure Law is
applicable, a lobbyist or lobbying firm is to register with the Department within 10 days of
the earlier of the following: (1) contracting in any form to engage in lobbying; or (2)
engaging in lobbying. 51 Pa. Code §§ 53.3(a), 53.4(a). Section 13A04(d)(1) of the
Lobbying Disclosure Law requires a lobbyist or lobbying firm that has already registered
with the Pennsylvania Department of State to amend such Registration Statement within
14 days if there is a change as to the information required to be disclosed on the
Registration Statement. See, 65 Pa.C.S. § 13A04(d)(1).
The parties have recommended that the lobbying activities engaged in by
Respondent operating either individually or as LHLT, LLC, be deemed to have been
initiated as to Lionsgate on March 1, 2007, at which time Respondent had an
understanding with representatives of Lionsgate that she would engage in lobbying on
behalf of Lionsgate for economic consideration. We agree with the parties'
recommendation. Although Respondent had formed LHLT, LLC in January 2007, it was
not until February 15, 2007, that Respondent knew she would be permitted by her
employer, UPMC, to provide lobbying services to Lionsgate. The terms of the contract
between Respondent /LHLT, LLC and Lionsgate were not agreed upon until March 1, 2007,
either verbally or in writing. Respondent was not compensated for her activities that
occurred prior to March 1, 2007.
We also agree with the parties that Respondent would have been required to
register LHLT, LLC as a lobbying firm on behalf of Lionsgate within ten days of March 1,
2007, or by March 11, 2007.
The "trigger" for LHLT, LLC to register was the March 1, 2007, contract with
Lionsgate. See, 51 Pa. Code § 53.3(a). Under the facts of this case, none of the
exemptions at Section 13A06 of the Lobbying Disclosure Law were applicable to LHLT,
LLC as a lobbying firm (see, 65 Pa.C.S. § 13A06; 51 Pa. Code § 57.2). Because LHLT,
LLC was not amending a prior Registration Statement to add Lionsgate, but rather, was
required to file its initial Registration Statement, it had ten days from March 1, 2007 - -or
until March 11, 2007 - -by which to do so. 65 Pa.C.S. § 13A04(a); 51 Pa. Code § 53.3(a).
In contrast, Respondent would have been required to amend her previously filed
Lobbyist Registration Statement to disclose her lobbying activities on behalf of Lionsgate
within fourteen (14) days of March 1, 2007, or by March 15, 2007. See, 65 Pa.C.S. §
13A04(d)(1).
We shall accept the recommendation of the parties for a conclusion that
Respondent was deficient in her individual Lobbyist Registration forms for a period of 201
days.
McCombs, 07 -001 L
Page 25
As for the parties' recommendations for the finding of violations deemed to be
negligent in nature, the imposition of an administrative penalty, and certain filings to be
made by Respondent, we accept such recommendations as an appropriate disposition for
this case.
We hold that in her capacity as a lobbyist, Respondent violated Section 13A04(c)(6)
of the Lobbying Disclosure Law, 65 Pa.C.S. § 13A04(c)(6), when she failed to timely
amend a Registration Statement filed with the Pennsylvania Department of State to identify
Lionsgate as a principal on whose behalf Respondent would engage in lobbying for
economic consideration.
We hold that Respondent violated Section 13A04 of the Lobbying Disclosure Law,
65 Pa.C.S. § 13A04, when she failed to register LHLT, LLC, a limited liability company, as
a lobbying firm with the Pennsylvania Department of State within ten days of acting in the
capacity as a lobbying firm.
We further hold that a technical violation of Section 13A04(c) of the Lobbying
Disclosure Law, 65 Pa.C.S. § 13A04(c), occurred when Respondent failed to list a daytime
telephone number for UPMC on a Registration Statement filed by her with the
Pennsylvania Department of State on January 8, 2007, regarding her employment as a
lobbyist for UPMC.
The transgressions of the Lobbying Disclosure Law outlined in the above
paragraphs are deemed to be negligent in nature.
As part of the Consent Agreement, Respondent has agreed to pay an administrative
penalty in the amount of $5,025.00, calculated at the rate of $25.00 per day for 201 days,
payable to the Commonwealth of Pennsylvania and forwarded to this Commission within
thirty (30) days of the issuance of the final adjudication in this matter.
Respondent has further agreed to file a Registration Statement for LHLT, LLC for
the years that said entity engaged in lobbying activity, within thirty (30) days of the
issuance of the final adjudication in this matter.
Finally, Respondent has agreed to file an amended Registration Statement listing
the daytime telephone number for UPMC within thirty (30) days of the issuance of the final
adjudication in this matter.
We determine that the Consent Agreement submitted by the parties sets forth a
proper disposition for this case, based upon our review as reflected in the above analysis
and the totality of the facts and circumstances.
Accordingly, per the Consent Agreement of the parties, Respondent is directed to
pay the agreed upon administrative penalty in the total amount of $5,025.00, to be made
payable to the Commonwealth of Pennsylvania and forwarded to this Commission by no
later than the thirtieth (30 day after the mailing date of this adjudication and Order. We
parenthetically note that the Lobbying Disclosure Law does not specify any particular fund
in which administrative penalties are to be deposited, and therefore, this Commission shall
process the payment for deposit into the General Fund.
To the extent she has not already done so, Respondent is directed to file with the
Pennsylvania Department of State: (1) a Registration Statement for LHLT, LLC for the
years that said entity engaged in lobbying activity; and (2) an amended Registration
Statement listing the daytime telephone number for UPMC, and to forward copies of all
such filings to this Commission for compliance verification purposes by no later than the
thirtieth (30) day after the mailing date of this adjudication and Order.
McCombs, 07 -001 L
Page 26
Compliance with the foregoing will result in the closing of this case with no further
action by this Commission. Noncompliance will result in the institution of an order
enforcement action.
IV. CONCLUSIONS OF LAW:
1. As an individual who, in 2007, engaged in lobbying for economic consideration on
behalf of the University of Pittsburgh Medical Center ( "UPMC ") and Lions Gate
Entertainment Corp. ( "Lionsgate "), Respondent Leslie McCombs ( "McCombs ") has
been a lobbyist subject to the provisions of Pennsylvania's lobbying disclosure law
( "Lobbying Disclosure Law "), 65 Pa.C.S. § 13A01 et seq.
2. The lobbying activities engaged in by McCombs operating either individually or as
LHLT, LLC, are deemed to have been initiated as to Lionsgate on March 1, 2007, at
which time McCombs had an understanding with representatives of Lionsgate that
she would engage in lobbying on behalf of Lionsgate for economic consideration.
3. Pursuant to the Lobbying Disclosure Law, McCombs would have been required to
register the entity LHLT, LLC as a lobbying firm on behalf of Lionsgate within ten
days of March 1, 2007, or by March 11, 2007.
4. Pursuant to the Lobbying Disclosure Law, McCombs would have been required to
amend the Lobbyist Registration Statement that she previously filed on January 8,
2007, to disclose her lobbying activities on behalf of Lionsgate within fourteen (14)
days of March 1, 2007, or by March 15, 2007.
5. Per the Consent Agreement of the parties, McCombs was deficient in her individual
Lobbyist Registration forms for a period of 201 days.
6. In her capacity as a lobbyist, McCombs violated Section 13A04(c)(6) of the
Lobbying Disclosure Law, 65 Pa.C.S. § 13A04(c)(6), when she failed to timely
amend a Registration Statement filed with the Pennsylvania Department of State to
identify Lionsgate as a principal on whose behalf McCombs would engage in
lobbying for economic consideration.
7 McCombs violated Section 13A04 of the Lobbying Disclosure Law, 65 Pa.C.S. §
13A04, when she failed to register LHLT, LLC, a limited liability company, as a
lobbying firm with the Pennsylvania Department of State within ten days of acting in
the capacity as a lobbying firm.
8. A technical violation of Section 13A04(c) of the Lobbying Disclosure Law, 65
Pa.C.S. § 13A04(c), occurred when McCombs failed to list a daytime telephone
number for UPMC on a Registration Statement filed by her with the Pennsylvania
Department of State on January 8, 2007, regarding her employment as a lobbyist
for UPMC.
9. The transgressions of the Lobbying Disclosure Law outlined in paragraphs 6 -8
above are deemed to be negligent in nature.
In Re: Leslie McCombs,
Respondent
ORDER NO. 1 -L
File Docket: 07-001L
Date Decided: 7/22/09
Date Mailed: 8/4/09
1 As a lobbyist for the University of Pittsburgh Medical Center ( "UPMC ") and Lions
Gate Entertainment Corp. ( "Lionsgate ") in 2007, Respondent Leslie McCombs
( "McCombs ") violated Section 13A04(c)(6) of Pennsylvania's lobbying disclosure
law ( "Lobbying Disclosure Law "), 65 Pa.C.S. § 13A04(c)(6), when she failed to
timely amend a Registration Statement filed with the Pennsylvania Department of
State to identify Lionsgate as a principal on whose behalf McCombs would engage
in lobbying for economic consideration.
2. McCombs violated Section 13A04 of the Lobbying Disclosure Law, 65 Pa.C.S. §
13A04, when she failed to register LHLT, LLC, a limited liability company, as a
lobbying firm with the Pennsylvania Department of State within ten days of acting in
the capacity as a lobbying firm.
3. A technical violation of Section 13A04(c) of the Lobbying Disclosure Law, 65
Pa.C.S. § 13A04(c), occurred when McCombs failed to list a daytime telephone
number for UPMC on a Registration Statement filed by her with the Pennsylvania
Department of State on January 8, 2007, regarding her employment as a lobbyist
for UPMC.
4. The transgressions of the Lobbying Disclosure Law outlined in paragraphs 1 -3
above are deemed to be negligent in nature.
5. Per the Consent Agreement of the parties, McCombs is directed to pay the agreed
upon administrative penalty in the total amount of $5,025.00, to be made payable to
the Commonwealth of Pennsylvania and forwa[ded to the Pennsylvania State Ethics
Commission by no later than the thirtieth (30 day after the mailing date of this
Order.
6. To the extent she has not already done so, McCombs is directed to file with the
Pennsylvania Department of State: (1) a Registration Statement for LHLT, LLC for
the years that said entity engaged in lobbying activity; and (2) an amended
Registration Statement listing the daytime telephone number for UPMC, and to
forward copies of all such filings to the Pennsylvania State Ethics commission for
compliance verification purposes by no later than the thirtieth (30 day after the
mailing date of this Order.
7 Compliance with paragraphs 5 and 6 of this Order will result in the closing of this
case with no further action by this Commission.
a. Non - compliance will result in the institution of an order enforcement action.
BY THE COMMISSION,
Name, Case #
Page 28
Louis W. Fryman, Chair