COLLECTION FINDING AID



PRESIDENT FORD COMMITTEE RECORDS

GENERAL COUNSEL'S OFFICE FILES, 1975-77




INTRODUCTION

The General Counsel's Office Files are an important resource for examining the legal issues involved in the operation of a presidential campaign committee. In addition the collection extensively documents the development of the Federal Election Commission, its role in regulating campaign finances, and PFC receipts and expenditures. Smaller, but important, segments concern aspects of PFC operations beyond the work of the legal staff, including notes on some high-level meetings and weekly reports of the Political Office field coordinators.

The General Counsel was the legal adviser to the President Ford Committee. His office, consisting of two lawyers and their secretaries, played an extremely important role in the 1976 presidential campaign.

The major differences between the PFC General Counsel's role and the role of lawyers in previous presidential campaigns were caused by the passage of the Federal Election Campaign Act Amendments of 1974. This legislation, signed into law by President Ford on October 15, 1974, established the first spending limits ever for candidates in presidential primary and general elections, provided for disclosure and reporting of campaign contributions and expenditures, introduced public financing for general election campaigns and matching funds to cover part of the costs of primary campaigns, and created a Federal Election Commission (FEC) to develop specific regulations implementing the law and enforce its provisions.

Because of delays in the appointment and confirmation of FEC members, the Commission did not begin its work until just before initial efforts to organize the PFC began. This meant that the PFC, like several other 1976 campaign committees, had to begin the process of running a campaign while frequently asking the FEC for guidance on procedures or filing complaints about possible violations by other campaign committees. The PFC General Counsel and his assistant handled these interactions with the FEC, while also working on more traditional campaign committee attorney tasks such as lawsuits, delegate challenges, contracts with consulting firms and staff members, coordinating the work of the PFC state legal counsels, and ballot security.

During the early months of the Ford campaign, Washington lawyer Dean Burch and members of his law firm handled much of the legal work under contract, but in September 1975, when the work became full-time, the PFC hired attorney Robert P. Visser as General Counsel. After a short time he added Tim Ryan as his assistant. Unlike most PFC offices, there was no staff turnover during the campaign, so Visser and Ryan handled the PFC's legal work through election day and even into the early part of 1977.

The files of the General Counsel's Office comprise a key resource for studying the changes in campaigning for President deriving from the implementation of the new campaign laws. The files also contain extensive files on the development of the FEC and its rules and regulations, including case files on each FEC meeting (usually attended by Visser or Ryan whose handwritten notes on the meeting or memoranda to the record often appear in the file). The General Counsel's Office Files also include significant materials on the Supreme Court decision in January 1976 which invalidated portions of the Federal Election Campaign Act and the development of the 1976 amendments to that law.

Visser or Ryan usually attended meetings of the Committee's Executive Committee, Advisory Committee, and Convention Cordinating Group. Although their material on those meetings is not extensive, it often includes either handwritten or typed notes on the discussions or memoranda listing assignments made to various staff members.

Materials on various lawsuits, contracts and other legal work conducted by the office also appears.

Related Materials (as of June 1990):

The files of Philip Buchen, Counsel to the President, contain materials on a number of campaign-related legal questions, including the Federal Election Campaign Act Amendments of 1974 and 1976 and White House interactions with the Federal Election Commission concerning proposed rulings and regulations. The staff files of John Marsh, Edward Schmults, and Rogers Morton also contain related materials, especially on the 1976 campaign law amendments. The White House Central Files Subject File contains material in categories FG 387 (Federal Election Commission) and PL (Political Affairs).


SERIES DESCRIPTIONS

General Counsel's Office: Political File, 1975­77.  (Boxes D1‑D15, 6.0 linear feet)
Memoranda, correspondence, strategy papers, agendas, schedule proposals, clippings, and printed material compiled by Callaway and his assistants, Mimi Austin and Judy Harbaugh. Prominent topics include early organizational efforts at the national and state level, liaison with White House staff, administrative and personnel matters, support for the President among members of Congress, and campaign finance. Included in several folders is material created by Bryce Harlow, an informal advisor to the President, during the period before the President formally announced his candidacy.

Arranged alphabetically by subject.

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General Counsel's Office: Federal Election Commission Subject File, 1975­76. (Boxes D16‑D30, 5.8 linear feet)
Memoranda, correspondence, reports, Congressional bills, notes, FEC advisory opinions, court briefs, congressional bills, press releases, and publications. The materials concern such topics as FEC reports submitted by the PFC and other campaign committees, the Supreme Court decision invalidating portions of the Federal Election Campaign Act and the passage of new amendments to that law, drafting FEC regulations, and complaints filed against various campaign committees.

Arranged alphabetically by subject.

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General Counsel's Office: Federal Election Commission Meetings File, 1975­76. (Boxes D30‑D35, 2.2 linear feet)
Case files on FEC meetings containing memoranda, correspondence, reports, agendas, minutes, and notes. The materials concern such topics as FEC organization and operation, drafting of regulations, and issuance of advisory opinions. Although some earlier material appears, the meetings best documented fall in the periods from September 1975 to February 1976 and late May to September 1976. The Supreme Court decision invalidating portions of the Federal Election Campaign Act left the Commission powerless to act during March, April, and part of May 1976.

Arranged chronologically by the meeting date.

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General Counsel's Office: General Subject File, 1975­76.  (Boxes D36‑D40, 2.0 linear feet)
Memoranda, correspondence, congressional bills, reports, legal briefs, and publications concerning court cases, legislation and actions of federal agencies. Topics include lawsuits by minor parties and independent candidates desiring to be included in the 1976 campaign debates, attempts to revise the Federal Communication Commission's "Equal Time Doctrine," Hatch Act reform legislation, the activities of a advisory group of lawyers who studied delegate selection procedures for the PFC, and the work of the PFC's state legal counsels.

Arranged alphabetically by subject.

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General Counsel's Office: State Legal File, 1975­76.  (Boxes D40‑D45, 2.0 linear feet)
Correspondence, memoranda, affidavits, notes, rules, committee reports, resolutions, by­laws, agendas, lists of nominees and delegates, vote tabulations, programs, ballot instructions, proof ballots, contracts, invoices, checks, and certificates. The materials document exchanges between the General Counsel's Office and state PFC legal counsels, other state PFC officers, local Republicans, federal and state agencies, and private law firms. The series relates primarily to interpretation of and compliance with federal and state campaign laws and Republican Party rules in the operations and procedures of local PFC offices, party precinct caucuses, and state conventions. Contents of some folders are routine, while challenges and disputes in other states yield substantial and interesting material. The Ford Library did not receive any folders for California or Virginia.

Arranged alphabetically by state.

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General Counsel's Office: Administrative Subject File, 1975­76.  (Boxes D46‑D48, 1.2 linear feet)
Routine memoranda, correspondence, leases, and resumes concerning such PFC administrative matters as budget and fiscal control, federal wage and hour laws, headquarters security, office rental, state bank accounts and possible candidates for employment.

Arranged alphabetically by subject.

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General Counsel's Office: State Receipt File, 1975­76.  (Boxes D49‑D51, 1.2 linear feet)
Routine cover memoranda from the General Counsel's Office to state Secretaries of State. The memoranda originally enclosed copies of amendments to Federal Election Commission registration forms, statements of organization, and reports of receipts and expenditures. The recipients removed these attachments, annotated the memoranda to indicate the material had been received, and returned them to the PFC as receipts.

Arranged alphabetically by state.

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CONTAINER LIST

Box D1 - General Counsel's Office: Political File

  • Advisory Committee
  • Advocates - Cabinet and Congressional: Guidelines, etc. (1)-(2)
  • Allocation of Campaign Expenses - Advocates
  • American Association of Political Consultants Panel
  • American Political Report (1)-(2)
  • Arthur Anderson and Company
  • Ballot Certifications - General Election (1)-(2)

Box D2 - General Counsel's Office: Political File

  • Ballot Security - General (1)-(3)
  • Ballot Security - Illinois
  • Ballot Security - Missouri
  • Ballot Security - Nixon/Agnew Campaign
  • Ballot Security - Publications
  • Ballot Security - Wisconsin
  • Block, Arthur
  • Brataas, Nancy (Telephone Campaign Consulting Firm)
    - Contract
    - General
    - Proposal
  • Campaign '76 Media Communications, Inc.
  • - Allocation of Costs

Box D3 - General Counsel's Office: Political File

  • Campaign '76 Media Communications, Inc.
    - CBS
    - Commercial Release Forms
    - Copy Clearance: Ads and Brochures (1)-(5)
    - General (1)-(4)
    - Personnel
    - Reports on Reagan Advertising

Box D4 - General Counsel's Office: Political File

  • Campaign '76 Media Communications, Inc.
    - Screen Actors Guild Contract (1)-(3)
    - SFM Media Service Corporation
    - Television Network Contracts (1)-(2)
    - Weekly Budget Reports
    - WGN Complaint (1)-(4)
  • Campaign Materials - General Election (1)-(2)

Box D5 - General Counsel's Office: Political File

  • Campaign Materials - Primary Election (1)-(2)
  • Carter Campaign - Carter Personal Finances (1)-(2)
  • Carter Campaign - Clippings
  • Carter Campaign - General (1)-(3)
  • Common Cause
  • Contracts and Agreements (1)-(3)

Box D6 - General Counsel's Office: Political File

  • Contracts and Agreements (4)-(5)
  • Convention
    - Challenges: District of Columbia
    - Challenges: General (1)-(2)
    - Challenges: Indiana
    - Challenges: Massachusetts
    - Challenges: Mississippi
    - Challenges: Missouri
    - Challenges: New Mexico
    - Challenges: North Carolina
    - Challenges: Ohio (1)-(2)
    - Challenges: Tennessee
    - Challenges: Texas
    - Challenges: Virginia
    - Challenges: Washington
    - Contracts (1)-(3)

Box D7 - General Counsel's Office: Political File

  • Convention
    - Coordinating Group (1)-(2)
    - Delegates: List
    - Delegates: Selection Procedures - Library of Congress Studies (1)-(3)
    - Delegates: Travel and Subsistence Payments
    - General (1)-(4)

Box D8 - General Counsel's Office: Political File

  • Convention
    - Legal (1)-(3)
    - Schedules (1)-(2)
    - State Certifications of Delegates (1)-(7)

Box D9 - General Counsel's Office: Political File

  • Dole, Robert
  • Donnelly (Reuben H.) Corporation - Consulting Contract
  • Drafts of Contracts, Agreements and Guidelines (1)-(3)
  • Evans - Novak Political Report (1)-(2)
  • Executive Committee Notes and Minutes
  • Expense Exclusion Forms
  • Fact Sheets (1)-(4)
  • Fair Campaign Practices Code
  • Fundraising
    - Checklist for Fundraisers (1)-(2)

Box D10 - General Counsel's Office: Political File

  • Fundraising
    - Direct Mail (1)-(3)
    - General (1)-(3)
    - Instructions for State Finance Chairmen (1)-(2)
    - Program in the 1972 Campaign
    - Reagan/Republican National Committee Film
    - Report
    - State Finance Chairmen (1)-(2)
    - Telephone Solicitations
  • Guidelines for Campaign Workers

Box D11 - General Counsel's Office: Political File

  • Heartland Material (1)-(2)
  • Important Dates - Presidential Preference Primaries (1)-(2)
  • Inaugural Committee Costs
  • Incorporation of the President Ford Committee
  • Indictments against Reagan and Hayakawa
  • Inside News (President Ford Committee Newsletter)
  • Liquidation Trust
  • Market Opinion Research Agreements (1)-(4)

Box D12 - General Counsel's Office: Political File

  • Market Opinion Research Agreements (5)-(7)
  • Midwest Republican Leadership Conference
  • People for Ford
    - American Business Volunteers for President Ford (1)-(3)
    - Black Desk
    - General (1)-(2)
    - Newsletters
    - Speaker's Kit
    - Youth: Food Service and Insurance Claims
  • Political - Miscellaneous (1)-(3)

Box D13 - General Counsel's Office: Political File

  • Political - Miscellaneous (4)-(7)
  • Polls and Surveys - Results (1)-(3)
  • Press
  • Press Releases - PFC
  • Press Releases - White House
  • Reagan Candidacy (1)-(3)

Box D14 - General Counsel's Office: Political File

  • Reagan - Texas Activity: Complaint (1)-(6)
  • Republican National Committee
    - Filings with the Federal Election Commission
    - General
    - Meeting 6/23-26/76 (1)-(2)
    - Relationship With PFC After Convention
    - Rules
  • Right Report
  • Senate Watergate Report
  • Southern States Republican Conference
  • State Campaign Spending Allocations

Box D15 - General Counsel's Office: Political File

  • Treasurer's Reports (1)-(5)
  • Unauthorized Ford Campaign Organizations
  • Weekly Reports - Field Coordinators (1)-(5)
  • Weekly Reports - Legal Office
  • Weekly Reports - President Ford Committee
  • Women for Ford
  • Youth Program - Ford

Box D16 - General Counsel's Office: Federal Election Commission Subject File

  • Advisory Opinion Requests
    - Campaign Contributions from a Partnership
    - Campaign '76 Media Communications, Inc.
    - Expenditure Limitations
    - General
    - Personal Services
    - PFC Accounting and Reporting Instructions and Procedures (1)-(2)
  • Advisory Opinions - General (1)-(2)
  • Audit of the President Ford Committee
  • Buckley v. Valeo
    - Brief for the Attorney General (1)-(2)
    - Court of Appeals Decision
    - General

Box D17 - General Counsel's Office: Federal Election Commission Subject File

  • Buckley v. Valeo
    - Memorandum in Support of an Injunction
    - Motions
    - Text of the Supreme Court Decision (1)-(4)
  • Campaign Guide
  • Citizens for Reagan Complaint Concerning Arrangements for the Republican National Convention
  • Compliance Action - Sheika Gramshammer
  • Contributions or Expenditures By National Banks, Corporations, or Labor Organizations
  • Docket
  • Federal Election Campaign Act Amendments of 1974
  • Federal Election Campaign Act Amendments of 1976
    - American Association of Political Consultants Recommendations
    - Background and Legislative History (1)-(2)

Box D18 - General Counsel's Office: Federal Election Commission Subject File

  • Federal Election Campaign Act Amendments of 1976
    - Compilation of Federal Election Laws (1)-(2)
    - Conference Committee Report (1)-(3)
    - General (1)-(3)
    - Hays Bill (1)-(4)

Box D19 - General Counsel's Office: Federal Election Commission Subject File

  • Federal Election Campaign Act Amendments of 1976
    - Pell Bill
    - Presidential Statements
    - S.3065 (1)-(3)
    - Section By Section Comparison
    - Text of Bill
    - Wiggins Substitute Bill
  • Federal Election Campaign Act of 1971 - Legislative History
  • Federal Election Campaign Laws
  • Federal-State Election Law Survey - Analysis of State Legislation, Federal Legislation and Judicial Decisions

Box D20 - General Counsel's Office: Federal Election Commission Subject File

  • Filings
    - Bayh, Birch
    - Bentsen, Lloyd
    - Carter, Jimmy (1)-(2)
    - Church, Frank
    - Connally, John
    - Democratic Presidential Campaign Committee (1)-(7)
    - Harris, Fred
    - Jackson, Henry (1)

Box D21 - General Counsel's Office: Federal Election Commission Subject File

  • Filings
    - Jackson, Henry (2)-(3)
    - McCarthy, Eugene
    - Reagan, Ronald: 10/75-12/75 (1)-(4)
    - Reagan, Ronald: 1/76 (1)-(3)

Box D22 - General Counsel's Office: Federal Election Commission Subject File

  • Filings
    - Reagan, Ronald: 2/76 (1)-(5)
    - Reagan, Ronald: 3/76
    - Reagan, Ronald: 6/76 (1)-(2)
    - Sanford, Terry
    - Shapp, Milton
    - Shriver, Sergeant
    - Udall, Morris
    - Wallace, George
  • Forms (1)-(3)

Box D23 - General Counsel's Office: Federal Election Commission Subject File

  • Major Provisions of the Federal Election Law (Publication)
  • MUR 154(76) - Complaint Re Citizens for Reagan (Texas)
  • MUR 198(76) - Complaint Re Excess Contributions
  • MUR 237(76) - Complaint Re Businessmen for Ford
  • MUR 246(76) - Complaint Re Books for Carter at State Expense
  • MUR 304(76) - Complaint re Newsweek/Playboy Copyright and Disclaimer Omissions
  • MUR 320(76) - Complaint Re AFL-CIO and Affiliated Unions
  • News Releases From the FEC
  • Opinions of Counsel (1)-(2)
  • President's Certification for General Election Funding
  • Primary Matching Funds (1)-(4)

Box D24 - General Counsel's Office: Federal Election Commission Subject File

  • Primary Matching Funds (5)
  • Registration Form and Amendments (1)-(9)
  • Regulations
    - Allocation of Expenses
    - Contribution and Expenditure Limitation

Box D25 - General Counsel's Office: Federal Election Commission Subject File

  • Regulations
    - Corporate and Labor Organizations Activity (1)-(2)
    - Disclosure, Limitations and Independent Expenditures (1)-(2)
    - General Election Financing
    - Government Contractors
    - Office Accounts
    - Primary Matching and Advisory Opinions
    - Proposal to Congress
  • Report on Contributors to the PFC
  • Reports on Receipts and Expenditures (PFC) - Memoranda
  • Reports on Receipts and Expenditures (PFC) - Summary (1)-(2)

Box D26 - General Counsel's Office: Federal Election Commission Subject File

  • Reports on Receipts and Expenditures (PFC) - 6/75-12/75

Box D27 - General Counsel's Office: Federal Election Commission Subject File

  • Reports on Receipts and Expenditures (PFC) - 1/76-9/76

Box D28 - General Counsel's Office: Federal Election Commission Subject File

  • Reports on Receipts and Expenditures (PFC) - 10/76-11/76

Box D29 - General Counsel's Office: Federal Election Commission Subject File

  • Reports on Receipts and Expenditures (PFC) - 12/1976 (1)-(4)
  • Title 2 Regulations (Reporting and Disclosure) - General (1)-(4)
  • Title 2 Regulations (Reporting and Disclosure) - Old Drafts (1)-(3)

Box D30 - General Counsel's Office: Federal Election Commission Subject File

  • Title 2 Regulations (Reporting and Disclosure) - Testimony at Hearings (1)-(2)
  • Union Expenditures - 1976 Election (1)-(2)
  • Volunteer Guide
  • General Counsel's Office: FEC Meetings File
  • Federal Election Commission Meetings, 4/22/75-9/15/75

Box D31 - General Counsel's Office: Federal Election Commission Subject File

  • Federal Election Commission Meetings, 9/18/75-10/14/75

Box D32 - General Counsel's Office: Federal Election Commission Subject File

  • Federal Election Commission Meetings, 10/16/75-11/13/75 (1)

Box D33 - General Counsel's Office: Federal Election Commission Subject File

  • Federal Election Commission Meetings, 11/13/75 (2)-12/11/75

Box D34 - General Counsel's Office: Federal Election Commission Subject File

  • Federal Election Commission Meetings, 12/16/75-1/22/76

Box D35 - General Counsel's Office: Federal Election Commission Subject File

  • Federal Election Commission Meetings, 1/29/76-2/26/76 and 5/21/76-9/23/76

Box D36 - General Counsel's Office: Federal Election Commission Meetings File

  • Advisory Committee on Protection of Presidential Candidates
  • American Bar Association (Publications)
  • Anderson v. Ford Case - Presidential Debates (1)-(3)
  • Beall v. Sarbanes Case - Maryland AFL-CIO
  • Campaign Practices Report
  • Common Situs Picketing Bill
  • Federal Communications Commission - Equal Time Doctrine (1)-(3)

Box D37 - General Counsel's Office: Federal Election Commission Meetings File

  • Federal Communications Commission - Equal Time Doctrine (4)-(6)
  • Federal Communications Commission - Licensee Obligations
  • Federal Criminal Code (1)-(2)
  • Federal Employees Political Participation - Hatch Act (1)-(3)
  • Fundraising - Fred Wilson Matter
  • General Correspondence (1)-(2)

Box D38 - General Counsel's Office: Federal Election Commission Meetings File

  • Hamel, Park, McCabe and Saunders - Legal Opinions
  • Injunctions - Political Campaigns (Published Article)
  • Internal Revenue Service (1)-(2)
  • Lawyers Panel on Delegate Selection (1)-(6)
  • Maddox, Lester
  • Martin, Terry
  • Martin-Trigon v. Ford Case - Use of Federal Matching Funds
  • Mason, James

Box D39 - General Counsel's Office: Federal Election Commission Meetings File

  • McCarthy v. Carter Case - Campaign Debates (1)-(7)
  • McCarthy, Eugene J. (1)-(2)
  • Miscellaneous Research (1)-(2)

Box D40 - General Counsel's Office: Federal Election Commission Meetings File

  • Miscellaneous Research (3)
  • Morgan, Marc
  • Morton, Ron - Campaign Finance: National Bank of Georgia
  • Peyser, Peter
  • Pierson, Ball and Doud - Legal Fees
  • Ripon Society - Rule 30 (1)-(2)
  • Secchia, Peter
  • Secretaries of State
  • State Campaign Laws
  • State Legal Counsels - General (1)-(2)
  • State Legal Counsels - Possible Litigation Against PFC
  • Voter Registration Act
  • Voting Rights and Qualifications

Box D41 - General Counsel's Office: State Legal File

  • Alabama
  • Alaska
  • Arizona
  • Arkansas
  • California (Folder not received by Ford Library)
  • Colorado
  • Connecticut
  • Delaware
  • District of Columbia (1)-(2)
  • Florida
  • Georgia
  • Hawaii

Box D42 - General Counsel's Office: State Legal File

  • Idaho
  • Illinois (1)-(2)
  • Indiana
  • Iowa
  • Kansas
  • Kentucky
  • Louisiana
  • Maine
  • Maryland
  • Massachusetts (1)-(3)
  • Michigan (1)-(2)
  • Michigan - Primary Ballot Proofs

Box D43 - General Counsel's Office: State Legal File

  • Minnesota
  • Mississippi
  • Missouri (1)-(2)
  • Montana
  • Nebraska
  • Nevada
  • New Hampshire (1)-(3)
  • New Jersey
  • New Mexico
  • New York
  • North Carolina (1)-(2)
  • North Dakota

Box D44 - General Counsel's Office: State Legal File

  • Ohio
  • Oklahoma
  • Oregon (1)-(2)
  • Pennsylvania
  • Rhode Island (1)-(2)
  • South Carolina
  • South Dakota
  • Tennessee (1)-(2)

Box D45 - General Counsel's Office: State Legal File

  • Texas
  • Utah
  • Vermont
  • Virginia (Folder not received by Ford Library)
  • Washington (1)-(3)
  • West Virginia
  • Wisconsin (1)-(2)
  • Wyoming
  • Guam, Puerto Rico, Virgin Islands

Box D46 - General Counsel's Office: Administrative Subject File

  • Authorization to Incur Expenses - Filed Copies (1)-(2)
  • Budget and Fiscal Control (1)-(2)
  • Employee Withholding
  • Federal Wage and Hour Laws (1)-(4)
  • Forms
  • Kastle Systems - Security
  • Lease - 1200 18th Street, N.W., Washington
  • Leases - State Offices: General Election (1)-(2)

Box D47 - General Counsel's Office: Administrative Subject File

  • Leases - State Offices: General Election (3)
  • MCI Communications Company
  • Memoranda - Callaway, Bo
  • Memoranda - Chairman's Office
  • Memoranda - Cochran, James
  • Memoranda - Political Office
  • Memoranda - Staff (1)-(3)
  • Memoranda - Treasurer's Office
  • Resumes - General (1)-(4)

Box D48 - General Counsel's Office: Administrative Subject File

  • Resumes - General (5)
  • Resumes - Legal (1)-(6)
  • Staff Expense Allocations
  • State Bank Accounts (1)-(5)
  • Stationery, Mailings, Reply Cards, and Contributor Cards
  • Stock Transfer Authorization
  • Workers Compensation Policy

Box D49 - General Counsel's Office: State Receipt File

  • Multi-State General Mailings and Alabama - Kansas

Box D50 - General Counsel's Office: State Receipt File

  • Kentucky - Ohio

Box D51 - General Counsel's Office: State Receipt File

  • Oklahoma - Wyoming and Territories