MUR #7056

RESPONDENTS: Victor, Adam H.; Block, Mark J.; Bruggerman, Jo-Ann; Cain, Herman; Coulter, Garry; Dani, Marta; Friends of Herman Cain, Inc.; Harris, Randall; Larrinaga, Roberto; Pegasus Elite Aviation, Inc.; Transnational Management Systems II LLC; Transnational Management Systems LLC; USA Risk Intermediaries, LLC; Victor, Adam; Victor, Alexia; Victor, Alicia; Victor, Jo-Ayla; Yoshioka, Nana

COMPLAINANT: Erdman, Tyler

SUBJECT: Contributions-Limitations; Contributions-In the name of another; Contributions-Corporations

DISPOSITION: The Commission decided by a vote of 5-0 to take the following actions in MURs 7005 and 7056: MURs 7005 and 7056 1. Accept the signed conciliation agreement with Adam H. Victor and TransGas Development Systems, LLC, as recommended in the Memorandum to the Commission dated July 26, 2017. 2. Dismiss the allegations that Marta Dani (formerly Marta Grabowska), Nana Yoshioka, Randall Harris, Adam Victor, Jr., Alexia Victor, Alicia Victor, Jo-Ayla Victor, and Jo-Ann Bruggemann violated 52 U.S.C. § 30122. 3. Find no reason to believe that Garry Coulter violated 52 U.S.C. § 30122. MUR 7005 1. Dismiss the allegations that Adam Victor Grantor Trust, Noel Daley, Michael C.J. Vanderkemp, and Project Orange Associates LLC violated 52 U.S.C. § 30122. 2. Find no reason to believe that, TransGas Energy Systems LLC, Gas Alternative Systems, Inc., or Adam Victor & Son Stables LLC violated 52 U.S.C. § 30122. 3. Approve the appropriate letters. 4. Close the file. MUR 7056 1. Find no reason to believe that Roberto Larrinaga or USA Risk Intermediaries LLC violated 52 U.S.C. § 30122. 2. Approve the appropriate letters. 3. Close the file.
The Commission decided by a vote of 5-0 to take the following actions in the above-captioned matter: 1. Enter into pre-probable cause conciliation with Adam H. Victor prior to a finding of probable cause to believe. 2. Approve the proposed conciliation agreement, as recommended in General Counsel’s Report #2 dated April 5, 2017, subject to the edits circulated by Commissioner Goodman’s office on April 20, 2017 at 4:02 p.m. 3. Edit the document before the Commission to transpose the names of the respondents so that Adam H. Victor appears first and TransGas Development Systems, LLC appears second in the caption. 4. Approve the appropriate letter.
The Commission decided by a vote of 6-0 to grant the Department of Justice Request for Documents Concerning Adam H. Victor, as recommended in the Memorandum from the Acting General Counsel dated January 3, 2017.
The Commission decided by a vote of 6-0 to approve the Subpoenas to Produce Documents and Orders to Submit Written Answers to Adam H. Victor, Jo-Ann Bruggemann, Alexia Victor, Alicia (“Alia”) Victor, Garry Coulter, Marta Dani (f/k/a Grabowska), Randall Harris, Jo-Ayla Victor, Nana Yoshioka, and Adam Victor, Jr., as recommended in the Memorandum from the Acting General Counsel dated November 7, 2016.
The Commission decided by a vote of 6-0 to take the following actions in MURs 7005 and 7056: 1. Find reason to believe that Adam H. Victor violated 52 U.S.C. §§ 30116(a) or 30118(a), and 30122 in connection with alleged contributions in the name of another. 2. Find reason to believe that TransGas Development Systems, LLC violated 52 U.S.C. §§ 2. 30116(a) or 30118(a), and 30122 in connection with alleged contributions in the name of another. 3. Find no reason to believe Adam H. Victor violated 52 U.S.C. §§ 30116(a) or 30118(a) in connection with the leasing of an airplane to Friends of Herman Cain. 4. Find no reason to believe that Transnational Management Systems II, LLC violated 52 U.S.C. §§ 30116(a) or 30118(a) and close the file as to it. 5. Find no reason to believe Pegasus Elite Aviation, Inc. violated 52 U.S.C. § 30118(a) and close the file as to it. 6. Find no reason to believe that Herman Cain or Friends of Herman Cain and Mark J. Block in his official capacity violated 52 U.S.C. §§ 30116(f) or 30118(a) and close the file as to it. 7. Find no reason to believe that Transnational Management Systems LLC violated the Act and close the file as to them. 8. Take no action at this time with respect to Adam Victor, Jr., Alexia Victor, Alicia Victor, Jo-Ayla Victor, Jo-Ann Bruggemann, Garry Coulter, Marta Dani (formerly Marta Grabowska), Nana Yoshioka, Randall Harris, TransGas Energy Systems LLC, Gas Alternative Systems, Inc., Project Orange Associates LLC, Adam Victor & Son LLC, Adam Victor Grantor Trust, USA Risk Intermediaries LCC, Noel Daley, Michael C. J. Vanderkemp, and Roberto Larranga with respect to the alleged contributions in the name of another. 9. Approve the Factual and Legal Analyses as recommended in the First General Counsel’s Report dated October 5, 2016 for Transnational Management Services LLC, Herman Cain, Friends of Herman Cain and Mark J. Block in his official capacity as treasurer, and Pegasus Elite Aviation, Inc.; and as recommended in the First General Counsel’s Report dated October 5, 2016 for Adam H. Victor, TransGas Development Systems LLC, and Transnational Management Services II, LLC subject to the edits last circulated by Commissioner Ravel’s Office on October 24, 2016 at 4:02 p.m. 10. Authorize the use of compulsory process, as necessary. 11. Approve the appropriate letters.
The Commission decided by a vote of 6-0 to take the following actions in MURs 7005 and 7056: 1. Find reason to believe that Adam H. Victor violated 52 U.S.C. §§ 30116(a) or 30118(a), and 30122 in connection with alleged contributions in the name of another. 2. Find reason to believe that TransGas Development Systems, LLC violated 52 U.S.C. §§ 30116(a) or 30118(a), and 30122 in connection with alleged contributions in the name of another. 3. Find no reason to believe Adam H. Victor violated 52 U.S.C. §§ 30116(a) or 30118(a) in connection with the leasing of an airplane to Friends of Herman Cain. 4. Find no reason to believe that Transnational Management Systems II, LLC violated 52 U.S.C. §§ 30116(a) or 30118(a) and close the file as to it. 5. Find no reason to believe Pegasus Elite Aviation, Inc. violated 52 U.S.C. § 30118(a) and close the file as to it. 6. Find no reason to believe that Herman Cain or Friends of Herman Cain and Mark J. Block in his official capacity violated 52 U.S.C. §§ 30116(f) or 30118(a) and close the file as to it. 7. Find no reason to believe that Transnational Management Systems LLC violated the Act and close the file as to them. 8. Take no action at this time with respect to Adam Victor, Jr., Alexia Victor, Alicia Victor, Jo-Ayla Victor, Jo-Ann Bruggemann, Garry Coulter, Marta Dani (formerly Marta Grabowska), Nana Yoshioka, Randall Harris, TransGas Energy Systems LLC, Gas Alternative Systems, Inc., Project Orange Associates LLC, Adam Victor & Son LLC, Adam Victor Grantor Trust, USA Risk Intermediaries LCC, Noel Daley, Michael C. J. Vanderkemp, and Roberto Larranga with respect to the alleged contributions in the name of another. 9. Approve the Factual and Legal Analyses as recommended in the First General Counsel’s Report dated October 5, 2016 for Transnational Management Services LLC, Herman Cain, Friends of Herman Cain and Mark J. Block in his official capacity as treasurer, and Pegasus Elite Aviation, Inc.; and as recommended in the First General Counsel’s Report dated October 5, 2016 for Adam H. Victor, TransGas Development Systems LLC, and Transnational Management Services II, LLC subject to the edits last circulated by Commissioner Ravel’s Office on October 24, 2016 at 4:02 p.m. 10. Authorize the use of compulsory process, as necessary. 11. Approve the appropriate letters.