Time: Wed Aug 20 06:28:01 1997
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Date: Wed, 20 Aug 1997 06:18:56 -0700
To: (Recipient list suppressed)
From: Paul Andrew Mitchell [address in tool bar]
Subject: SLS: WHITEWATER: THE CONSPIRACY OF SILENCE (fwd)
<snip>
>
>http://citizensunited.org/cu/ww/monograph/
>
>WHITEWATER: THE CONSPIRACY OF SILENCE
>A Citizens United Monograph
>
> THE EARLY YEARS
>
>The seeds of the Whitewater scandal were planted in the late 1970s. In
>August 1978, Bill Clinton, who was then Arkansas attorney general, and
>his wife, Hillary Rodham, joined James McDougal and his wife, Susan, in
>purchasing a 230+ acre tractof land located south of Crooked Creek and
>west of the White River in Marion County, Arkansas.1 Jim McDougal and
>Bill Clinton were long-time friends, having met when they worked
>together on Senator J. William Fulbright's (D-AR) staff in Washington,
>D.C. in the late 1960s.2
>
> NO MONEY DOWN
>
>The Clintons and McDougals purchased the Whitewater tract from 101
>River Development, Inc. for $202,611.20. The purchase was financed by a
>$186,611.20 mortgage through the Citizens Bank & Trust Company.3 The
>bank's president, James Patterson, Jr., was also corporate secretary of
>101 River Development, Inc.4 The mortgage suggests the Clintons and
>McDougals made a $20,000 down payment on the property. However, records
>indicate the down payment was financed by a $20,000 unsecured loan from
>Union National Bank of Little Rock which was personally signed for by
>Bill Clinton and Jim McDougal.5
>
>In November 1978, Bill Clinton was elected to his first term as
>governor of Arkansas. Shortly after taking office, Clinton made Jim
>McDougal his top economic advisor.6
>
> $48,000 PAPER PROFIT
>
>In June 1979, the Clintons and McDougals formed the Whitewater
>Development Company, Inc. (WDC).7 The primary objective of WDC was
>"[t]o engage in the business of owning, selling, developing, managing
>and improving real property."8 On September 30, 1979, the two couples
>sold their interests in the Whitewater land tract to their newly formed
>WDC.9 While the exact selling price has not been made public, real
>estate transfer tax payments suggest the price was in the neighborhood
>of $250,000.10 This would indicate a capital gain of about $48,000 for
>the Clintons and McDougals. However the gain appears to have been more
>a paper profit than a realized cash gain, as there are no publicly
>available records indicating a cash transfer from WDC to the Clintons
>and McDougals at the time of the property sale. In addition, the
>Clintons and McDougals remained personally obligated for the mortgage
>on the tract.
>
> 1980s: DECADE OF GREED IN ARKANSAS
>
>Although Bill Clinton was Arkansas' leading political figure throughout
>the 1980s, his political career received a serious jolt when he lost
>his campaign for re-election during the Reagan landslide of 1980. As
>was the case with many Democrats, liberalism and high taxes were major
>factors in Clinton's humiliating defeat at the polls. After leaving
>office, Clinton joined the Little Rock law firm of Wright, Lindsey &
>Jennings where he practiced law and planned his political comeback.11
>
>With Bill Clinton out of office, Jim McDougal left state government to
>go into the banking business. He purchased Madison Bank & Trust of
>Kingston, Arkansas, which he later renamed Madison Bank & Trust.12
>
>UNUSUAL LAND TRANSACTIONS
>
>1980 also saw a series of unusual transactions involving the Clinton
>and McDougal-owned Whitewater Development Company.
>
>On October 14, Whitewater lot #7, which was described as "its best
>piece of land," was sold to Chris V Wade &Associates (a.k.a. Ozarks
>Realty Co.) for approximately $2,000. The next day, Chris V Wade &
>Associates resold the lot for approximately $35,000,13 a profit of
>1,650 percent in just 24 hours.
>
>Adding to the intrigue of this series of transactions is Chris Wade's
>relationship with the Clintons and McDougals. Wade was the real estate
>agent who represented the two couples in their Whitewater venture.14
>Moreover he has publicly disputed the Clintons' claim that they lost
>money on their Whitewater investment.15
>
>Another extraordinary transaction involved Hillary Clinton, then known
>as Hillary Rodham. On December 16, McDougal's Bank of Kingston loaned
>Hillary $30,000 to build what was called a "model home" on WDC lot
>#13.16 On December 28,lot # 13 was transferred from WDC to Hillary
>Rodham.17 The next day, $30,000 was deposited in the WDC account at the
>Bank of Kingston.18 While a home was eventually built on lot #13, it
>apparently was not a "model home." On November 10,1981, Hillary Rodham
>sold lot #13 and the home to Mr. Hillman Logan for $27,500.19 It is
>unclear from publicly available documents whether Hillary suffered an
>actual loss on this series of transactions or whether her paper loss
>was somehow covered by WDC. It is known that as late as January 8,
>1982, WDC made a $6,361.65 interest payment on Hillary's loan to
>Madison Bank & Trust (the Bank of Kingston having been renamed by Jim
>McDougal).20 Hillary was receiving reimbursement for 1983 property tax
>payments on the lots as late as November 1984.21 Additionally, bank
>records indicate that the $30,000 model home mortgage was not fully
>paid off until October 19, 1983, almost two years after Hillary sold
>thelot.22 The mortgage pay-off was apparently made possible by a
>$20,800 personal loan to Bill Clinton from the Security Bank of
>Paragould. The check was made payable to Madison Bank & Trust and noted
>as "loan proceeds for Gov. BillClinton."23
>
> JIM MCDOUGAL BUYS THE PIGG YBANK
>
>Hillary was not the only member of the Clinton household to receive
>credit from McDougal's bank. On February 20, 1982 ,Bill Clinton wrote a
>personal check for $20,744.65 to Madison Bank & Trust. A notation in
>the lower left-hand comer of the check reads, "Re-payment of loan."24
>
>The Lyons report, issued by Bill Clinton's 1992 presidential campaign
>for damage control, apparently included this loan as part of the
>Clintons' Whitewater investment. It accounted for a large portion of
>the nearly $70,000 loss the Clintons were claiming. But during his
>March 25, 1994 news conference, President Clinton said he now recalls
>that the loan was actually for a cabin built for his late mother.25 It
>is hard to imagine that someone who had been earning about $35,000
>before taxes would not remember making a $20,800 loan to his mother. In
>any case, this particular loan had nothing to do with Whitewater and
>should not have been listed as part of the Clintons' capital
>investment.
>
>1982 was also the year Jim McDougal purchased Madison Guaranty Savings
>& Loan (Madison S&L), which should not be confused with the McDougal-
>owned Madison Bank & Trust.26 At the time, Madison S&L had
>approximately $6 million in liabilities. By 1985, however Madison S&L
>liabilities had grown to more than $123 million, due largely to
>speculative real estate loans.27 The S&L was shut down by federal
>regulators in 1989 at a cost to taxpayers of approximately $60
>million.28
>
> CLINTON STAGES POLITICAL COMEBACK
>
>In November 1982, Bill Clinton made his political comeback by winning
>the governorship by a 55-45 percent margin, becoming the first Arkansas
>governor to regain the office after losing it in a prior election. But
>Jim McDougal was not so lucky. He lost his bid to win a seat in
>Congress to long-time GOP incumbent John Paul Hammerschmitt.
>
>By 1983, Capital Management Services, Inc. (CMS), a federally insured
>small business investment company owned by judge David Hale, had begun
>making sizable loans to members of the Arkansas political elite and
>their friends. On September 16, a $50,000 loan was made to County
>Cable, Inc., a company owned and operated by Jim Guy Tucker.29 On
>November 30, an additional $50,000 CMS loan was issued to County
>Cable.30
>
>The problem with these seemingly innocent loans is that Capital
>Management Services was licensed by the Small Business Administration
>(SBA). As such, it was limited to lending to businesses that were
>socially or economically disadvantaged. A man of considerable personal
>wealth, Jim Guy Tucker was hardly qualified to receive these loans.
>
>Tucker is currently governor of Arkansas, having moved up from the
>position of lieutenant governor following Bill Clinton's election to
>the presidency. At the time of the CMS loans, Tucker was a partner in
>the law firm of Mitchell, Williams, Selig, Jackson & Tucker,31 a law
>firm that also served as legal counsel to Madison S&L. The attorney who
>performed the bulk of the fires legal work for Madison was none other
>than Beverly Bassett Schaffer, whom Gov. Clinton would later appoint as
>head of the Arkansas Securities Commission.32 In addition to the CMS
>loans, Tucker also secured business loans from Madison S&L.33
>
> S&L, DEPOSITORS COVER WHITEWATER OVERDRAFTS
>
>By 1984, WDC had begun running negative balances in its checking
>accounts at both Madison Bank & Trust and Madison S&L. According to
>Congressman Jim Leach (R-IA), ranking Republican on the House Banking
>Committee, these overdrafts often resulted from payments on loans for
>which Bill and Hillary Clinton were personally liable.34 For example,
>on October 4, 1984, WDC made a $4,811.19 payment on a personal loan of
>Bill Clinton's from the Security Bank ofParagould.35 This was the
>unsecured personal loan used to pay off the balance on the Whitewater
>lot # 13 mortgage for which Hillary Clinton was personally liable.
>Documents indicate that $2,811.19 of this payment was for interest,
>which the Lyons report concludes the Clintons inadvertently deducted
>from their personal taxes.36 Check stubs from the WDC account indicate
>the payment resulted in an overdraft of more than $2,900.37 On November
>11, 1985, WDC made a$7,322.42 payment on a Bill Clinton loan from
>Security Bank of Paragould. However this payment was drawn on WDC's
>account at Madison S&L, resulting in a $7,309.93 overdraft in the
>account.38 The check was covered the following day bya $7,500 deposit
>from Madison Marketing.39
>
>On paper, Madison Marketing was owned and operated by Susan McDougal.
>But in reality it appears that it was an arm of Madison S&L and its
>subsidiary, Madison Financial Corporation.
>
>Like her husband, Susan McDougal served on the Madison S&L Board of
>Directors. In fact, Susan served as the S&L corporate secretary and
>treasurer.40 According to a 1986 report of the Federal Home Loan Bank
>Board (FHLBB),Madison Marketing was set up for the sole purpose of
>handling advertising for Madison S&L and Madison Financial Corporation,
>Madison Marketing's only clients.41 Beginning in 1983, more than $1.5
>million was funnelled through the S&L and its subsidiary.42
>Approximately $200,000 of this amount was for the so called services of
>Madison Marketing, which, according to the FHLBB report, amounted to
>little more than adding its 15% fee to the bills of various advertising
>venders and passing them along to Madison S&L.43 Additionally, Rep.
>Leach says records on file with the Arkansas secretary of state
>indicate that on July 26, 1986, Madison Financial Corporation filed an
>application for registration to do business under the name "Madison
>Marketing." Rep. Leach contends it is likely that this filing was
>prompted by the FHLBB report which cited Madison Financial Corporation
>for having failed to register as doing business under a fictitious
>name.44 According to Rep. Leach, this interwoven relationship between
>Madison Marketing, Madison Financial Corporation, and Madison S&L
>provides an illustrative example of how Madison S&L depositor funds
>were used to cover WDC overdrafts resulting from WDC's payments on
>loans for which the Clintons were personally liable.45
>
> FEDERAL REGULATORS EYE MADISON S&L
>
>As mentioned above, federal regulators issued their first report on
>January 20, 1984, raising serious questions about the financial
>stability of Madison S&L. The FHLBB report concluded that:
>
> The viability of the institution is jeopardized through the
>institution's current investment and lending practices in real estate
>development projects. There is a concentration of assets and loans in
>land and development type properties. Prudent investment practices have
>not been utilized in development projects and poor loan underwriting is
>characteristic of loans originated. These long-term investments and
>loans have been funded with short-term brokered deposits.
>
> Substantial profits from the service corporation on the sale of real
>estate owned have been improperly recognized. Such profits were
>recognized as a result of contract sales and submarket interest rates.
>Correcting entries will adversely affect the net worth and result in
>an insolvent position.46
>
>The report was especially critical of the S&L's management and its
>Board of Directors, citing its "limited savings and loan industry
>background."47 The report pointed out that no one in the S&L top
>management had any S&L experience prior to joining Madison. Federal
>auditors warned that the operations and activities of the S&L "warrant
>close supervisoryattention."48
>
> HILLARY TO THE RESCUE
>
>Jim McDougal's reaction to the FHLBB report was to seek help from his
>friends in high places. Hillary Rodham of the powerful Rose Law Firm
>was eventually placed on a $2,000 per month retainer by Madison S&L.
>According to McDougal, this financial arrangement was made through Gov.
>Clinton, who stopped by the S&L during his morning jog through Little
>Rock. Hillary's principal role was to deal with the state securities
>commission, which, by then, was scrutinizing the S&L finances.49
>
>There is another side to this transaction. According to published
>reports, McDougal claims that he put Hillary on retainer solely to
>augment the Clintons' financial situation: "I asked him how much he
>needed, and Clinton said 'about $2,000 a month'... I hired Hillary
>because Bill came in whimpering they needed help."50
>
>Meanwhile, Gov. Clinton needed an infusion of cash to finance his re-
>election campaign. Instead of turning to Madison S&L, which, at the
>time, was undergoing intense scrutiny, Clinton turned to his senior
>campaign aide, Maurice Smith, who owned the Bank of Cherry Valley.
>Smith's bank loaned Clinton $50,000.51 In November 1984, Gov. Clinton
>was easily re-elected with 64% of the vote.
>
>In addition to the campaign loan, the Bank of Cherry Valley apparently
>loaned money to help underwrite the Clintons' and McDougals' Whitewater
>investment. On December 4, WDC made a $3,276-18 loan payment to the
>Bank of Cherry Valley. WDC check stubs indicate the payment resulted in
>a $9,162.53 overdraft in the company's Madison Bank & Trust checking
>account.52
>
> FRIENDS IN HIGH PLACES
>
>On January 16, 1985, while the Arkansas State Securities Commission was
>investigating Madison S&L, Gov. Clinton appointed his close friend
>Beverly Bassett Schaffer to serve as Arkansas State Securities
>Commissioner.53 Ms. Schaffer had served as legal counsel for Madison
>S&L when she worked at the law firm of Mitchell, Williams, Selig,
>Jackson &Tucker. McDougal claims that he recommended to Gov. Clinton
>that Schaffer be appointed to this position.54
>
>On March 1, Madison S&L's accounting firm, Frost & Company, issued a
>report claiming the S&L was. actually solvent. The Frost report claimed
>that as of December 31, 1984, Madison had assets of $48,961,154 and
>liabilities of$48,818,206. The S&L was reported to have a net worth of
>$142,948.55 The Frost report was a major tool used by Hillary Clinton
>in persuading Beverly Bassett Schaffer and the State Securities
>Commission to allow Madison S&L to remainopen.56 Coincidentally,
>Frost's chief auditor on the Madison project, James Alford, had two
>outstanding loans at Madison at the time.
>
>Soon after the Frost report was issued, Gov. Clinton appointed Madison
>S&L CEO, John Latham, to the state's Savingsand Loan Board.57 The
>appointment followed a strong recommendation from Jim McDougal, who
>referred to Mr. Lathamas "a major contributor to your campaign."58 In
>1989, Latham pleaded guilty to falsifying Madison's records.59
>
>In 1985, Hillary Clinton and the Rose Law Firm were officially brought
>in to represent Madison S&L with its proposal for a public stock
>offering.60 On April 30, Hillary presented the S&L's recapitalization
>proposal to Ms. Schaffer.61 Despite warnings of the S&L's impending
>failure from a State Securities Commission member, on May 14 Ms.
>Schaffer informed Hillary Clinton that the plan was approved, having
>accepted the Rose Law Firm's legal analysis of the proposal.62 However
>the public stock offering was never implemented.
>
>On April 3, Jim McDougal withdrew approximately $30,000 from the WDC
>account at Madison S&L, calling it a "loan repayment." The withdrawal
>caused a $28,000 overdraft in the WDC account.63 On April 17, Madison's
>real estate subsidiary, Madison Financial Corporation, covered the
>deficit by authorizing the deposit of Jim McDougal's $30,000"annual
>bonus" to the WDC account.64
>
> MADISON DEPOSITORS BAIL OUT CLINTON CAMPAIGN
>
>On the day after his withdrawal of $30,000 from WDC's account at
>Madison S&L, McDougal hosted a fund-raising event which raised
>approximately $30,000 to help Bill Clinton repay the balance on his
>1984 campaign loan from the Bank of Cherry Valley.65 At least one of
>the reported contributors to this fund-raiser denies having made the
>contribution that bears his name. According to Clinton campaign
>records, Kenneth Peacock, then a 24-year-old college student, was
>credited with a $3,000 contribution made in the form of a Madison S&L
>cashier's check.66 Mr. Peacock denies having made thiscontribution.67
>However, Mr. Peacock's father Charles Peacock, who was a major borrower
>at Madison S&L and at onetime served on the S&L's Board of Directors,
>claims to have made the loan in his son's name.68 Other contributions
>that have come under scrutiny include a $3,000 contribution attributed
>to the late Dean Landrum, who was an employee of Charles Peacock, and a
>$3,000 contribution attributed to Jim McDougal's wife, Susan.69 The
>Washington Post reported that the Resolution Trust Corporation (RTC)
>believes as much as $60,000 in Madison S&L depositor funds was diverted
>to the 1984 Clinton campaign.70
>
>On May 30, 1985 Whitewater's tangled web became even more complicated.
>WDC traded two dozen lots to Ozark Air Services, Inc. for an airplane
>purportedly valued at $35,000.71 It was actually Chris Wade who gained
>possession of the lots and Jim McDougal who gained possession of the
>airplane. "I had an airplane and no money, and they had the lots,"
>recalled Wade in a subsequent interview.72 McDougal eventually sold the
>airplane to a Little Rock flying service. The following day, the flying
>service sold the plane to one of McDougal's employees, who reportedly
>financed the purchase through MadisonS&L.73 Citizens United has been
>advised that the McDougal employee who purchased the aircraft was Seth
>Ward. Mr. Ward is the father-in-law of former Associate Attorney
>General Webster Hubbell, who resigned facing damaging disclosures
>related to his billing practices at the Rose Law Firm. Ward was also a
>member of the Board of Directors of Madison Financial Corporation at
>the time that Hubbell, as a partner at the Rose Law Firm, represented
>the RTC in recovering depositor funds following the collapse of Madison
>S&L.74
>
> A NEW PIGGY BANK COMES INTO PLAY
>
>The airplane sale was not the only possible sweetheart deal involving
>Seth Ward or Webster Hubbell in 1985. Their Park-O-Meter company (POM)
>received a $2,750,000 loan through the newly-created Arkansas
>Development and Finance Authority (ADFA).75 ADFA was set up by Gov.
>Clinton as a bond agency to generate funds for small business loans to
>create new jobs within the state of Arkansas.76 As one of the largest
>parking meter companies in the nation, POM was clearly not a small
>business. ADFA gave many other such loans to business enterprises of
>the Clintons' friends and associates, including Rose Law Firm attorneys
>and their families.
>
>More than $2 million in ADFA loans also went to Pine Bluff Warehouse,
>whose chairman was the father of former Rose Law Firm partner William
>H. Kennedy III, who currently serves as Associate White House
>Counsel.77 Additionally, Rose Law Firm attorneys provided a large
>portion of the legal work on many ADFA public bond offerings.78
>
> JUDGE HALE TO THE RESCUE
>
>David Hale's Capital Management Services was similarly handing out
>taxpayer-funded loans to business ventures associated with Bill
>Clinton's inner circle of friends and political allies.
>
>Judge Hale says that he was first approached about helping the Clintons
>with a loan in the latter part of 1985.79 Hale says Clinton later
>requested that CMS loan money to Susan McDougal to help clean up
>Madison S&L's books prior to the scheduled visit from federal
>auditors.80
>
>On April 3, 1986, Judge Hale came through. CMS made a $300,000 SBA loan
>to Susan McDougal and her newest business venture, Master Marketing,81
>which, according to a "Confidential Data" report, was a real estate
>brokerage and land development firm.82 Mrs. McDougal received the SBA
>loan, which, as in the case of Jim Guy Tucker and County Cable, should
>have been reserved for economically or socially disadvantaged
>businesses. Three months before applying for the loan, the McDougals
>estimated their assets at over $3 million.83
>
>The funds were supposed to have been used for various real estate
>development projects, none of which were related to WDC or Madison S&L
>financial problems.84 In fact, a large portion of the loans proceeds
>were used as a down payment by WDC to purchase a parcel of land from
>the International Paper Company.85 WDC ultimately defaulted on this
>transaction and International Paper repossessed the property.86 The
>$300,000 taxpayer-guaranteed CMS loan was neverrepaid.87
>
>Meanwhile, the financial problems of Jim McDougal and Madison S&L
>continued to escalate. On March 4, 1986, the FHLBB issued a second
>highly critical report on the S&L's financial status. The report
>accused Mr. McDougal of "divert[ing] substantial amounts of funds [from
>projects underwritten wit Madison S&L loans] to himself and others, who
>are considered to be insiders (relatives of Mr. McDougal employees,
>relatives of employees and friends)."88 In August, federal regulators
>issued a cease and desist order directing the S&L to comply with
>federal savings and loan regulations.89 Under pressure from federal
>regulators, Jim McDougal was eventually removed from the S&L's Board of
>Directors.90
>
>In November 1986, Bill Clinton was elected to fourth term as governor.
>He would not have to see re-election again until1990, as the governor's
>term had been extended from two years to four years.91
>
> GIVE ME THOSE RECORDS NOW!
>
>While 1987 was a relatively quiet year, there was at least one
>significant Whitewater-related development. According to Jim McDougal,
>at some point during the year Hillary Clinton demanded and was given
>all WDC records. The McDougals say that the records were turned over to
>Hillary at the governor's mansion in Little Rock.92 But when the
>Whitewater story first broke during the 1992 presidential campaign, the
>Clintons claimed they did not have any files. Yet, as The Washington
>Post reported, a few weeks later "Clinton aides had assembled enough
>documentation to prepare a 'forensic accounting' of the venture and
>declare it a money-loser for the candidate and his wife."93
>
>Despite the fact that Jim McDougal had been removed from the Madison
>S&L Board of Directors, he and his wife were still the majority
>stockholders in the S&L. However, on June 1, 1988 they signed a proxy
>for the annual Madison S&L stockholders meeting, giving their votes to
>David Hale's CMS.94 There is yet to be a public explanation for this
>action.
>
>On September 14, Bill and Hillary Clinton regained ownership of
>Whitewater lot #13 from the bankruptcy trustee representing the estate
>of Hillman Logan.95 On October 31 they sold the lot to a couple that is
>in no way implicated in the Whitewater scandal.96 According to The New
>York Times, the Clintons paid the bankruptcy trustee approximately
>$8,000for the lot. But when they resold it six weeks later, they
>received about $23,000 after deducting closing costs.97 Even assuming
>Hillary Clinton lost $2,500 on her initial sale of the lot in 1981,
>publicly available documents indicate the Clinton household netted a
>capital gain of over $ 10,000 on all of their lot #13 transactions.
>
>The series of unusual dealings surrounding lot #13 is one of the many
>matters that needs to be further investigated. These transactions not
>only raise questions as to the truthfulness of the Clintons' claim that
>they lost money on their Whitewater investment, but they also appear to
>undermine the couple's assertion that they were merely passive
>investors in WDC.
>
>In late November, Hillary Clinton wrote to Jim and Susan McDougal
>requesting that they grant her power of attorney for all matters
>dealing with WDC.98 There is no record of the McDougals having complied
>with this request. All the same, like the lot #13 transactions, this
>request seems curious in light of the Clintons' assertion that they
>were passive investors in the company.
>
>On December 7, CMS filed suit against Susan McDougal and her Master
>Marketing company to recover its $300,000defaulted loan. On February 6,
>1989 the court entered judgment against Mrs. McDougal and her
>company.99 Judge Hale says none of the loan proceeds were ever
>recovered.100
>
> FEDS SHUT DOWN THE PIGGYBANK
>
>In March 1989 Madison S&L was taken over by federal regulators and
>eventually shut down.101 Later in the year, Jim McDougal was indicted
>on federal fraud charges, but he was ultimately acquitted at trial. As
>stated earlier, the S&L failure cost taxpayers an estimated $60
>million.
>
>Also in 1989, Rose Law Firm attorneys Vince Foster and Webster Hubbell
>sought and obtained an FDIC contract to help recover lost depositor
>funds that resulted from failed Arkansas S&Ls. Their efforts earned the
>firm over $400,000.102
>
>Among the cases handled by the Rose Law Firm was the government's $10
>million suit against Madison S&L accounting firm, Frost & Co. Rose
>settled the case for less than $1 million.103
>
>Rose Law Firm attorney Hillary Clinton had represented Madison S&L, and
>she had used the Frost & Co. report in her dealings with the State
>Securities Commission to keep Madison S&L open in 1985. With a big-
>money contract at stake, the Rose Law Firm apparently saw no potential
>conflict of interest arising out of their representation of the
>government, despite the fact that they had previously used Frost &
>Co.'s work in their representation of Madison S&L. Compounding this
>potential conflict was the fact that from 1977 to 1983, the Clintons
>
========================================================================
Paul Andrew Mitchell : Counselor at Law, federal witness
B.A., Political Science, UCLA; M.S., Public Administration, U.C. Irvine
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