“ Although Morris was initially unaware of the financial condition of Clinton/Gore and the DNC at the time he was pressing for significant advertising expenditures, he learned that the Clinton/Gore Primary Committee was limited to spending approximately $30 million.32 Morris shared Ickes’ concern that the media campaign likely would exceed the $30 million limit placed on the Clinton-Gore Primary Committee.33 Confronted with these funding limitations, Morris searched for alternative methods to finance the President’s re-election campaign. ”

“ McAuliffe did go on to lead Clinton/Gore's fund-raising effort; however, Clinton/Gore was limited by law to raising funds in certain increments (no more than $1,000 from an individual) ,19 and there was an overall spending limit. By the end of the summer of 1995, the re-election campaign had raised “a good chunk” of all the funds it could legally raise.20 No doubt, a strong motivating factor in quickly raising this money was the need to discourage potential primary challengers. ”

“ From the thirst for advertising dollars developed the DNC’s search to tap new veins for money, such as emerging political groups. From the need for funds to pay for issue advertising arose the willingness to sell access to senior government officials and to use government property to raise funds. The White House and the Presidency were reduced to tools for fund-raising. In sum, Morris wrote the script. ”

“ A presidential candidate who accepts federal matching funds agrees in return to limit campaign expenditures in primaries and in the general election. 2 U.S.C. § 441a (b) (1) .
35 Morris deposition, pp. 262-63; see March 2 and 16, and April 27, 1995 agendas (Exs. 1, 2 and 3) . Morris produced portions of written agendas for the weekly strategy meetings beginning in February or March of 1995. See Morris deposition, p. 256. ”

“ Pressure on the DNC to Satisfy the Campaign’s Need for Money The President’s massive media plan, combined with the DNC’s operating costs, required Democrats to raise an unprecedented amount of money.70 Morris testified that the media team constantly needed additional money to fund fully the planned weekly media purchases. ”

“ Terence R. McAuliffe, the DNC’s National Finance Chairman from March 1994 to January 31, 1995, and later National Finance Chairman for Clinton-Gore ‘96, testified that “for the Democrats, it was not a very optimistic time.”2 McAuliffe was in a unique position to assess the mood of both the Democratic Party and its incumbent President. As DNC Finance Chairman, McAuliffe testified that he “had a better feeling for the mood of the donors ... ”

“ Unregulated “soft money” contributions may not be used to influence a federal campaign, except when used in the limited, party-building activities specifically designated in the statute. See §
431 (8) (B) .
Colorado Republican Fed. Campaign Comm. v. FEC, ___ U.S. ___, 116 S. Ct. 2309, 2316 (1996) .
40 Morris deposition, p. 134.
41 Id. at pp. 140-41. Morris did not recall who first informed him of issue advocacy advertising, but he believed it was Utrecht, Sandler or Bill Knapp, a consultant with the firm Squier Knapp & Ochs. Id. at p. 134. ”