Document 6RoZB7kz8Xvwj1v5jnDbj8o86

To: dbramer@bramergroup.com[dbramer@bramergroup.com] Cc: Melinda Loftin[melinda.loftin@sol.doi.gov]; Kimberly Benton[kimberly.benton@sol.doi.gov]; Heindl, Jennifer[jennifer.heindl@sol.doi.gov]; Leila Getto[leila_getto@ios.doi.gov]; Timothy Nigborowicz[timothy_nigborowicz@ios.doi.gov] From: McDonnell, Edward Sent: 2017-11-30T09:13:55-05:00 Importance: Normal Subject: Fwd: Mistletoe Event Received: 2017-11-30T09:14:47-05:00 Hi Mr. Bramer, I'm the Alternate Designated Agency Ethics Official for the Department of the Interior and I wondered if I may please ask you a few questions that would further help with our analysis. Or, if there is someone else to whom I should ask these questions, I would appreciate it if you could provide contact information for that person. First, do you hold a position in the American Freedom Fund? Second, is the Three Star Award for Outstanding Service to the Veteran Community actually awarded by the American Freedom Fund itself? Third, I understand that there was a 2016 award and now a 2017 award. Does American Freedom Fund plan for this to be an annual award and, if so, is there a commitment to fund the award in future years? Fourth, is selection of award recipients made pursuant to written standards? If so, would it be possible to get a copy of those written standards? If you have any questions or would care to discuss, please feel free to contact me by email or at (202) 510-8427. Thank you very much, Ed - Stewardship for America with Integrity and Excellence - --- Please note that a current or former employee who discloses information to an agency ethics official or a Government attorney does not personally enjoy an attorney-client privilege with respect to such communications. Additionally, reliance on the oral or written advice of an agency ethics official cannot ensure that an employee will not be prosecuted for a violation of Title 18 of the United States Code. However, good faith reliance on such advice is a factor that may be taken into account by the Department of Justice in the selection of cases for prosecution. --- Ed McDonnell Alternate Designated Agency Ethics Official/Deputy Designated Agency Ethics Official U.S. Department of the Interior Departmental Ethics Office Office of the Solicitor E-mail: edward.mcdonnell@sol.doi.gov Fax: (202) 208-5515 (Please call or e-mail me to let me know you've sent me a fax as the fax machine is in a separate room.) Located at: Main Interior Building Room 5313 Office: (202) 208-5916 Cell: (202) 510-8427 Mailing Address: Departmental Ethics Office Office of the Solicitor Department of the Interior Mail Stop 5311 1849 C Street NW Washington, DC 20240 E-mail the Departmental Ethics Office at DOI Ethics@sol.doi.gov or visit us online at www.doi.gov/ethics This e-mail (including any attachments) is intended for the use of the individual or entity to which it is addressed. It may contain information that is privileged, confidential, or otherwise protected by applicable law. If you are not the intended recipient or the employee or agent responsible for delivery of this e-mail to the intended recipient, you are hereby notified that any dissemination, distribution, copying, or use of this e-mail or its contents is strictly prohibited. If you received this e-mail in error, please notify the sender immediately and destroy all copies. --------- Forwarded message --------From: Boulton, Caroline <caroline boulton@,ios.doi.gov> Date: Tue, Nov 28, 2017 at 6:12 PM Subject: Fwd: Mistletoe Event To: Melinda Loftin <melinda.loftin@sol.doi.gov>, "McDonnell, Edward" <edward.mcdonnell@sol.doi.gov>, Kimberly Benton <kimberly.benton@sol.doi.gov>, "Heindl, Jennifer" <jennifer.heindl@sol.doi.gov>, Leila Getto <leila getto@ios.doi.gov>, Timothy Nigborowicz <timothy nigborowicz@,ios.doi.gov> Hi all-- Another update on the selection process for the Mistletoe event on 12/6. Please let me know if there are further questions. Best, Caroline --------- Forwarded message --------From: Don Bramer <dbramer@bramergroup.com> Date: Tue, Nov 28, 2017 at 6:01 PM Subject: Re: Mistletoe Event To: "Boulton, Caroline" <caroline bo.ulton@ios.doi.gov> Caroline - Thanks for your email. We are excited to have Ryan Zinke as the recipient of this year's Three Star Award for Outstanding Service to the Veteran Community. Ryan will join the company of Woodrow "Woody" Williams, the oldest living MOH Survivor of WWII and Iowa Jima. The event, Manhattans, Martinis & Mistletoe is hosted by the American Freedom Fund. A 501c(19) created to support Veterans and Veteran organizations. We were thrilled to have Mr. Zinke join us in 2015 as a one of our guest speakers to this event. In fact, he was among the finalist for the 2016 Award by the Committee. However, Mr. Williams beat him by just a few votes. As the 2016 Cmte wrapped up its business for the year, three names were submitted for the 2017 event to be recognized for there amazing work to the Veteran community. Those were Michael Thornton, Condolesa Rice and Ryan Zinke. At the time of our consideration, Mr. Zinke was still the Congressman for Montana. This meeting was held at the Annual After Action Meeting during the week of December 7th 2016. Again, thank you for your continued assistance and cooperation. You've been amazing to work with and we look forward to having the Secretary join us next week. Regards, DB Donald R. Bramer Chairman Bramer Group LLC +1.502.386.0036 (M) On Nov 28, 2017, at 15:38, Boulton, Caroline <caroline boulton@ios.doi.gov> wrote: Hi Don, I spoke with our Ethics office today again about the event next week, and they have asked for documentation (via email) of when the selection of Secretary Zinke for the award took place (roughly; whether it was before or after the announcement of his nomination) and what the criteria for the selection process was. I know that we have spoken about it over the phone, but they would like it in writing so that they can refer back to it. If you are able to send that to me, that would be greatly appreciated. Best, Caroline Caroline Boulton Special Assistant to the Secretary U.S. Department of the Interior Office of Scheduling & Advance Caroline Boulton@ios.doi.gov l Scheduling@ios.doi.gov Caroline Boulton Special Assistant to the Secretary U.S. Department of the Interior Office of Scheduling & Advance Caroline Boulton@ios.doi.gov l Scheduling@,ios.doi.gov To: Melinda Loftin[melinda.loftin@sol.doi.gov]; Kimberly Benton[kimberly.benton@sol.doi.gov]; Heindl, Jennifer[jennifer.heindl@sol.doi.gov]; Leila Getto[leila_getto@ios.doi.gov]; Timothy Nigborowicz[timothy_nigborowicz@ios.doi.gov] Cc: dbramer@bramergroup.com[dbramer@bramergroup.com] From: McDonnell, Edward Sent: 2017-11-30T12:05:22-05:00 Importance: Normal Subject: Fwd: Mistletoe Event Received: 2017-11-30T12:06:14-05:00 All, I have spoken with Mr. Bramer and I understand that: 1. The award is to Ryan Zinke from American Freedom Fund; 2. The selection was made prior to the White House's announcement of the intent to nominate then-Congressman Zinke and was in no way based on his position as Secretary of the Interior; 3. American Freedom Fund is not a prohibited source; and 4. American Freedom Fund is not a registered lobbying organization. Based on the above, I have determined that the award does not constitute a prohibited gift and that a reasonable person with knowledge of the relevant facts would not question the Secretary's integrity or impartiality as a result of accepting the award. Accordingly, the Secretary may accept the award. If you have any questions or would care to discuss, please let me know. Thanks, Ed - Stewardship for America with Integrity and Excellence - --- Please note that a current or former employee who discloses information to an agency ethics official or a Government attorney does not personally enjoy an attorney-client privilege with respect to such communications. Additionally, reliance on the oral or written advice of an agency ethics official cannot ensure that an employee will not be prosecuted for a violation of Title 18 of the United States Code. However, good faith reliance on such advice is a factor that may be taken into account by the Department of Justice in the selection of cases for prosecution. --- Ed McDonnell Alternate Designated Agency Ethics Official/Deputy Designated Agency Ethics Official U.S. Department of the Interior Departmental Ethics Office Office of the Solicitor E-mail: edward.mcdonnell@sol.doi.gov Fax: (202) 208-5515 (Please call or e-mail me to let me know you've sent me a fax as the fax machine is in a separate room.) Located at: Main Interior Building Room 5313 Office: (202) 208-5916 Cell: (202) 510-8427 Mailing Address: Departmental Ethics Office Office of the Solicitor Department of the Interior Mail Stop 5311 1849 C Street NW Washington, DC 20240 E-mail the Departmental Ethics Office at DOI Ethics@sol.doi.gov or visit us online at www.doi.gov/ethics This e-mail (including any attachments) is intended for the use of the individual or entity to which it is addressed. It may contain information that is privileged, confidential, or otherwise protected by applicable law. If you are not the intended recipient or the employee or agent responsible for delivery of this e-mail to the intended recipient, you are hereby notified that any dissemination, distribution, copying, or use of this e-mail or its contents is strictly prohibited. If you received this e-mail in error, please notify the sender immediately and destroy all copies. --------- Forwarded message --------From: McDonnell, Edward <edward.mcdonnell@sol.doi.gov> Date: Thu, Nov 30, 2017 at 9:13 AM Subject: Fwd: Mistletoe Event To: dbramer@bramergroup.com Cc: Melinda Loftin <melinda.loftin@sol.doi.gov>, Kimberly Benton <kimberly.benton@sol.doi.gov>, "Heindl, Jennifer" <jennifer.heindl@sol.doi.gov>, Leila Getto <leila getto@ios.doi.gov>, Timothy Nigborowicz <timothy nigborowicz@ios.doi.gov> Hi Mr. Bramer, I'm the Alternate Designated Agency Ethics Official for the Department of the Interior and I wondered if I may please ask you a few questions that would further help with our analysis. Or, if there is someone else to whom I should ask these questions, I would appreciate it if you could provide contact information for that person. First, do you hold a position in the American Freedom Fund? Second, is the Three Star Award for Outstanding Service to the Veteran Community actually awarded by the American Freedom Fund itself? Third, I understand that there was a 2016 award and now a 2017 award. Does American Freedom Fund plan for this to be an annual award and, if so, is there a commitment to fund the award in future years? Fourth, is selection of award recipients made pursuant to written standards? If so, would it be possible to get a copy of those written standards? If you have any questions or would care to discuss, please feel free to contact me by email or at (202) 510-8427. Thank you very much, Ed - Stewardship for America with Integrity and Excellence - --- Please note that a current or former employee who discloses information to an agency ethics official or a Government attorney does not personally enjoy an attorney-client privilege with respect to such communications. Additionally, reliance on the oral or written advice of an agency ethics official cannot ensure that an employee will not be prosecuted for a violation of Title 18 of the United States Code. However, good faith reliance on such advice is a factor that may be taken into account by the Department of Justice in the selection of cases for prosecution. --- Ed McDonnell Alternate Designated Agency Ethics Official/Deputy Designated Agency Ethics Official U.S. Department of the Interior Departmental Ethics Office Office of the Solicitor E-mail: edward.mcdonnell@sol.doi.gov Fax: (202) 208-5515 (Please call or e-mail me to let me know you've sent me a fax as the fax machine is in a separate room.) Located at: Main Interior Building Room 5313 Office: (202) 208-5916 Cell: (202) 510-8427 Mailing Address: Departmental Ethics Office Office of the Solicitor Department of the Interior Mail Stop 5311 1849 C Street NW Washington, DC 20240 E-mail the Departmental Ethics Office at DOI Ethics@sol.doi.gov or visit us online at www.doi.gov/ethics This e-mail (including any attachments) is intended for the use of the individual or entity to which it is addressed. It may contain information that is privileged, confidential, or otherwise protected by applicable law. If you are not the intended recipient or the employee or agent responsible for delivery of this e-mail to the intended recipient, you are hereby notified that any dissemination, distribution, copying, or use of this e-mail or its contents is strictly prohibited. If you received this e-mail in error, please notify the sender immediately and destroy all copies. --------- Forwarded message --------From: Boulton, Caroline <caroline boulton@ios.doi.gov> Date: Tue, Nov 28, 2017 at 6:12 PM Subject: Fwd: Mistletoe Event To: Melinda Loftin <melinda.loftin@soLdoi.gov>, "McDonnell, Edward" <edward.mcdonnell@sol.doi.gov>, Kimberly Benton <kimberly.benton@sol.doi.gov>, "Heindl, Jennifer" <jennifer.heindl@sol.doigoy>, Leila Getto <leila getto@ios.doi.gov>, Timothy Nigborowicz <timothy nigborowicz@ios.doi.gov> Hi all-Another update on the selection process for the Mistletoe event on 12/6. Please let me know if there are further questions. Best, Caroline --------- Forwarded message --------From: Don Bramer <dbramer@bramergroup.com> Date: Tue, Nov 28, 2017 at 6:01 PM Subject: Re: Mistletoe Event To: "Boulton, Caroline" <caroline boulton@ios.doi.gov> Caroline - Thanks for your email. We are excited to have Ryan Zinke as the recipient of this year's Three Star Award for Outstanding Service to the Veteran Community. Ryan will join the company of Woodrow "Woody" Williams, the oldest living MOH Survivor of WWII and Iowa Jima. The event, Manhattans, Martinis & Mistletoe is hosted by the American Freedom Fund. A 501c(19) created to support Veterans and Veteran organizations. We were thrilled to have Mr. Zinke join us in 2015 as a one of our guest speakers to this event. In fact, he was among the finalist for the 2016 Award by the Committee. However, Mr. Williams beat him by just a few votes. As the 2016 Cmte wrapped up its business for the year, three names were submitted for the 2017 event to be recognized for there amazing work to the Veteran community. Those were Michael Thornton, Condolesa Rice and Ryan Zinke. At the time of our consideration, Mr. Zinke was still the Congressman for Montana. This meeting was held at the Annual After Action Meeting during the week of December 7th 2016. Again, thank you for your continued assistance and cooperation. You've been amazing to work with and we look forward to having the Secretary join us next week. Regards, DB Donald R. Bramer Chairman Bramer Group LLC +1.502.386.0036 (M) On Nov 28, 2017, at 15:38, Boulton, Caroline <carolme boulton@ios.doi.gov> wrote: Hi Don, I spoke with our Ethics office today again about the event next week, and they have asked for documentation (via email) of when the selection of Secretary Zinke for the award took place (roughly; whether it was before or after the announcement of his nomination) and what the criteria for the selection process was. I know that we have spoken about it over the phone, but they would like it in writing so that they can refer back to it. If you are able to send that to me, that would be greatly appreciated. Best, Caroline Caroline Boulton Special Assistant to the Secretary U.S. Department of the Interior Office of Scheduling & Advance Caroline Boulton@ios.doi.gov l Scheduling@ios.doi.gov Caroline Boulton Special Assistant to the Secretary U.S. Department of the Interior Office of Scheduling & Advance Caroline Boulton@ios.doi.gov l Scheduling@ios.doi.gov