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B-202116,B-210338 1 (1983-09-19)

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                 COP IT RO 1 R  (, fILRA  OI  1-1HE U.NI LD  SIAfE.
                           WASHINGTON D.C. 20548

B-210338/B-202116       IINfIN           September 19, 198



The Honorable Jeremiah Denton
Chairman, Subcommittee on Family and Human Services
Committee on Labor and Human Resources
United States Senate

Dear Mr. Chairman:

     This is in response to your recent letters requesting
this Office to render a legal opinion concerning whether any
of the documents and other materials that you recently
obtained from the Legal Services Corporation (LSC) files and
turned over to this Office, contain'evidence of violations
of certain restrictions in the Legal Services Corporation
Act of 1974 (42 U.S.C. § 2996).

                         BACKGROUND

     At the end of 1980, Representative Sensenbrenner pro-
vided this Office with certain internal memoranda he had
obtained from the LSC and requested an opinion on whether
these documents indicated that the Corporation had violated
Federal anti-lobbying laws. We rendered our opinion in
60 Comp. Gen. 423 on May 1, 1981, holding that the material
in the memoranda indicated that LSC had itself engaged and
allowed its grant recipients to engage in lobbying activi-
ties prohibited by Federal law. You have now provided us
with several hundred additional internal memoranda and other
materials from the LSC headquarters and regional office
files covering primarily the 1981 calendar year period and
have requested a determination concerning whether these
materials contain evidence indicating that LSC or its fund
recipients violated statutory restrictions on its training
and coalition building activities as well as restrictions on
advocating or opposing ballot measures, initiatives and
referendums.

     It would require several months for us to review the
enormous volume of material you have supplied and we plan to
accomplish this task in connection with our investigation of
the LSC survival plan that you requested. However, in order
to comply with the short time frame of your request to pro-
vide you with a response regarding the issues referred to
above by mid-September 1983, we have selected certain mate-
rial, that in our opinion, indicate violations of restric-
tions you mentioned.

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