LETTER FROM EDOUARD R. QUATREVAUX TO THE HONORABLE CHRIS CANNON, A REPRESENTATIVE IN CONGRESS FROM THE STATE OF UTAH, AND CHAIRMAN, SUBCOMMITTEE ON COMMERCIAL AND ADMINISTRATIVE LAW Edouard R. Quatrevaux 5000 Sharp Road Mandeville, LA 70471 The Honorable Chris Cannon Chairman Committee on the Judiciary Subcommittee on Commercial and Administrative Law United States House of Representatives B-353 Rayburn Office Building Washington, DC 20515-6221 Re: Letter of Support for H.R. 6101 Dear Chairman Cannon: September 21, 2006 As the former Inspector General (IG) at the Legal Services Corporation (LSC), from 1991 until 2000, I am writing you to support your bill H.R. 6101, the "Legal Services Corporation Improvement Act" to provide appropriate removal procedures for the Inspector General of the Legal Services Corporation, and for other purposes." For your information, I have enclosed a copy of my biographical sketch. During my nine-year tenure as the LSC IG, I faced numerous difficulties and constant challenges in trying to fulfill the independent IG role as Congress intended in the IG Act. I fought numerous challenges to IG independence with the LSC Board of Directors and headquarters' management. Independent authorities explicitly granted by the IG Act were questioned including audit authority, personnel, contractual and access to LSC and grantee documents. IG access to grant recipient records required to ensure grantee compliance was denied by a grantee, and LSC failed to sanction the organization, choosing to conduct its own impaired investigation instead. My understanding that the current IG is facing many of the same problems with a different Board and management group leads me to believe that LSC's propensity to challenge the authorities and independence of the IG is an institutional problem. I therefore wholeheartedly support your bill H.R. 6101. Sincerely, Haut Edouard R. Quatrevaux Enclosure MEMORANDUM TO BOARD OF DIRECTORS OF THE LEGAL SERVICES CORPORATION FROM COVINGTON & BURLING L.L.P. COVINGTON & BURLING LLP MEMORANDUM TO BOARD OF DIRECTORS OF THE LEGAL SERVICES CORPORATION Response to Coogan Memorandum Regarding Authority of Thomas S. Williamson, Jr. Covington & Burling LLP 1201 Pennsylvania Avenue, NW Washington, DC 20004 (202) 662-5438 twilliamson@cov.com July 28, 2006 The Inspector General Act Affirmatively Establishes the Board's Authority and Responsibility for Conducting Performance Evaluations of The Board Has Statutory Authority to Exercise "General The Statutory Prohibition on Interfering With the Inspector General's Investigations And Audits Does Not Negate the Board's The Inspector General's “Dual Reporting" Role Does Not Impose Existing Mechanisms for "Review” and “Oversight" of the Inspector General Are Not Sufficient as a Substitute for Annual Performance COVINGTON & BURLING LLP Page 1. The OIG Has Not Established That Impropriety Results from the .19 2. The Memorandum Does Not Articulate a Valid Basis for the OIG's ..20 D. The Coogan Memorandum Offers No Substantiated Grounds for the .20 E. The OIG's Assessment of Performance Appraisal Practices at Other ..24 III. The Coogan Memorandum's Conclusions Are Both Contradictory and Confusing......... 25 |