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In addition, investigative inquiries with respect to
petitioner’s direct-mail fundraising activities were begun by
various State attorneys general, including the attorneys general
for Alabama, Illinois, Maryland, Massachusetts, New York, and
Pennsylvania. Later, lawsuits were begun by some of the State
attorneys general, including the attorneys general for New York
and Pennsylvania.
G. Petitioner’s Escrow Account-Related Problems
1. Draws and Petitioner’s Dispute With W&H Over the
Calculation of Cumulative Net Mailing Campaign Revenue
Pursuant to its draw arrangement with W&H, petitioner
received monthly draws from the Escrow Account maintained by WIB.
See supra table 6 & preceding text. In late 1984 these draws
were $5,000 per month. W&H exercised final authority with
respect to approving and directing WIB to release the funds
petitioner sought. Even though the Escrow Account was in
petitioner’s name and WIB considered that the funds in the Escrow
Account belonged to petitioner, WIB paid money out of the Escrow
Account only in response to check requests submitted by W&H.
This was so whether the payments were (1) to vendors in
connection with petitioner’s fundraising activities (in which
events WIB also required the vendors’ invoices), (2) to W&H, or
(3) directly to petitioner.
Petitioner could not have obtained immediate possession of
the funds that WIB held in the Escrow Account by unilaterally
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