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Enclosure (Page 21 of 38)


According to Department records, at least three DOT staff accompanied the Secretary to this event.


OCA Westchester 37th Anniversary and Dynamic Achiever Award Gala (November 11, 2017)

On November 11, 2017, the Westchester & Hudson Valley Chapter of the Organization of Chinese Americans (OCA-WHV) hosted its Dynamic Achiever Award Gala and 37th Anniversary Celebration in Tarrytown, New York. Dr. Chao was one of three Dynamic Achiever Awardees, and the OCA-WHV invited Secretary Chao to attend as a distinguished guest and speaker.

In a May 9, 2017, email to a Foremost Group employee, an OCA-WHV representative asked Dr. Chao to accept their Dynamic Achiever Award. Approximately 4 hours later, an OST staffer indicated Secretary Chao’s desire to attend the gala in an email that also asked the Foremost Group employee for the date of the gala “so that we can coordinate.” Per the Foremost Group employee’s request, Dr. Chao received a formal invitation on May 12, 2017. Later, in an October 23, 2017, email to OCA-WHV, a Foremost Group employee stated Dr. Chao’s preference that Secretary Chao introduce him during the gala.

From November 2 to November 6, 2017, an OCA-WHV official and an OST staffer spoke several times via telephone and exchanged emails during which they revised the Secretary and Dr. Chao’s respective activities during the gala. Among other things, they discussed a draft version of the gala’s program book and the order in which the Secretary and Dr. Chao would speak, pose for photographs, return to their seats, and have dinner. In a November 5, 2017, email to the OCAWHV official, an OST staffer suggested two edits to the program book: (1) Insert “Keynote by the Honorable Elaine L. Chao” and (2) Change to Dr. James S.C. Chao.

In a November 7, 2017, email, an OGC ethics attorney provided guidance concerning the gala to Inman and Carlson pursuant to Inman’s request. In the email, the OIG ethics attorney advised that, in keeping with previous advice, Secretary Chao could accept an invitation to the gala, she could attend as the Secretary of Transportation, and the dinner would not be considered a gift to her or DOT if she spoke at the gala. The OGC ethics attorney further advised, however, that if Secretary Chao “attends in her official capacity, she should not introduce her father, because of his connection to the Foremost Group and their transportation interests.” In the event Secretary Chao wished to introduce her father, according to the ethics attorney’s email, “she should attend in her personal capacity, not as Secretary Chao, but just as the Honorable Elaine L. Chao.”

In a November 8, 2017, email to a Foremost Group employee and OST staffer, an OCA-WHV official sought approval to use 90 bags provided by a local bank to gift one copy of Dr. Chao’s book, Fearless Against the Wind, upon request. Later that day, the Foremost Group employee emailed an approval and the OCA-WHV official promptly expressed thanks in a reply email to the Foremost Group employee and OST staffer.

On November 9, 2017, an OST staffer emailed a Foremost Group employee an itinerary for the gala. According to the itinerary and other emails, a national OCA official would deliver welcome remarks and then introduce Secretary Chao, who would deliver her keynote address and then return


– Redacted for public disclosure by the U.S. Department of Transportation, Office of General Counsel


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