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Chief of Staff for the General Services Administration (GSA), David Safavian went on a golf trip to Scotland with lobbyist Jack Abramoff. He sought ethical advice from GSA’s General Counsel, but represented that Abramoff had “no business before GSA.” Safavian did not disclose that Abramoff had previously asked him about leasing two GSA-owned properties. D.C. Circuit Court of Appeals upheld four counts related to falsifying or concealing a material fact and obstruction of justice.
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