In a June 10 op-ed column, Robert D. Novak quoted Rep. Dan Burton to the effect that a statement in my recently published book established that President Clinton and the White House were involved in illegal fund-raising relating to White House coffees. In a letter to Attorney General Janet Reno, Rep. Burton cited as "credible" evidence my statement in the book that the White House coffees "were held to raise money during a political campaign."

Fact one: The White House coffees were held in the residence of the White House and, under established law and a Justice Department opinion published in 1979, never disputed by subsequent administrations of both parties. The White House residence is not a "federal building" under the Hatch Act and, thus, not subject to restrictions on fund-raising.

Fact two: No money was ever solicited at any White House coffee, nor was there ever a requirement of a donation in order to attend -- meaning that even if the coffees were held in a federal building, there would be no Hatch Act violation. It is possible that Rep. Burton is frustrated by coming up with nothing in his search for proof of Clinton White House illegal conduct on campaign finance issues. But that is no excuse for him to misstate the law and the facts.

LANNY J. DAVIS

Washington

The writer is a former special counsel to the president.