A state police investigation is taking place into any criminal wrongdoing in the 38 Studios deal, but another investigation is also under way by a state office that has no investigators on staff.
Secretary of State A. Ralph Mollis is focusing in on some of the key 38 Studios players and what they might have been saying in meetings and dinners outside of the State House.
Did these meetings influence legislation? Did they pressure lawmakers to make the $75 million state-backed loan guarantee sail through the State House?
Mollis wants to know.
"At this point there is no guarantee that there (are) any lobbying violations, although I think there are at least some," he said.
In letters obtained by the NBC 10 I-Team, the key players in the 38 Studios deal are all being asked by Mollis for explanations of why they failed to register as state lobbyists and file the proper paperwork.
The list includes former Boston Red Sox pitcher Curt Schilling, former 38 Studios board member Thomas Zaccagnino, Providence attorney Michael Corso and former Economic Development Director Keith Stokes. All of those accused of possible lobbying violations have denied any wrongdoing in letters submitted by their attorneys.
When asked if his investigation was late for a company that closed its doors two years ago, Mollis disagreed.
"At this point it was a case of us being aware that lobbying did take place. Transparency is key. The people of Rhode Island should know what's happening in the halls of their State House," Mollis said.
The NBC 10 I-Team first reported on an internal 38 Studios log that showed Corso, a friend of former House Speaker Gordon Fox, visited 38 Studios' Massachusetts office in 2009 with Fox and then-House Speaker William Murphy.
Later, six-figure contracts show Corso stood to make a lot of money on the 38 Studios deal. He was consulting for the company and meeting with public officials but never registered as a lobbyist.
The state has set up a hearing for Corso to explain his actions on Tuesday.
However, outside of holding hearings, what kind of authority does the Secretary of State's Office have? The office has no subpoena powers.
"We'll have an initial hearing to give the others an opportunity to let us know why they shouldn't file. Should we feel they should have filed we then can impose fines," Mollis said.
Administrative fines can reach up to $2,000 for each incident. If the parties willfully failed to file reports or register, a criminal penalty can also be handed down.
Attorney Louis DeSimone has been appointed to serve as the hearing officer. He also served in this capacity in the 1990s when the issue was challenged during the Langevin administration.