BEFORE THE FEDERAL ELECTION COMMISSION 

In the Matter of ) 

Unknown of Respondents 

) 

) 

MURs 7532 and 7537 

CERTIFICATION 

I, Vicktoria J. Allen, recording secretary of the Federal Election Commission executive 

session, do hereby certify that on September 30, 2021, the Commission took the following 

actions in the above-captioned matter: 

1. Failed by a vote of 2-3 to: 

a. Dismiss the allegations in MUR 7537 that Unknown Respondents 

violated 52 U.S.C. § 30120(a) with regard to the Hawley mailers. 

b. Dismiss the allegations in MUR 7537 that Unknown Respondents 

violated 52 U.S.C. § 30104(b), (c), and (g) with regard to the 

Hawley mailers. 

c. Merge the allegations regarding the Wagner communications in 

MUR 7537 into MUR 7532. 

d. Find reason to believe that Unknown Respondents violated 52 

U.S.C. § 30120(a), with regard to the Paulsen and Wagner mailers 

and internet video ads. 

e. Take no action at this time as to the allegations that Unknown 

 Respondents violated 52 U.S.C. § 30120(a) with regard to the 

 Paulsen and Wagner mailers and internet video ads. 

f. Find reason to believe that Unknown Respondents violated 52 

U.S.C. § 30104(b) or (c), and (g) with regard to the Paulsen and 

Wagner mailers and internet video ads. 

g. Authorize the use of compulsory process, as necessary. 

MUR753700061
Federal Election Commission Page 2 

Certification for MURs 7532 and 7537 

September 30, 2021 

h. Direct the Office of General Counsel to draft a revised Factual and 

Legal Analysis to be considered and circulated to the Commission 

for approval. 

i. Approve the appropriate letters. 

Commissioners Dickerson and Trainor voted affirmatively for the motion. 

Commissioners Broussard, Walther, and Weintraub dissented. Commissioner Cooksey was 

recused and did not vote. 

2. Failed by a vote of 3-2 to: 

a. Take no action at this time regarding the allegations that Unknown 

 Respondents violated 52 U.S.C. § 30120(a) with regard to the 

Hawley mailers. 

b. Take no action at this time regarding the possibility that Unknown 

 Respondents violated 52 U.S.C. § 30104(b) or (c), and (g) with 

regard to the Hawley mailers. 

Commissioners Broussard, Walther, and Weintraub voted affirmatively for the motion. 

Commissioners Dickerson and Trainor dissented. Commissioner Cooksey was recused and did 

not vote. 

3. Failed by a vote of 3-1 to: 

a. Merge MUR 7532 into MUR 7537. 

b. Find reason to believe that Unknown Respondents violated 52 

U.S.C. § 30120(a), with regard to the Paulsen and Wagner mailers 

and internet video ads on the basis that the communications 

contained express advocacy. 

c. Take no action at this time as to the allegations that Unknown 

 Respondents violated 52 U.S.C. § 30120(a) with regard to the 

 Paulsen and Wagner mailers and internet video ads on the basis 

that the sponsor may have been a political committee. 

d. Find reason to believe that Unknown Respondents violated 52 

U.S.C. § 30104(b) or (c), and (g) with regard to the Paulsen and 

MUR753700062
Federal Election Commission Page 3 

Certification for MURs 7532 and 7537 

September 30, 2021 

Wagner mailers and internet video ads on the basis that the 

communications contained express advocacy. 

e. Take no action at this time regarding the allegations that Unknown 

 Respondents violated 52 U.S.C. § 30120(a) with regard to the 

Hawley mailers on the basis that the sponsor may have been a 

political committee. 

f. Take no action at this time regarding the possibility that Unknown 

 Respondents violated 52 U.S.C. § 30104(b) or (c), and (g) with 

regard to the Hawley mailers on the basis that the sponsor may 

have been a political committee. 

g. Authorize the use of compulsory process, as necessary. 

h. Approve the relevant portions of the Factual and Legal Analysis, 

as recommended in the First General Counsel’s Report dated 

October 21, 2019. 

i. Approve the appropriate letters. 

Commissioners Broussard, Dickerson, and Walther voted affirmatively for the motion. 

Commissioner Trainor dissented. Commissioner Weintraub abstained. Commissioner Cooksey 

was recused and did not vote. 

4. Decided by a vote of 4-0 to: 

a. Merge MUR 7532 into MUR 7537. 

b. Find reason to believe that Unknown Respondents violated 52 

U.S.C. § 30120(a), with regard to the Paulsen and Wagner mailers 

and internet video ads on the basis that the communications 

contained express advocacy. 

c. Find reason to believe that Unknown Respondents violated 52 

U.S.C. § 30104(b) or (c), and (g) with regard to the Paulsen and 

Wagner mailers and internet video ads on the basis that the 

communications contained express advocacy. 

d. Authorize the use of compulsory process, as necessary. 

MUR753700063
Federal Election Commission Page 4 

Certification for MURs 7532 and 7537 

September 30, 2021 

e. Approve the relevant portions of the Factual and Legal Analysis, 

as recommended in the First General Counsel’s Report dated 

October 21, 2019. 

f. Approve the appropriate letters. 

Commissioners Broussard, Trainor, Walther, and Weintraub voted affirmatively for the 

decision. Commissioner Dickerson abstained. Commissioner Cooksey was recused and did not 

vote. 

5. Decided by a vote of 5-0 to: 

Reconsider motion #4. 

Commissioners Broussard, Dickerson, Trainor, Walther, and Weintraub voted 

affirmatively for the decision. Commissioner Cooksey was recused and did not vote. 

6. Failed by a vote of 3-1 to: 

a. Merge MUR 7532 into MUR 7537. 

b. Find reason to believe that Unknown Respondents violated 52 

U.S.C. § 30120(a), with regard to the Paulsen and Wagner mailers 

and internet video ads on the basis that the communications 

contained express advocacy. 

c. Find reason to believe that Unknown Respondents violated 52 

U.S.C. § 30104(b) or (c), and (g) with regard to the Paulsen and 

Wagner mailers and internet video ads on the basis that the 

communications contained express advocacy. 

d. Authorize the use of compulsory process, as necessary. 

e. Approve the relevant portions of the Factual and Legal Analysis, 

as recommended in the First General Counsel’s Report dated 

October 21, 2019. 

f. Approve the appropriate letters. 

MUR753700064
Federal Election Commission Page 5 

Certification for MURs 7532 and 7537 

September 30, 2021 

Commissioners Broussard, Walther, and Weintraub voted affirmatively for the motion. 

Commissioner Trainor dissented. Commissioner Dickerson abstained. Commissioner Cooksey 

was recused and did not vote. 

7. Decided by a vote of 5-0 to: 

Reconsider motion #3. 

Commissioners Broussard, Dickerson, Trainor, Walther, and Weintraub voted 

affirmatively for the decision. Commissioner Cooksey was recused and did not vote. 

8. Decided by a vote of 4-1 to: 

a. Merge MUR 7532 into MUR 7537. 

b. Find reason to believe that Unknown Respondents violated 52 

U.S.C. § 30120(a), with regard to the Paulsen and Wagner mailers 

and internet video ads on the basis that the communications 

contained express advocacy. 

c. Take no action at this time as to the allegations that Unknown 

 Respondents violated 52 U.S.C. § 30120(a) with regard to the 

 Paulsen and Wagner mailers and internet video ads on the basis 

that the sponsor may have been a political committee. 

d. Find reason to believe that Unknown Respondents violated 52 

U.S.C. § 30104(b) or (c), and (g) with regard to the Paulsen and 

Wagner mailers and internet video ads on the basis that the 

communications contained express advocacy. 

e. Take no action at this time regarding the allegations that Unknown 

 Respondents violated 52 U.S.C. § 30120(a) with regard to the 

Hawley mailers on the basis that the sponsor may have been a 

political committee. 

f. Take no action at this time regarding the possibility that Unknown 

 Respondents violated 52 U.S.C. § 30104(b) or (c), and (g) with 

regard to the Hawley mailers on the basis that the sponsor may 

have been a political committee. 

g. Authorize the use of compulsory process, as necessary. 

MUR753700065
Federal Election Commission Page 6 

Certification for MURs 7532 and 7537 

September 30, 2021 

h. Approve the Factual and Legal Analysis, as recommended in the 

First General Counsel’s Report dated October 21, 2019. 

i. Approve the appropriate letters. 

Commissioners Broussard, Dickerson, Walther, and Weintraub voted affirmatively for 

the decision. Commissioner Trainor dissented. Commissioner Cooksey was recused and did not 

vote. 

 Attest: 

 October 4, 2021 

 

Date Vicktoria J. Allen 

 Acting Deputy Secretary of the 

Commission 

Vicktoria Allen Digitally signed by Vicktoria Allen 

Date: 2021.10.04 19:17:38 -04'00'

MUR753700066