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SANDLER REIFF 1090 Vermont Ave NW, Suite 750

Washington, DC 20005

www.sandlerreiff.com

T: 202-479-1111

SANDLER REIFF LAMB

ROSENSTEIN & BIRKENSTOCK, P.C.

May 18, 2022

Via E-Mail

Roy Q. Luckett, Esq.

Acting Associate General Counsel

Federal Election Commission

1050 First Street, NE

Washington, DC 20463

Re: RR 22L-14

Dear Mr. Luckett:

The undersigned serves as counsel to the Brady PAC and Jeanne Connelly, in her official 

capacity as Treasurer. We are writing in response to the Commission’s letter of May 9, 2022, in 

connection with the above-referenced referral. 

For the reasons set forth below, Brady PAC respectfully requests that the Office of 

General Counsel recommend that no further action be taken in this matter or, in the alternative, 

that this matter be referred to the Alternative Dispute Resolution Division for further 

proceedings.

This matter relates to a referral from the Commission’s Reports Analysis Division and 

specifically related to voluntary amendments filed by Brady PAC with respect to a debt owed to 

a vendor, Mothership Strategies, in the amount of $637,615.00.

Although Brady PAC acknowledges that it did not initially provide information regarding 

the debt to this vendor, this oversight was caused in large part by staff transition at the time of 

preparation of the report for which this debt related, as well as the disputed nature of a large 

portion of the debt disclosed to Mothership Strategies. A miscommunication between Brady 

PAC staff and the professional compliance firm retained by Brady PAC to prepare reports led to

the debt being inadvertently omitted – until that omission was discovered during an internal 

review of the dispute between Brady PAC and Mothership.

In response to this problem, Brady PAC has taken several steps to ensure that proper 

communications between its staff and compliance firm include all debts owed at the conclusion 

of each reporting period. Other than this omission, Brady PAC has had a stellar record with 

respect to disclosure and takes its disclosure responsibilities very seriously.

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Finally, it should be noted that Brady PAC and Mothership are currently in the process of 

arm’s length negotiations to amicably resolve this debt and it is the expectation of Brady PAC 

that the amount of this debt will be decreased significantly as a result of those negotiations. 

Therefore, Brady PAC believes that any potential violation amount should be reduced to reflect 

the final debt amount, once that amount is determined.

Based upon the above, most importantly, the impressive compliance record and 

significant resources devoted by Brady PAC to review and improve its internal processes, as well 

as the disputed nature of the debt in question, the Commission should either determine to take no 

further action in this matter, or, in the alternative, refer this matter to its Alternative Dispute 

Resolution Division to work with Brady PAC to come up with comprehensive steps to ensure 

future compliance.

If you have any further questions, please contact us at (202) 479-1111, or at 

reiff@sandlerreiff.com and mitrani@sandlerreiff.com respectively.

Respectfully submitted,

Neil P. Reiff

David Mitrani

Counsel Brady PAC and Jeanne Connelly, 

in her official capacity as Treasurer

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FEDERAL ELECTION COMMISSION 

1050 First Street, NE 

Washington, DC 20463 

STATEMENT OF DESIGNATION OF COUNSEL 

Provide one form for each Respondent/Witness 

E-MAIL: cela@fec.gov 

AR/MUR/RR/P-MUR# RR 22L-14 

Name of Counsel: Neil Reiff, Esq. and David Mitrani, Esq. 

Firm: Sandler Reiff Lamb Rosenstein & Birkenstock, P.C. 

Address: 1090 Vermont Avenue Ste 750 

Washington, DC 20005 

Office#: 202-4 79-1111 Fax#: ___________ _ _ 

Mobile#: __________ _ 

E-mail: reiff@sandlerreiff.com, mitrani@sandlerreiff.com 

The above-named individual and/or firm is hereby designated as my counsel and is authorized to receive any 

notifications and other communications from the Commission and to act on my behalf before the Commission. 

5/11/22 

Date 

Jeanne Connelly 

(Name - Please Print) 

RESPONDENT: Brady PAC I Jeanne Connelly 

Treasurer 

Title 

(Please print Committee Name/ Company Name/Individual Named in Notification Letter) 

Mailing Address: 600 Pennsylvania Ave SE # 15180 

(Please Print) 

Washington, DC 20003 

Home#: Mobile#: ------------- -------------

Office#: Fax#: ------------- ---------------

E-mail: info@bradypac.org, reporting@capcompliance.com 

This form relates to a Federal Election Commission matter that is subject to the confidentiality provisions of 52 U.S.C. § 30 I 09(a)(J 2)(A). 

This section prohibits making public any notification or investigation conducted by the Federal Election Commission without the express 

written consent of the person under investigation. Rev. 2021 

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