1 

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

CAMPAIGN LEGAL CENTER

1101 14th Street NW, Suite 400 

Washington, DC 20005, 

 Plaintiff,

v. 

FEDERAL ELECTION COMMISSION

1050 First Street NE 

Washington, DC 20463, 

 Defendant.

Civil Action No. ________________ 

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF

INTRODUCTION

More than 600 days ago, on July 28, 2020, Plaintiff Campaign Legal Center (“CLC”) filed 

an administrative complaint with the Federal Election Commission (“FEC” or “Commission”) 

alleging that Donald J. Trump’s authorized campaign committee, Donald J. Trump for President, 

Inc. (“Trump campaign”), and one of his authorized joint fundraising committees, Trump Make 

America Great Again Committee (collectively, “committees” or “Trump committees”), violated 

the disclosure requirements of the Federal Election Campaign Act (“FECA” or “the Act”) by 

laundering hundreds of millions of dollars of campaign spending in the 2020 election through firms 

created and/or managed by senior Trump campaign officials—namely, American Made Media 

Consultants (“AMMC”) and Parscale Strategy—rather than disclosing itemized payments to each 

vendor or individual actually working for the committees, as FECA requires. A January 28, 2021 

supplement to the administrative complaint provided further evidence that the Trump committees 

did not have an arm’s-length relationship with AMMC, which was reportedly created with the 

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approval of one of the campaign’s most senior officials and initially included members of the 

President’s and Vice President’s families on its board. The effect and apparent goal of routing the 

campaign’s spending through conduits was to disguise the Trump committees’ ultimate payees, 

and the amounts, dates, and purposes of such payments, in violation of the reporting requirements 

at 52 U.S.C. § 30104(b)(5)-(6).

To Plaintiff’s knowledge, the FEC has taken no action on the July 2020 administrative 

complaint or January 2021 supplement. Accordingly, even as likely 2024 hopefuls—including 

former President Trump—are already beginning to lay the groundwork for presidential election 

campaigns, CLC and voters remain in the dark about how the Trump campaign spent its money in 

2020. Plaintiff therefore requests that this Court declare that the FEC’s failure to act is contrary to 

law, and order the FEC to conform within thirty days by acting on Plaintiff’s administrative 

complaint. See 52 U.S.C. § 30109(a)(8)(A). If the FEC does not conform to such an order within

thirty days, FECA authorizes Plaintiff to commence a civil action to remedy the violations

involved in the original complaint. See id. § 30109(a)(8)(C).

* * *

1. This is an action against the FEC under 52 U.S.C. § 30109(a)(8)(A) based on 

unlawful agency delay. Plaintiff CLC seeks declaratory and injunctive relief to compel Defendant

FEC to take action on Plaintiff’s administrative complaint, and the supplement to that complaint, 

alleging violations of 52 U.S.C. § 30104(b), a FECA provision that requires all federal political 

committees to file itemized reports of their disbursements that disclose both the “name and 

address” of each payee and the “date, amount, and purpose” of each disbursement. Id.

§ 30104(b)(5)-(6); see also 11 C.F.R. § 104.3(b)(3)(i), (b)(4)(i).

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2. CLC filed an administrative complaint with the FEC on July 28, 2020—and a 

supplement to that complaint on January 28, 20211—alleging that former President and 2020 

presidential candidate Donald Trump’s campaign committee, Donald J. Trump for President, Inc., 

and one of its authorized joint fundraising committees, Trump Make America Great Again 

Committee, had violated 52 U.S.C. § 30104(b) by failing to properly itemize and report payments 

to sub-vendors and staff made through two firms affiliated with the Trump campaign. Ex. 1, 

Admin. Compl. ¶¶ 1-2, 81, 91; Ex. 2, Suppl. to Admin. Compl. 6. In particular, the complaint and 

its supplement alleged that the Trump committees had laundered hundreds of millions of dollars 

in spending through American Made Media Consultants (“AMMC”)—a corporation apparently 

created by Trump campaign officials—and Parscale Strategy—the consulting firm of former 

Trump campaign manager Brad Parscale—thereby disguising the details of the transactions and 

the identities of the ultimate payees. Ex. 1, Admin. Compl. ¶ 2.

3. The administrative complaint asked the Commission (1) to find reason to believe 

that the committees had violated § 30104(b) by failing to properly itemize and report their 

disbursements, (2) to conduct an investigation to determine whether a violation had occurred or 

was about to occur, and (3) to seek appropriate sanctions. Ex. 1, Admin. Compl. ¶¶ 92-93.

4. FECA provides administrative complainants with a right of action against the FEC 

if the Commission fails to act on a complaint within 120 days. 52 U.S.C. § 30109(a)(8)(A).

5. Over twenty months after CLC filed its initial complaint, and more than fourteen 

months after it supplemented that complaint, there is no indication that the FEC has taken any 

action on the matter.

1 The July 28, 2020 administrative complaint and the January 28, 2021 supplement are attached 

hereto as Exhibits 1 and 2, respectively.

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6. This failure to enforce FECA’s disclosure requirements undermines voters’ ability 

“to make informed decisions.” Citizens United v. FEC, 558 U.S. 310, 371 (2010). Moreover, the 

Commission’s prolonged inaction in this matter encourages future campaigns—including any

2024 Trump presidential campaign2—to seek to evade the Act’s reporting requirements by 

similarly laundering payments through a small number of reported vendors. 

7. The Commission’s failure to act on Plaintiff’s complaint injures CLC by depriving 

it of statutorily mandated disclosure information upon which CLC relies to complete its work and 

advance its mission. Without full and accurate reporting by the administrative respondents, 

Plaintiff cannot know what vendors ultimately supplied the services for which the Trump 

committees paid through AMMC or Parscale Strategy. Plaintiff also cannot discern the amounts, 

dates, and purposes of payments ultimately made to those vendors. FECA legally entitles CLC to 

this information. 

8. Plaintiff therefore requests that this Court declare the FEC’s failure to act on the 

administrative complaint and its supplement contrary to law, and order the Commission to conform 

with such declaration within thirty days. 

2

 Former President Trump has repeatedly signaled that he plans to once again be a candidate for 

President in the 2024 election. See, e.g., Mary Papenfuss, Trump Says Only Hurdle to 2024 Run 

Would Be a ‘Bad Call from a Doctor,’ Yahoo! News (Sept. 25, 2021), https://news.yahoo.com/

trump-says-only-hurdle-2024-231133553.html; Cheryl Teh, Trump Drops the Biggest Hint Yet 

that He’ll Be Running in 2024, Calling Himself the ‘45th and 47th President’ in a Video, Insider 

(Jan. 26, 2022), https://www.businessinsider.com/trump-drops-hint-about-2024-run-callinghimself-47th-president-2022-1. Indeed, Trump may have already triggered candidate status under 

FECA based on his public statements and conduct. See, e.g., American Bridge PAC, FEC 

Complaint Against Donald J. Trump (Mar. 14, 2022), https://americanbridgepac.org/wp-content/

uploads/2022/03/Trump-FEC-complaint-edits-v2.pdf; Meg Kinnard, Trump Accused of Breaking 

Campaign Laws by Teasing 2024 Run, ABC News (Mar. 14, 2022), https://abcn.ws/3t8X74G. 

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JURISDICTION AND VENUE

9. This Court has both subject matter jurisdiction over this action and personal 

jurisdiction over the parties pursuant to 52 U.S.C § 30109(a)(8)(A) and 28 U.S.C. § 1331.

10. Venue lies in this district under 52 U.S.C. § 30109(a)(8)(A).

THE PARTIES

11. Plaintiff CLC is a nonpartisan, nonprofit organization that works to strengthen 

American democracy through, among other activities, local, state, and federal efforts to ensure that 

the public has access to information regarding the financing and spending of U.S. election 

campaigns.

12. As part of this work, CLC conducts research, authors reports and articles, and 

regularly provides expert analysis to the media. CLC also litigates throughout the country 

regarding campaign finance matters; files FEC complaints requesting that enforcement actions be 

taken against individuals or organizations that violate the law; participates in rulemaking and 

advisory opinion proceedings before the FEC to ensure that the agency is properly interpreting and 

enforcing federal election laws; and engages in legislative advocacy for reform measures at the 

federal, state, and local levels.

13. CLC relies on the accurate and complete reporting of campaign finance information 

to carry out activities central to its mission, including the production of reports and other materials 

to educate the public about campaign spending. These activities are obstructed when information 

that is subject to mandatory disclosure under FECA is not publicly available.

14. CLC expends significant resources assisting reporters and other members of the 

media in their investigative research into candidates’ financial activities, to ensure that the public 

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is equipped with the information necessary to evaluate different candidates and messages and to 

cast informed votes.

15. CLC also uses its analysis of federal campaign finance disclosure information to 

support its administrative practice at the FEC and before state and local campaign finance agencies, 

and to defend campaign finance laws in its active docket of cases in federal and state courts.

16. When inadequate disclosure of federal campaign finance activity makes it difficult 

to ascertain the nature of a committee’s spending, reporters often contact CLC for guidance as to 

whether or where they can find the campaign finance information that is not being properly 

reported. This work requires CLC to divert resources and funds from other organizational needs.

17. Defendant FEC is an independent federal agency charged with the administration 

and civil enforcement of FECA. 52 U.S.C. § 30106(b).

STATUTORY AND REGULATORY BACKGROUND

FECA’s Disclosure and Reporting Requirements

18. FECA requires that “[e]ach treasurer of a political committee . . . file reports of 

receipts and disbursements” with the Commission. 52 U.S.C. § 30104(a)(1). These reports must 

disclose “the name and address” of each person to whom the committee has made operating 

expenditures or other disbursements of over $200, “together with the date[s], amount[s], and 

purpose[s]” of those expenditures or disbursements. Id. § 30104(b)(5)-(6).

19. FEC regulations similarly require that political committees disclose the dates, 

amounts, and purposes of expenditures and disbursements in excess of $200. 11 C.F.R. 

§ 104.3(b)(3)(i), (b)(4)(i). Those regulations define “purpose” to mean “a brief statement or 

description of why the disbursement was made.” Id. § 104.3(b)(3)(i)(A), (b)(4)(i)(A).

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20. Commission precedent makes clear that a federal political committee must itemize 

payments to a sub-vendor if (1) the immediate vendor receiving the disbursement does not have 

an arm’s-length relationship with the committee, (2) the payments to the sub-vendor are unrelated 

to the services provided pursuant to the immediate vendor’s contract with the committee, or (3) 

the immediate vendor is merely acting as a “conduit” for disbursements to sub-vendors. See, e.g., 

General Counsel’s Brief 33-37, MUR 3847 (Stockman) (Sept. 15, 1997); Conciliation Agreement 

2-4, MUR 4872 (Jenkins) (Feb. 15, 2002); First General Counsel’s Report 12-14, MUR 6724 

(Bachmann for President) (Aug. 26, 2014). Under these circumstances, failing to itemize 

disbursements to the ultimate payee violates 52 U.S.C. § 30104(b).

21. The Supreme Court has recognized the importance of FECA’s disclosure and 

reporting requirements, which “provide[] the electorate with information ‘as to where political 

campaign money comes from and how it is spent,’” Buckley v. Valeo, 424 U.S. 1, 66 (1976) (per 

curiam) (quoting H.R. Rep. No. 92-564, at 4 (1971)), and thereby “enable[] the electorate to make 

informed decisions,” Citizens United, 558 U.S. at 371.

Governing Administrative and Judicial Process

22. FECA provides administrative complainants with a right of action against the FEC 

if the Commission fails to act on a complaint within 120 days. 52 U.S.C. § 30109(a)(8)(A).

23. If the Court declares that the FEC’s failure to act on an administrative complaint is 

contrary to law, it may order the FEC to conform within thirty days by acting on the administrative 

complaint, failing which the plaintiff may commence a civil action against the administrative 

respondents to remedy the underlying FECA violation. See id. § 30109(a)(8)(A), (C).

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FACTUAL BACKGROUND

24. On July 28, 2020, CLC filed an administrative complaint with the FEC urging the 

Commission to find reason to believe that the Trump committees had violated 52 U.S.C. 

§ 30104(b) by failing to properly itemize and report payments to sub-vendors and staff made

through AMMC and Parscale Strategy. See Ex. 1, Admin. Compl. ¶¶ 1-2, 81, 91. On January 28, 

2021, CLC filed a supplement to the complaint providing additional support for the allegations. 

See Ex. 2, Suppl. to Admin. Compl. 1-2.

25. Drawing on publicly available information—including media reports, statements 

by Trump campaign officials and contractors, and filings with state and federal agencies other than 

the FEC—the complaint and its supplement alleged that the Trump committees violated FECA by 

failing to itemize payments to sub-vendors paid through AMMC and Parscale Strategy even 

though those firms both (1) did not have arm’s-length relationships with the committees and 

(2) were used by the committees as conduits for disbursements to sub-vendors.

AMMC

26. The administrative complaint and its supplement alleged both that the Trump 

committees did not have an arm’s-length relationship with AMMC and that AMMC acted merely 

as a conduit for disbursements to sub-vendors.3

27. First, the complaint and supplement alleged that the committees and AMMC did 

not have an arm’s-length relationship.4

28. CLC’s administrative filings described the substantial evidence that officials from 

the Trump campaign approved of and oversaw AMMC’s creation and participated in its corporate 

3 See Ex. 1, Admin. Compl. ¶¶ 73-81.

4 See Ex. 1, Admin. Compl. ¶¶ 13-25, 73-74; Ex. 2, Suppl. to Admin. Compl. 2-3.

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governance. For example, the supplement cited reporting that Jared Kushner, a senior campaign 

official, “approved the creation of” AMMC.

5

 The complaint also cited corporate filings with state 

authorities and the Federal Communications Commission showing that campaign officials served 

as officers of AMMC and its parent corporation and that AMMC’s parent company shared an 

address with the Trump campaign’s compliance firm.6

29. The complaint also cited numerous media reports describing AMMC as “created,”7

“established,”8

 or “set up” by the Trump campaign or its officials.9

30. In addition, the complaint and supplement demonstrated that AMMC was devoted 

largely to the Trump committees’ success: for example, all but one FEC-reported payment to 

AMMC came from the committees.

10

5

 Ex. 2, Suppl. to Admin. Compl. 2 (quoting Tom LoBianco & Dave Levinthal, Jared Kushner 

Helped Create a Trump Campaign Shell Company that Secretly Paid the President’s Family 

Members and Spent $617 Million in Reelection Cash, a Source Tells Insider, Bus. Insider (Dec. 

18, 2020), https://www.businessinsider.com/jared-kushner-trump-campaign-shell-companyfamily-ammc-lara-2020-12).

6

 Ex. 1, Admin. Compl. ¶ 13 (citing state and FCC filings). 

7

 E.g., Ex. 1, Admin. Compl. ¶ 19 (quoting Kenneth P. Vogel, Trump Campaign Doubles 

Spending Rate as the 2020 Race Draws Near, N.Y. Times (Oct. 15, 2018), https://www.nytimes.

com/2018/10/15/us/politics/trump-campaign-spending-midterms-2020.html).

8

 Ex. 1, Admin. Compl. ¶ 21 (quoting Ashley Balcerzak, Trump Campaign Spends Big at Trump 

Properties—and Feathers Friends’ Nests, Ctr. for Pub. Integrity (Apr. 15, 2019), https://public

integrity.org/politics/trump-campaign-spends-big-at-trump-properties-and-feathers-friendsnests).

9

 Ex. 1, Admin. Compl. ¶ 23 (quoting Michelle Ye Hee Lee & Anu Narayanswamy, Trump’s 

2016 Campaign Was Run on a Shoestring. His Reelection Machine Is Huge—and Armed with 

Consultants, Wash. Post (Oct. 8, 2019), https://www.washingtonpost.com/nation/2019/10/08/

trumps-campaign-was-run-shoestring-his-reelection-machine-is-huge-armed-with-consultants); 

see also id. ¶ 73 (summarizing media reports regarding the campaign’s control of AMMC). 

10 Ex. 2, Suppl. to Admin. Compl. 1-2. The one exception is a “list acquisition” payment from 

the Republican National Committee—an entity closely associated with the committees—in 

September 2019. Id. at 2.

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31. Second, drawing on publicly available information, the administrative complaint

alleged that the committees used AMMC as a conduit to pay contractors without reporting the 

disbursements to the FEC.11

32. For example, drawing on media reports, press releases, and filings made to agencies 

other than the FEC, the administrative complaint described the Trump campaign’s use of AMMC 

as a conduit to pay software company Phunware, Inc. (“Phunware”) to develop the campaign’s 

official app.12

33. Comments from both Phunware and Trump campaign officials indicated that the 

company effectively worked directly for the Trump campaign, with AMMC serving merely as a 

conduit for payments. Parscale, for example, indicated that the campaign wanted “to build [its] 

own app,” one that the campaign “actually” and “directly owned,”13 and that the campaign was 

involved in the decision to create the app, in defining the project’s scope, and in adjusting the 

project’s goals in light of the COVID-19 pandemic.14 Phunware’s president and CEO similarly 

explained that the company built the software for “the Trump-Pence team,”15 and a company press 

11 See Ex. 1, Admin. Compl. ¶¶ 26-48, 75-80.

12 See Ex. 1, Admin. Compl. ¶¶ 26-34. 

13 Ex. 1, Admin. Compl. ¶ 30 (emphasis omitted) (quoting Dana Bash & Bridget Nolan, Trump’s 

New Campaign App Gamifies Voter Outreach, CNN (Apr. 23, 2020), https://www.cnn.com/2020/

04/23/politics/trump-campaign-app/index.html). 

14 Ex. 1, Admin. Compl. ¶ 31 (citing Peter Doocy, Trump Team Launches New App Allowing 

Supporters to ‘Engage with the Campaign from Their Couch,’ Fox News (Apr. 23, 2020), https://

www.foxnews.com/politics/trump-team-launches-new-app-allowing-supporters-to-engage-withthe-campaign-from-their-couch).

15 Ex. 1, Admin. Compl. ¶ 29 (quoting Josh Rivera, Donald Trump’s 2020 Campaign App Gets 

a Boost with Phunware Partnership, One Day After Twitter Fact-Check, USA Today (May 28, 

2020), https://www.usatoday.com/story/tech/2020/05/27/donald-trump-reelection-app-phunware/

5271268002).

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release touted “American Made Media Consultants (otherwise known as ‘Trump-Pence 2020’ and 

‘Keep America Great’ Campaign)” as new Phunware clients.16

34. Multiple media reports characterized Phunware as “hired” by17 or “working for” 

the Trump campaign.18

35. Yet, although Phunware’s SEC filings revealed that the company received millions 

of dollars in payments from AMMC in 2019 and 2020,19 neither the Trump campaign nor any 

other political committee reported any disbursements to Phunware to the FEC during the 2019-

2020 election cycle.20

36. The administrative complaint described similar evidence that the Trump 

committees used AMMC as a conduit to pay ad-placement firms Realtime Media21 and Harris

Sikes Media LLC22 and peer-to-peer messaging company Opn Sesame,

23 none of which appeared 

16 Ex. 1, Admin. Compl. ¶ 28 (emphasis added) (quoting Press Release, Phunware, Phunware

Announces Third Quarter 2019 Customer Wins (Oct. 4, 2019), https://www.phunware.com/pressreleases/third-quarter-2019-wins).

17 Ex. 1, Admin. Compl. ¶ 28 (quoting Jarrett Renshaw & James Oliphant, With Rallies Halted 

and Tweets Fact-Checked, Trump Campaign Turns to Smartphone App, Reuters (June 2, 2020), 

https://www.reuters.com/article/us-usa-election-trump/with-rallies-halted-and-tweets-factchecked-trump-campaign-turns-to-smartphone-app-idUSKBN2391FT).

18 Ex. 1, Admin. Compl. ¶ 33 (quoting Stephen Gandel & Graham Kates, Phunware, a Data Firm 

for Trump Campaign, Got Millions in Coronavirus Small Business Help, CBS News (Apr. 23, 

2020), https://www.cbsnews.com/news/phunware-data-collection-trump-campaign-coronavirussmall-business-loans). 

19 Ex. 1, Admin. Compl. ¶ 27 (citing Gandel & Kates, supra note 18, and SEC records).

20 Ex. 1, Admin. Compl. ¶ 34 (citing Disbursements to Phunware, FEC.gov, https://www.fec.

gov/data/disbursements/?data_type=processed&recipient_name=phunware&two_year_trans

action_period=2020&max_date=12%2F31%2F2020). No committee reported any payments to 

Phunware after the administrative complaint was filed. See Disbursements to Phunware, supra. 

21 See Ex. 1, Admin. Compl. ¶¶ 35-38. 

22 See Ex. 1, Admin. Compl. ¶¶ 46-48. 

23 See Ex. 1, Admin. Compl. ¶¶ 39-45. 

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in the committees’ FEC-reported expenditures for the 2019-2020 election cycle at the time of the 

complaint’s filing.

24

37. CLC, by conducting independent research, uncovered the links between the 

committees and the four AMMC sub-vendors discussed in the administrative complaint. But that 

research does not enable CLC to discern all the information that FECA required the committees to 

disclose in connection with those sub-vendors, including the amount, date, and purpose of each 

disbursement. 

38. Moreover, the four sub-vendors discussed in CLC’s administrative complaint do 

not account for the full amount of the payments to AMMC reported by the committees or for the

full range of purposes given for those payments. For example, the committees regularly labeled 

disbursements to AMMC as paying for media or video production, yet none of the four subvendors identified in the complaint appear to provide those services.25 Thus, the committees’ 

funneling of payments through AMMC has hidden the identities of other sub-vendors paid through 

AMMC and the details of the committees’ disbursements to those sub-vendors. 

39. The Trump committees’ failure to properly report the disbursements made through 

AMMC to undisclosed sub-vendors therefore violates 52 U.S.C. § 30104(b) and deprives CLC of 

disclosure information to which it is statutorily entitled. 

24 Ex. 1, Admin. Compl. ¶¶ 38, 45, 47. After the complaint’s filing, the Trump campaign reported

a disbursement to Harris Sikes Media LLC on December 22, 2020, for “Recount: Placed Media.” 

See Disbursements to Harris Sikes, FEC.gov, https://www.fec.gov/data/disbursements/?data_

type=processed&recipient_name=harris+sikes (last visited Mar. 29, 2022). This date and 

description would not cover spending made to the firm through AMMC before Election Day. 

25 Ex. 1, Admin. Compl. ¶¶ 11, 80 n.122; see also Disbursements to American Made Media 

Consultants, FEC.gov, https://www.fec.gov/data/disbursements/?committe&data_type=pro

cessed&recipient_name=american+made+media+consultants (last visited Mar. 29, 2022). 

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Parscale Strategy 

40. Again drawing on publicly available information, including media reports, 

statements by Trump campaign officials, and corporate filings, the administrative complaint also

alleged both that the committees did not have an arm’s-length relationship with Parscale Strategy

and that Parscale Strategy acted merely as a conduit for disbursements to sub-vendors.

41. First, the complaint alleged that the committees did not have an arm’s-length 

relationship with Parscale Strategy.26

42. The complaint explained that, according to corporate records, Parscale Strategy’s 

only principal was Brad Parscale, a senior Trump campaign official.27 In addition, the only firms 

to report payments to Parscale Strategy in 2020 were the committees and the Republican National 

Committee, an entity with close ties to the committees.28

43. Second, the complaint alleged that the Trump campaign used Parscale Strategy as 

a conduit to pay salaries for individuals working under the direction and control of the committee.29

44. For example, the complaint compiled numerous media reports indicating, based on 

statements by Parscale and other Trump campaign officials, that the campaign used Parscale 

Strategy as a conduit to pay staff salaries.

30 Among the campaign staff reportedly paid through 

26 See Ex. 1, Admin. Compl. ¶¶ 6, 12, 50-51, 84-85. 

27 Ex. 1, Admin. Compl. ¶¶ 49, 84 (citing Taxable Entity Search Results for “Parscale Strategy,”

Tex. Comptroller of Pub. Accts., https://mycpa.cpa.state.tx.us/coa/coaSearchBtn (search under 

“Entity Name” for “Parscale Strategy”)).

28 Ex. 1, Admin. Compl. ¶¶ 50-51, 85 (citing FEC records). 

29 See Ex. 1, Admin. Compl. ¶¶ 49-60, 86-90. 

30 See Ex. 1, Admin. Compl. ¶¶ 52-59 (citing, for example, Vogel, supra note 7; Vicky Ward & 

Jim Acosta, Trump Campaign Manager Brad Parscale Remains on Defense After Scrutiny over 

Financial Ties, CNN (Sept. 9, 2019), https://www.cnn.com/2019/09/09/politics/brad-parscaletrump-campaign-financial-ties/index.html).

Case 1:22-cv-00838 Document 1 Filed 03/29/22 Page 13 of 16
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Parscale Strategy were Kimberly Guilfoyle and Lara Trump—the girlfriend and wife of former 

President Trump’s sons—and Parscale himself.31

45. The Trump committees did not report any salary payments to Guilfoyle, Parscale, 

or Lara Trump during the 2020 election cycle.32

46. CLC, by conducting independent research, uncovered the information included in 

its administrative filings about the relationship between the Trump committees and Parscale 

Strategy. But the available information is incomplete and cannot substitute for the comprehensive 

and verified disclosure reports required under FECA. And CLC remains unable to discern the

identities of all the staff and contractors potentially paid through Parscale Strategy, or the true 

amounts, dates, and purposes of each payment funneled through Parscale Strategy. 

ADMINISTRATIVE PROCEEDINGS

47. CLC and Margaret Christ, an individual, filed an administrative complaint with the 

FEC against the Trump campaign and the Trump Make America Great Again Committee on July 

28, 2020. The complaint alleged that the committees had violated 52 U.S.C. § 30104(b) by routing 

payments to vendors and staff through AMMC and Parscale Strategy without itemizing those 

disbursements or properly reporting them to the FEC. Ex. 1, Admin. Compl. ¶¶ 70-91. 

48. The FEC responded to the complaint with a letter of acknowledgement dated 

August 28, 2020, informing CLC that the proceeding would be designated Matter Under Review 

7784.33

31 See Ex. 1, Admin. Compl. ¶¶ 52-59 (citing, for example, Danny Hakim & Glenn Thrush, How 

the Trump Campaign Took Over the GOP, N.Y. Times (Dec. 24, 2020), https://www.nytimes.com/

2020/03/09/us/trump-campaign-brad-parscale.html; Ward & Acosta, supra note 30).

32 Ex. 1, Admin. Compl. ¶ 60 (citing FEC records). 

33 The August 28 acknowledgement letter is attached hereto as Exhibit 3. 

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49. On January 28, 2021, CLC and Christ filed a supplement to the July 28, 2020

complaint with the Commission. The supplement explained that the committees had continued to 

route payments through AMMC and Parscale Strategy after CLC filed its administrative 

complaint. Ex. 2, Suppl. to Admin. Compl. 1-2. The supplement also described reporting from 

December 2020 showing that senior Trump campaign officials had approved AMMC’s creation

and appeared on its board, providing further evidence that AMMC was an extension of the Trump 

campaign used to conceal the campaign’s spending. Id. at 2-3.

50. Upon information and belief, the FEC has failed to act on Plaintiff’s July 28, 2020 

administrative complaint or its January 28, 2021 supplement since their filing over twenty and 

fourteen months ago, respectively. The Commission’s inaction has thus persisted well beyond the 

statutorily allotted 120-day response period.

CAUSE OF ACTION

Count I: FECA, 52 U.S.C. § 30109(a)(8)(A)

51. Plaintiff repeats and realleges paragraphs 1-50 as if set forth fully herein.

52. Defendant’s failure to act on Plaintiff's administrative complaint is contrary to law 

under 52 U.S.C. § 30109(a)(8)(A), which provides Plaintiff a cause of action for “a failure of the 

Commission to act on such complaint during the 120-day period beginning on the date the 

complaint is filed.”

REQUESTED RELIEF

WHEREFORE, Plaintiff requests that this Court:

(1) Declare that the FEC’s failure to act on Plaintiff’s administrative complaint was 

contrary to law under 52 U.S.C. § 30109(a)(8)(A);

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(2) Order the FEC to conform with this declaration within 30 days pursuant to 52 

U.S.C. § 30109(a)(8)(C);

(3) Award Plaintiff its costs and reasonable attorneys’ fees incurred in this action; and

(4) Grant such other relief as the Court may deem just and proper. 

Dated: March 29, 2022 Respectfully submitted,

 

/s/ Megan P. McAllen 

Megan P. McAllen (DC Bar No. 1020509) 

Richard Samuel Horan* (pro hac vice

motion forthcoming) 

CAMPAIGN LEGAL CENTER

1101 14TH ST. NW, SUITE 400 

WASHINGTON, D.C. 20005 

(202) 736-2200 

* Licensed to practice in Massachusetts 

only; District of Columbia Bar application 

pending. Supervised by Megan McAllen, a 

member of the D.C. Bar.

Case 1:22-cv-00838 Document 1 Filed 03/29/22 Page 16 of 16