FEDERAL ELECTION COMMISSION WASHINGTON, D.C.

February 8, 2024 

Mr. R. Reid LeBeau II, Esq. 

The Jacobson Law Group 

180 East Fifth St., Suite 940 

St. Paul, MN 55101 

rlebeau@thejacobsonlawgroup.com

 MUR 7537

Dear Mr. LeBeau: 

On November 1, 2018, you, on behalf of your client, Friends of Erik Paulsen, filed a

complaint with the Federal Election Commission alleging violations of the Federal Election

Campaign Act, as amended. You were notified by letter of the action taken by the Commission

regarding the complaint on September 30, 2021. 

On February 6, 2024, the Commission rescinded its reason to believe findings in this 

matter and closed its file. Enclosed is a Statement of Reasons adopted by the Commission 

explaining its vote. This document will be placed on the public record as part of the file in this

matter.

If you have any questions, please contact me at (202) 694-1650. 

Sincerely,

Wanda D. Brown 

Assistant General Counsel 

Enclosure 

 Statement of Reasons

MUR753700163
FEDERAL ELECTION COMMISSION

Washington, DC 20463 

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of ) 

 ) 

Care in Action, Inc. ) MUR 7537 

 ) 

STATEMENT OF REASONS OF CHAIRMAN SEAN J. COOKSEY, VICE CHAIR 

ELLEN L. WEINTRAUB, AND COMMISSIONERS SHANA M. BROUSSARD, ALLEN 

J. DICKERSON, DARA LINDENBAUM, AND JAMES E. “TREY” TRAINOR III

 The Federal Election Campaign Act requires the Commission to notify respondents of a 

complaint filed against them.1 While Care in Action, Inc. was named in the Complaint in this 

matter, it was not notified prior to a finding of reason to believe, through no fault of its own.

2

 

On September 30, 2021, at the recommendation of the Office of General Counsel, the 

Commission found reason to believe that “Unknown Respondents” failed to report expenditures 

and include disclaimers on certain communications in violation of 52 U.S.C. §§ 30104(b), (c) or 

(g), and 30120(a).3 Due to the failure to timely notify Care in Action and as a matter of 

procedural fairness, we voted to rescind the reason-to-believe findings in this matter.4 

__________________ ______________________ 

Date Sean J. Cooksey 

 Chairman

__________________ ______________________ 

Date Ellen L. Weintraub 

 Vice Chair

1

 See 52 U.S.C. § 30109(a) (“Within 5 days after receipt of a complaint, the Commission shall notify, in 

writing, any person alleged in the complaint to have committed such a violation. Before the Commission conducts 

any vote on the complaint, other than a vote to dismiss, any person so notified shall have the opportunity to 

demonstrate, in writing, to the Commission within 15 days after notification that no action should be taken against 

such person on the basis of the complaint.”)

2

 See Compl. at 1, MUR 7532 (Care in Action). The Commission voted to merge MUR 7532 into MUR 

7537. Certification at ¶ 8a (Oct. 4, 2021).

3

 Certification at ¶ 8b, d (Oct. 4, 2021). 

4

 Amended Certification at 1 (Feb. 6, 2024). 

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MUR753700164
MUR 7537 (Care in Action) 

Statement of Reasons

Page 2 of 2 

__________________ ______________________ 

Date Shana M. Broussard 

 Commissioner 

 

__________________ ______________________ 

Date Allen J. Dickerson 

 Commissioner

__________________ ______________________ 

Date Dara Lindenbaum 

 Commissioner

__________________ ______________________ 

Date James E. “Trey” Trainor III 

 Commissioner

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MUR753700165