Case 1:22-cv-03282-RDM Document 15 Filed 01/27/23 Page 1 of 19 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

) 

READY FOR RON, ) 

) 

Plaintiff, ) Civ. No. 22-3282 (RDM) 

) 

v. ) 

) 

FEDERAL ELECTION COMMISSION, ) ANSWER 

) 

Defendant. ) 

) 

DEFENDANT FEDERAL ELECTION COMMISSION’S ANSWER 

Defendant Federal Election Commission (“FEC” or “Commission”) submits this Answer 

to the Complaint for Injunctive and Declaratory Relief filed by plaintiff Ready for Ron (“RFR”) 

on October 27, 2022. Any allegation not specifically responded to below is DENIED. 

INTRODUCTION 

Plaintiff’s complaint begins with a series of factual assertions, legal conclusions, and 

opinions in unnumbered paragraphs across pages 1-4. This portion of the complaint does not 

follow the requirement in Fed. R. Civ. P. 10(b) that factual and legal declarations be made in the 

form of numbered paragraphs to facilitate responses by other parties and review by the Court, 

thereby making responses to particular assertions impractical. These opening paragraphs, 

moreover, summarize the allegations in plaintiff’s complaint, which speaks for itself and so no 

response is required. To the extent a response is required, the allegations in this portion of the 

complaint are DENIED. 

1. DENY that 28 U.S.C. § 2201 provides an independent basis for jurisdiction and 

deny that the Court possesses jurisdiction for Counts III-V. 

2. ADMIT. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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3. This paragraph contains plaintiff’s legal conclusions, to which no response is 

required. The Commission is without knowledge or information sufficient to admit or deny the 

factual allegations in this paragraph, including the intent for which RFR was formed. To the 

extent a response is required, ADMIT that RFR has registered with the FEC as an unauthorized, 

non-connected hybrid political committee with a mailing address in Miami Florida. 

4. ADMIT. 

5. This paragraph contains plaintiff’s legal conclusions, to which no response is 

required. The Commission is without knowledge or information sufficient to admit or deny 

whether Florida Governor Ronald Dion DeSantis (“Governor DeSantis”) is presently testing the 

waters with regards to a federal candidacy under 11 C.F.R. § 100.72(a) or meets the definition of 

a “candidate” for President or another federal office under FECA, 52 U.S.C. § 30101(2). 

ADMIT the remaining factual allegations of this paragraph. 

6. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. 

7. ADMIT that RFR has registered and filed disclosure reports with the FEC as an 

unauthorized, non-connected hybrid political committee, also known as a “Carey PAC.” The 

Commission is without knowledge or information sufficient to admit or deny the remaining 

allegations in this paragraph and subparagraphs. 

8. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. 

9. ADMIT that RFR has created a petition advocating that Governor DeSantis 

become a candidate for the Republican nomination for President in the 2024 election. The 

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Commission is without knowledge or information sufficient to admit or deny the remaining 

allegations in this paragraph. 

10. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. 

11. ADMIT that as of January 25, 2023, the cited website displays the text of a 

petition and provides visitors an opportunity to submit personally identifying information. The 

Commission is without knowledge or information sufficient to admit or deny the remaining 

allegations in this paragraph. 

12. This paragraph describes the content of a website, which speaks for itself and so 

no response is required. To the extent a response is required, ADMIT that as of January 25, 

2023, www.readyforron.com contains the quoted statements. 

13. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. 

14. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. 

15. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. 

16. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. 

17. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph and subparagraphs. 

18. This paragraph describes a Commission advisory opinion, which speaks for itself 

and so no response is required. To the extent a response is required, DENY that any action of 

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the Commission has exposed RFR to the possibility of administrative proceedings and potential 

sanctions. DENY that the Commission has represented there is no point in time at which RFR 

may legally provide its signed petition to Governor DeSantis, as the advisory opinion did not 

address or foreclose alternatives such as payment by DeSantis for lists containing supporter 

contact information. ADMIT the remaining allegations in this paragraph. 

19. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. 

20. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph and subparagraphs. 

21. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. 

22. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. 

23. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. 

24. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. 

25. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. 

26. RFR’s statement that there is an “absence of any applicable statutory prohibition” 

as to whether RFR may provide the signed petition to Governor DeSantis before he begins 

testing the waters is a legal conclusion which requires no response. The paragraph contains 

characterizations of an FEC advisory opinion which speaks for itself and so no response is 

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required. The Commission is without knowledge or information sufficient to admit or deny the 

remaining allegations in this paragraph. To the extent a response is required, DENY that the 

Commission’s Advisory Opinion treated the list of the RFR petition’s signatories improperly, 

illegally, or unconstitutionally. 

27. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. 

28. ADMIT that RFR submitted the advisory opinion request attached to the 

Complaint as Exhibit 1 with the Commission in May of 2022. The Commission is without 

knowledge or information sufficient to admit or deny the remaining allegations in this paragraph. 

29. ADMIT. 

30. ADMIT. 

31. ADMIT. 

32. DENY that the correspondence described in this paragraph was provided to the 

Commission “[t]he next day,” i.e. September 16, 2022. The exhibit identified in this paragraph 

indicates that this correspondence was provided to the Commission on September 18, 2022. 

ADMIT the remaining allegations in this paragraph. 

33. ADMIT. 

34. ADMIT. 

35. ADMIT. 

36. ADMIT that on September 27, 2022, RFR submitted a 25-page comment in 

response to Draft C, reflected in Exhibit 7 to the Complaint. The remaining allegations of this 

paragraph characterize Exhibit 7, which speaks for itself and so no response is required. To the 

extent a response is required, the remaining allegations in the paragraph are DENIED. 

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37. ADMIT that on September 27, 2022, the Commission circulated a revised version 

of Draft C for an internal, written 24-hour “tally vote” which concluded on the afternoon of 

September 28, as reflected in Exhibit 8 to the Complaint. The remaining allegations of this 

paragraph are DENIED. 

38. ADMIT that RFR emailed the Commission on September 28, 2022, with 

comments on the Commission’s Advisory Opinion Draft C, as reflected in Exhibit 9 to the 

Complaint. The Commission is without knowledge or information sufficient to admit or deny 

the remaining allegations in this paragraph. 

39. ADMIT that on September 28, 2022, the Commission concluded its paper tally 

vote and approved Draft C as its Advisory Opinion, as reflected in Exhibit 10 to the Complaint 

and that no public hearing was held on RFR’s advisory opinion request after September 15, 

2022. 

40. ADMIT that Exhibit 11 to the Complaint is a true and complete copy of 

Commission Advisory Opinion 2022-12 (Ready for Ron). The remaining allegations in this 

paragraph characterize the contents of the Commission’s approved Advisory Opinion, which 

speaks for itself and is the best evidence of its contents, therefore no response is required. To the 

extent a response is required, those allegations are DENIED. 

41. The allegations in this paragraph and subparagraphs characterize the contents of 

the referenced Advisory Opinion, which speaks for itself and is the best evidence of its contents, 

and contain legal conclusions, therefore no response is required. 

42. The allegations in this paragraph characterize the contents of the referenced 

Advisory Opinion, which speaks for itself and is the best evidence of its contents, therefore no 

response is required. 

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43. The allegations in this paragraph characterize the contents of the referenced 

Advisory Opinion, which speaks for itself and is the best evidence of its contents, therefore no 

response is required. 

44. The allegations in this paragraph characterize the contents of the referenced 

Advisory Opinion, which speaks for itself and is the best evidence of its contents, therefore no 

response is required. 

45. The allegations in this paragraph characterize the contents of the referenced 

Advisory Opinion, which speaks for itself and is the best evidence of its contents, therefore no 

response is required. 

46. This paragraph contains plaintiff’s legal conclusions, to which no response is 

required. To the extent a response is required, the allegations are DENIED. 

47. This paragraph contains plaintiff’s legal conclusions, to which no response is 

required. 

48. This paragraph and subparagraphs characterize a judicial opinion, which speaks 

for itself and is the best evidence of its contents, therefore no response is required. 

49. This paragraph consists of plaintiff’s legal conclusions, to which no response is 

required. To the extent a response is required, the allegations are DENIED. 

50. This paragraph consists of plaintiff’s legal conclusions, to which no response is 

required. To the extent a response is required, the allegations are DENIED. 

51. This paragraph consists of plaintiff’s legal conclusions, to which no response is 

required. 

52. This paragraph consists of plaintiff’s legal conclusions, to which no response is 

required. 

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53. This paragraph consists of plaintiff’s legal conclusions, to which no response is 

required. To the extent a response is required, the allegations are DENIED. 

54. This paragraph consists of plaintiff’s legal conclusions, to which no response is 

required. To the extent a response is required, the allegations are DENIED. 

55. This paragraph characterizes judicial opinions, which speak for themselves and 

are the best evidence of their contents, therefore no response is required. This paragraph also 

consists of plaintiff’s legal conclusions, to which no response is required. To the extent a 

response may be required to the third sentence, the allegations are DENIED. 

56. This paragraph characterizes a judicial opinion, which speaks for itself and is the 

best evidence of its contents, therefore no response is required. 

57. This paragraph characterizes a judicial opinion, which speaks for itself and is the 

best evidence of its contents, therefore no response is required. 

58. This paragraph characterizes a judicial opinion, which speaks for itself and is the 

best evidence of its contents, therefore no response is required. This paragraph also consists of 

plaintiff’s legal conclusions, to which no response is required. 

59. This paragraph characterizes judicial opinions, which speak for themselves and 

are the best evidence of their contents, therefore no response is required. This paragraph also 

consists of plaintiff’s legal conclusions, to which no response is required. To the extent a 

response is required to the second sentence of this paragraph, the allegations are DENIED. 

60. This paragraph contains plaintiff’s legal conclusions, to which no response is 

required. 

61. This paragraph contains plaintiff’s legal conclusions, to which no response is 

required. 

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62. This paragraph characterizes the contents of an FEC report, which speaks for 

itself and is the best evidence of its contents, therefore no response is required. To the extent a 

response is required, ADMIT that the FEC made legislative recommendations regarding draft 

committees in 1976. 

63. This paragraph characterizes the contents of FEC legislative recommendations, 

which speak for themselves and are the best evidence of their contents, therefore no response is 

required. 

64. This paragraph characterizes the contents of proposed legislative amendments, 

which speak for themselves and are the best evidence of their contents, therefore no response is 

required. 

65. This paragraph and subparagraphs characterize the contents of proposed 

legislation, which speaks for itself and is the best evidence of its contents, therefore no response 

is required. 

66. DENY that RFR’s provision of its signed petition to Governor DeSantis should 

not at any juncture be deemed a “contribution.” The remaining allegations in this paragraph are 

legal conclusions, to which no response is required. 

67. DENY. 

68. This paragraph characterizes the contents of a statute and regulation, which speak 

for themselves and are the best evidence of their contents, therefore no response is required. 

69. This paragraph consists of plaintiff’s legal conclusions, to which no response is 

required. 

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70. This paragraph consists of plaintiff’s legal conclusions, to which no response is 

required. To the extent a response is required, the allegations regarding plaintiff’s petition are 

DENIED. 

71. This paragraph characterizes the contents of judicial opinions, which speak for 

themselves and are the best evidence of their contents, therefore no response is required. This 

paragraph also consists of plaintiff’s legal conclusions, to which no response is required. To the 

extent a response is required, the allegations are DENIED. 

72. This paragraph and subparagraphs consist of plaintiff’s legal conclusions, to 

which no response is required. To the extent a response is required, the allegations are DENIED. 

73. This paragraph characterizes various statutes and regulations, which speak for 

themselves and are the best evidence of their contents, therefore no response is required. This 

paragraph also consists of plaintiff’s legal conclusions, to which no response is required. 

74. DENY that there is no legal basis upon which the FEC’s advisory opinion refused 

to affirm RFR’s right to share its signed petition to Governor DeSantis before he begins testing 

the waters. The remaining allegations of this paragraph consist of plaintiff’s legal conclusions, 

to which no response is required. 

75. DENY that no statutory authority exists for the cited regulation. This paragraph 

characterizes the contents of a statute and regulation, which speak for themselves and are the best 

evidence of their contents, therefore no response is required. This paragraph also consists of 

plaintiff’s legal conclusions, to which no response is required. To the extent a response is 

required, the remaining allegations of this paragraph are DENIED. 

76. This paragraph characterizes the contents of a statute and regulations, which 

speak for themselves and are the best evidence of their contents, therefore no response is 

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required. The remaining allegations of this paragraph consist of plaintiff’s legal conclusions, to 

which no response is required. To the extent a response is required, the allegations are DENIED. 

77. This paragraph and subparagraphs characterize the contents of a regulation and 

the record of Commission hearings, which speak for themselves and are the best evidence of 

their contents, therefore no response is required. The remaining allegations of this paragraph 

consist of plaintiff’s legal conclusions, to which no response is required. The news articles cited 

in the accompanying footnote speak for themselves, and are the best evidence of their contents, 

therefore no response is required. To the extent a response is required, the allegations are 

DENIED. 

78. The allegations in this paragraph consist of plaintiff’s legal conclusions, to which 

no response is required. To the extent a response is required, the allegations are DENIED. 

79. This paragraph characterizes the contents of a statute, which speaks for itself and 

is the best evidence of its contents, therefore no response is required. 

80. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. 

81. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. 

82. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. 

83. The Commission is without knowledge or information sufficient to admit or deny 

allegations in this paragraph. The allegations in this paragraph also consist of plaintiff’s legal 

conclusions, to which no response is required. 

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84. The Commission is without knowledge or information sufficient to admit or deny 

the factual allegations in this paragraph. The allegations in this paragraph also consist of 

plaintiff’s legal conclusions, to which no response is required. DENY the allegation stating the 

FEC is defending “a bizarre pay-to-play system[.]” 

85. DENY. 

86. The allegations in this paragraph consist of plaintiff’s legal conclusions, to which 

no response is required. To the extent a response is required, the allegations are DENIED. 

87. DENY. 

88. This paragraph characterizes a Commission advisory opinion, which speaks for 

itself and is the best evidence of its contents, therefore no response is required. To the extent a 

response is required, DENY that the Commission’s advisory opinion affirmatively prohibited 

RFR from providing its petition to Governor DeSantis, which misstates the legal effect of an 

advisory opinion in general, and the scope of this advisory opinion in particular, as the advisory 

opinion did not address or foreclose alternatives such as payment by DeSantis for lists containing 

supporter contact information. DENY that RFR would be “forced to discontinue” soliciting and 

collecting signatures and signatories’ contact information for its petition if Governor DeSantis 

begins testing the waters or becomes a candidate. The Commission is without knowledge or 

information sufficient to admit or deny what knowledge or information RFR has regarding 

Governor DeSantis, what RFR seeks to do in the future, or its plans regarding spending and/or 

advocacy. The remaining allegations in this paragraph and subparagraphs consist of plaintiff’s 

legal conclusions, to which no response is required. 

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89. The allegations in this paragraph and subparagraphs consist of plaintiff’s legal 

conclusions, to which no response is required. To the extent a response is required, the 

allegations are DENIED. 

90. The allegations in this paragraph consist of plaintiff’s legal conclusions, to which 

no response is required. To the extent a response is required, the allegations are DENIED. 

91. The allegations in this paragraph consist of plaintiff’s legal conclusions, to which 

no response is required. To the extent a response is required, the allegations are DENIED. 

92. The Commission is without knowledge or information sufficient to admit or deny 

any factual allegation in this paragraph regarding RFR’s planned future conduct. The heading 

preceding this paragraph consist of plaintiff’s legal conclusions, to which no response is 

required. 

93. The Commission incorporates by reference its responses to the allegations 

contained in each of the preceding paragraphs of plaintiff’s complaint. 

94. DENY. 

95. The allegations in this paragraph consist of plaintiff’s legal conclusions, to which 

no response is required. 

96. The allegations in this paragraph consist of plaintiff’s legal conclusions, to which 

no response is required. To the extent a response is required, the allegations that plaintiff’s First 

Amendment rights have been violated are DENIED. DENY the allegations following this 

numbered paragraph beginning with “WHEREFORE.” 

97. The Commission incorporates by reference its responses to the allegations 

contained in each of the preceding paragraphs of plaintiff’s complaint. The heading above this 

paragraph is DENIED. 

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98. This paragraph characterizes the contents of a statute, which speaks for itself and 

is the best evidence of its contents, therefore no response is required. 

99. ADMIT. 

100. This paragraph characterizes a Commission advisory opinion, which speaks for 

itself and is the best evidence of its contents, therefore no response is required. To the extent a 

response is required, DENY that the Commission ruled that there are no circumstances in which 

RFR could provide a signed petition to Governor DeSantis while he is testing the waters or after 

he becomes a candidate, as the advisory opinion did not address or foreclose alternatives such as 

payment by DeSantis for lists containing supporter contact information, and DENY that the 

Commission ruled RFR may not spend funds from its non-contribution Carey account to 

advertise a petition and invite people to sign it. 

101. ADMIT that the Commission’s Advisory Opinion 2022-12 (Ready for Ron) does 

not provide a “safe harbor” under 52 U.S.C. § 30108(c)(1)(A), (2) for RFR’s proposed course of 

conduct. The remaining allegations of this paragraph are DENIED. 

102. The allegations in this paragraph consist of plaintiff’s legal conclusions, to which 

no response is required. To the extent a response is required, the allegations are DENIED. 

103. The allegations in this paragraph consist of plaintiff’s legal conclusions, to which 

no response is required. To the extent a response is required, the allegations are DENIED. 

104. DENY. The allegations following this numbered paragraph beginning with 

“WHEREFORE” are DENIED. 

105. The Commission incorporates by reference its responses to the allegations 

contained in each of the preceding paragraphs of plaintiff’s complaint. 

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106. This paragraph characterizes the contents of a statute, which speaks for itself and 

is the best evidence of its contents, therefore no response is required. 

107. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. 

108. The allegations in this paragraph consist of plaintiff’s legal conclusions, to which 

no response is required. The allegations following this numbered paragraph beginning with 

“WHEREFORE” are DENIED. 

109. The Commission incorporates by reference its responses to the allegations 

contained in each of the preceding paragraphs of plaintiff’s complaint. 

110. This paragraph characterizes the contents of a judicial opinion, which speaks for 

itself and is the best evidence of its contents, therefore no response is required. 

111. The allegations in this paragraph consist of plaintiff’s legal conclusions, to which 

no response is required. To the extent a response is required, the allegations are DENIED. 

112. The allegations in this paragraph consist of plaintiff’s legal conclusions, to which 

no response is required. 

113. The allegations in this paragraph consist of plaintiff’s legal conclusions, to which 

no response is required. To the extent a response is required, the allegations are DENIED. 

114. The allegations in this paragraph consist of plaintiff’s legal conclusions, to which 

no response is required. To the extent a response is required, the allegations are DENIED. 

115. The allegations in this paragraph consist of plaintiff’s legal conclusions, to which 

no response is required. To the extent a response is required, the allegations are DENIED. 

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116. The allegations in this paragraph and the paragraph after “WHEREFORE” consist 

of plaintiff’s legal conclusions, to which no response is required. To the extent a response is 

required, the allegations are DENIED. 

117. The Commission incorporates by reference its responses to the allegations 

contained in each of the preceding paragraphs of plaintiff’s complaint. 

118. This paragraph characterizes the contents of a statute, which speaks for itself and 

is the best evidence of its contents, therefore no response is required. 

119. This paragraph characterizes the contents of a statute, which speaks for itself and 

is the best evidence of its contents, therefore no response is required. 

120. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. To the extent a response is required, the allegations are 

DENIED. 

121. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. To the extent a response is required, the allegations are 

DENIED. 

122. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. To the extent a response is required, the allegations are 

DENIED. 

123. The Commission is without knowledge or information sufficient to admit or deny 

the allegations in this paragraph. The allegations in this paragraph also consist of plaintiff’s legal 

conclusions, to which no response is required. To the extent a response is required, the 

allegations are DENIED. The allegations following this numbered paragraph beginning with 

“WHEREFORE” are DENIED. 

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124. The Commission incorporates by reference its responses to the allegations 

contained in each of the preceding paragraphs of plaintiff’s complaint. 

125. This paragraph characterizes the contents of a statute, which speaks for itself and 

is the best evidence of its contents, therefore no response is required. 

126. DENY that RFR’s requested Advisory Opinion sought to “confirm[] its right” to 

engage in its proposed course of conduct. ADMIT the remaining allegations of this paragraph. 

127. This paragraph characterizes a Commission advisory opinion, which speaks for 

itself and is the best evidence of its contents, therefore no response is required. To the extent a 

response is required, DENY that the Commission ruled that there are no circumstances in which 

RFR could provide a signed petition to Governor DeSantis while he is testing the waters, as the 

advisory opinion did not address or foreclose alternatives such as payment by DeSantis for lists 

containing supporter contact information. 

128. This paragraph characterizes the contents of a statute and regulations, which 

speak for themselves and are the best evidence of their contents, therefore no response is 

required. 

129. This paragraph characterizes the contents of a statute, which speaks for itself and 

is the best evidence of its contents, therefore no response is required. 

130. DENY. 

131. The allegations in this paragraph consist of plaintiff’s legal conclusions, to which 

no response is required. The allegations following this numbered paragraph beginning with 

“WHEREFORE” are DENIED. 

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PRAYER FOR RELIEF 

Plaintiff is not entitled to the relief prayed for in this portion of the complaint, or to any 

other relief. 

AFFIRMATIVE DEFENSES 

1. The Court lacks subject matter jurisdiction for Counts III-V. 

Respectfully submitted, 

Lisa J. Stevenson (D.C. Bar No. 457628) /s/ Christopher H. Bell 

Acting General Counsel Christopher H. Bell (D.C. Bar No. 1643526) 

lstevenson@fec.gov Attorney 

chbell@fec.gov 

Kevin Deeley 

Associate General Counsel COUNSEL FOR DEFENDANT 

kdeeley@fec.gov FEDERAL ELECTION COMMISSION 

1050 First Street, N.E. 

Jacob S. Siler Washington, D.C. 20463 

Assistant General Counsel (202) 694-1650 

jsiler@fec.gov 

January 27, 2023 

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CERTIFICATE OF SERVICE 

I hereby certify that on January 27, 2023, I served the foregoing pursuant to Fed. R. Civ. 

P. 5(b)(2)(E) on counsel of record, as a registered ECF user, through the Court’s ECF system. 

/s/ Christopher H. Bell 

Christopher H. Bell (D.C. Bar No. 1643526) 

Attorney 

chbell@fec.gov