JAMES Bopp, JR.' 

Senior Associates 

RICHARD E. COLESON' 

RANDY ELF' 

JEFFREY P. GALLANT' 

Associates 

ANITA Y . WOUDENBERG' 

KAYLAN L. PHILLIPS* 

JOSEPH A . VANDERHULST' 

NOEL H. JOHNSON^ 

'admitted in Ind. 

'admitted in NY and Penn. 

'admitted in Va. 

''admitted in Okla. 

'admitted in Wis. 

THE BOPP LAW FIRM 

ATTORNEYS AT LA W 

THE NATIONAL BUILDING 

I South Sixth Street 

TERRE HAUTE, INDIANA 47807-3510 

Telephone 812/232-2434 Facsimile 812/23S-368S 

THOMAS J. MARZEN 

(1946-2007) 

E-MAIL ADDRESSES 

jboppjr@aol.com 

rcoleson@bopplaw.com 

reir@bopplaw.com 

jgalIant@bopplaw.com 

awoudenberg@bopplaw.com 

kphill ips@bopplaw.com 

jvanderhulst@bopplaw,com 

njohnson@bopplaw.com 

December 20,2011 

Mr. Thomas Hintermister 

Audit Division 

Federal Election Conunission 

999 E Street, N.W. 

Washington, DC 20463 

VIA FAX: 202-219-3483 

Dear Mr. Hintermister: 

Re: National Right to Life PAC 

As you know, this firm represents the National Right to Life PAC (NRL PAC) in regard 

to the audit of the 2007-08 election cycle. Statements of Designation of Counsel were previously 

provided. This will acknowledge receipt of your Draft Final Audit Report, dated December 2, 

2011. This is NRL PACs response and request for a hearing. 

Response to the Draft Final Audit Report 

The basis for Finding 1 is a bookkeeping error on the part of NRL PAC. Because of this 

intemal error, certain expenditures were reported as both expenditures and advances. As a result, 

NRL PAC overstated expenditures and understated its cash-on-hand. This error has been 

corrected internally and NRL PAC has filed corrected reports with the FEC. 

With respect to Finding 2, NRL PAC has complied with all legal requirements 

conceming the exercise of best efforts to obtain and provide contributor occupation and/or name 

of employer information. NRL PAC has filed amended Schedules A that materially correct the 

missing contributor information. Furthermore, the procedures used by NRL PAC to obtain this 

information from contributors satisfy the best efforts requirements. The recommendations by the 

Audit staff require further documentation that is not required by law. 
Federal Election Commission 

December 20,2011 

Page 2 

Finally, the scope limitation in the report is incorrect. Invoices and broadcast station 

affidavits for the expenditures in question were provided to the Audit staff for review. 

Request for Hearing 

Respondent NRL PAC requests a hearing before the Commission to present legal 

arguments conceming the findings in the Draft Final Audit Report. 11 CFR Part 111. 

A hearing is being requested because (1) the misstatements of financial activity have 

been corrected; (2) the committee complied with all best efforts requirements in obtaining 

contributor occupation and/or name of employer information, yet the audit process now requires 

them to produce documentation above and beyond what is required to show best efforts; and (3) 

the creation and maintenance of invoices and broadcast affidavits are not required by law when 

making independent expenditures, and yet the audit process is now requiring them. 

The issues that NRL PAC will address at the hearing are: (1) whether the correction of 

reports should be satisfactory in an audit proceeding; (2) whether the Commission's 

requirements for showing best efforts in obtaining contributor infonnation provide a clear 

standard for what is required; and (3) whether invoices and broadcast affidavits are required by 

law so that a committee under audit can be made to produce them in response. 

Sincerely, 

THE BOPP LAW FIRM 

James Bopp, Jr. 

Joseph A. Vanderhulst