UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA 

 

 ) 

FEDERAL ELECTION COMMISSION, ) 

999 E Street, N.W. ) 

Washington, DC 20463, ) 

 ) 

 Plaintiff, ) 

 ) 

 v. ) No. __ 

 ) 

EDWARD J. LYNCH, Sr., ) COMPLAINT 

10269 Trianon Pl. ) 

Wellington, FL 33449, ) 

 ) 

LYNCH FOR CONGRESS, ) 

P.O. Box 210544, ) 

Royal Palm Beach, FL 33421, ) 

 ) 

and ) 

 ) 

EDWARD J. LYNCH, Sr., ) 

in his official capacity as Treasurer of ) 

Lynch for Congress, ) 

c/o Lynch for Congress ) 

P.O. Box 210544, ) 

Royal Palm Beach, FL 33421, ) 

 ) 

 Defendants. ) 

 ) 

PLAINTIFF FEDERAL ELECTION COMMISSION’S 

COMPLAINT FOR CIVIL PENALTY, DECLARATORY, 

INJUNCTIVE, AND OTHER APPROPRIATE RELIEF 

1. Between 2008 and 2010, defendants converted as much as $53,500 of campaign 

contributions given to Lynch for Congress, the principal campaign committee for Edward J. 

Lynch, Sr. for his 2008 campaign for United States Congress to represent Florida’s 19th 

Congressional District in the United States House of Representatives and in his 2010 special 

election campaign for the same seat, for Mr. Lynch’s personal use. Mr. Lynch used campaign 

Case 9:15-cv-81732-XXXX Document 1 Entered on FLSD Docket 12/18/2015 Page 1 of 11
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funds to pay for various personal expenses, including monthly gym membership dues, payments 

on a personal loan, various automobile expenses, and retail purchases. The Federal Election 

Commission seeks a declaration that defendants’ conversion of $1,622 of campaign funds for 

Mr. Lynch’s personal use on or after August 12, 2010 violated 52 U.S.C. § 30114(b), the 

assessment of a $7,500 civil penalty against Mr. Lynch in his personal capacity, the assessment 

of a $7,500 civil penalty against Lynch for Congress and Mr. Lynch in his official capacity as 

treasurer of that committee, an order requiring Mr. Lynch to disgorge the $1,622 of campaign 

funds converted to personal use on or after August 12, 2010, and a permanent injunction against 

future similar violations by defendants. 

JURISDICTION AND VENUE 

2. This action seeks declaratory, injunctive, and other appropriate relief pursuant to 

the express authority granted by Congress to the Federal Election Commission in the Federal 

Election Campaign Act (“Act” or “FECA”), codified at 52 U.S.C. §§ 30101-146.1

3. This Court has jurisdiction over this suit pursuant to 28 U.S.C. § 1345 as an action 

brought by an agency of the United States expressly authorized to sue by an act of Congress. 52 

U.S.C. §§ 30107(a)(6), 30109(a)(6)(A). 

4. A substantial part of the acts or omissions giving rise to this suit occurred in this 

district and venue is properly found in the United States District Court for the Southern District 

of Florida pursuant to 28 U.S.C. § 1391(b) and 52 U.S.C. § 30109(a)(6)(A). 

                                                           

1 Until recently, FECA’s provisions were found in Title 2 of the United States Code. 

Those provisions have now been moved to new Title 52. [The alleged violations and many of the 

administrative actions in this matter occurred prior to this change.] A full transfer table is 

available at http://uscode.house.gov/editorialreclassification/t52/Reclassifications_Title_52.html.

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THE PARTIES 

5. Plaintiff Federal Election Commission (“Commission” or “FEC”) is the 

independent agency of the United States government with exclusive jurisdiction over the 

administration, interpretation, and civil enforcement of FECA. See 52 U.S.C. §§ 30106(b)(1), 

30107(a), 30109. The Commission is authorized to institute investigations of possible violations 

of the Act, 52 U.S.C. § 30109(a)(1)-(2), and to initiate civil actions in the United States district 

courts to obtain judicial enforcement of the Act, 52 U.S.C. §§ 30107(e), 30109(a)(6). 

6. Defendant Edward J. Lynch, Sr. was a candidate, within the meaning of 52 U.S.C. 

§ 30101(2), to represent Florida’s 19th Congressional District in the United States House of 

Representatives in 2008 and in a special election for the same congressional seat in 2010. 

7. Defendant Lynch for Congress (“Lynch Committee”) was and is a political 

committee of Edward J. Lynch, Sr. within the meaning of 52 U.S.C. § 30101(4). Mr. Lynch 

designated the Lynch Committee as his authorized principal campaign committee, within the 

meaning of 52 U.S.C. § 30101(5)-(6), for the 2008 election to represent Florida’s 19th 

Congressional District in the United States House of Representatives and the 2010 special 

election for the same congressional seat. As such, the Lynch Committee was authorized to 

receive contributions and make expenditures on behalf of the candidate, Edward J. Lynch, Sr. 

See 52 U.S.C. § 30102(e)(1)-(2). No expenditure by or on behalf of the Lynch Committee could 

or can be made without the authorization of the Committee’s treasurer or his or her agent. See 

52 U.S.C. §§ 30102(a), 30103(b)(4). 

8. In addition to being a candidate, Mr. Lynch has served as the treasurer and 

custodian of records for the Lynch Committee since February 28, 2008. 

 

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RELEVANT STATUTORY AND REGULATORY PROVISIONS 

9. FECA provides that contributions accepted by a candidate may be used by the 

candidate for, inter alia, “otherwise authorized expenditures in connection with the campaign for 

Federal office of the candidate.” 52 U.S.C. § 30114(a)(1). 

10. The Act provides that contributions or donations described in 52 U.S.C. 

§ 30114(a) “shall not be converted by any person to personal use.” 52 U.S.C. § 30114(b)(1). 

11. The Act defines “personal use” as the use of a contribution or donation “to fulfill 

any commitment, obligation, or expense of a person that would exist irrespective of the 

candidate’s election campaign or individual’s duties as a holder of Federal office.” 52 U.S.C. 

§ 30114(b)(2). 

12. Personal use includes, inter alia, payments of home mortgages, rent, or utilities; 

clothing purchases; non-campaign related automobile expenses; and health club dues, among 

other payments. 52 U.S.C. § 30114(b)(2); 11 C.F.R. § 113.1(g). 

13. In enforcement actions instituted by the Commission, courts are authorized to 

grant injunctions or other orders, including assessing civil penalties that do not exceed the 

greater of $7500 or an amount equal to any contribution or expenditure involved, for each 

violation of the Act. 52 U.S.C. § 30109(a)(6)(B); 11 C.F.R. § 11.24(a)(1) (providing the 

inflation-adjusted statutory penalty amount). 

14. Actions “for the enforcement of any civil fine, penalty, or forfeiture, pecuniary or 

otherwise,” including for violations of the personal use prohibition, are subject to a five-year 

statute of limitations. 28 U.S.C. § 2462. 

 

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FACTUAL BACKGROUND

15. Edward J. Lynch, Sr. was an unsuccessful candidate in the 2008 election to 

represent Florida’s 19th Congressional District in the United States House of Representatives 

and again in the 2010 special election for the same congressional seat. 

16. During his first campaign, Mr. Lynch filed a Statement of Candidacy and 

Statement of Organization designating himself as treasurer and custodian of records for the 

Lynch Committee. He filed a new Statement of Candidacy when he decided to participate in the 

2010 special election to fill a vacancy resulting from Representative Robert Wexler’s retirement 

and did not change his designation as the Lynch Committee’s treasurer. 

17. Evidence obtained by the Commission indicates that during each campaign, Mr. 

Lynch exercised nearly exclusive oversight of the Lynch Committee’s funds and bank records 

and that he restricted his staff’s access to records reflecting the Lynch Committee’s financial 

activities and status. 

18. Evidence obtained by the Commission further indicates that between 2008 and 

2010, as much as $53,500 in campaign contributions to the Lynch Committee were used to pay 

Mr. Lynch’s personal expenses. 

19. Mr. Lynch has admitted that he spent “over $5,000” in campaign funds for 

personal expenses, including seven months of a recurring gym membership fee, a home utility 

bill payment, an emergency room visit, a driver’s license fee, payment on a personal loan, 

purchase of a gun holster, shooting range fees, and retail and clothing purchases. 

20. Mr. Lynch has also admitted that he spent campaign funds on expenses that were 

for a mixture of campaign and personal use, including vehicle expenses, cell phone payments, 

meals, and cash withdrawals, and he has stated that he failed to document such expenditures. 

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21. Bank records subpoenaed by the Commission reflect $30,530 in cash withdrawals 

through ATM and bank teller withdrawals for which there is no documentation reflecting how 

the withdrawn fund were used or by whom. 

22. This complaint seeks relief for each of the following expenditures, made on or 

after August 12, 2010 — months after Mr. Lynch lost the April 2010 special election for 

Florida’s 19th Congressional District in the United States House of Representatives — of 

personal expenses of Mr. Lynch with the Lynch Committee’s campaign funds: 

Date Amount of 

disbursement

Description of Payment in Bank Statement 

8/12/2010 $66.39 Shell Oil 

8/16/2010 $25.46 Advance Auto Parts 

8/18/2010 $92.12 Pep Boys 

8/19/2010 $10.65 PF Gyms 

8/19/2010 $53.75 Shell Oil 

8/20/2010 $59.22 Chevron 

8/30/2010 $69.00 Shell Oil 

8/30/2010 $35.00 The Ladders 

9/2/2010 $82.72 ER Bradley's Saloon 

9/3/2010 $42.00 Lake Point BP 

9/7/2010 $17.36 Publix 

9/16/2010 $500.00 Over the Counter W/D 

9/16/2010 $52.77 On the Border Royal 

9/16/2010 $64.18 Shell Oil 

9/16/2010 $286.42 Kohl’s 

9/17/2010 $10.65 PF Royal Palm 

9/20/2010 $52.61 Shell Oil 

9/27/2010 $62.54 Exxon Mobil 

10/10/2010 $29.00 PF Royal Palm 

11/17/2010 $10.65 PLA FIT RPB member pay 

TOTAL $1,622.49 

ADMINISTRATIVE PROCEEDINGS

23. The underlying administrative enforcement matter, Matter Under Review 

(“MUR”) 6498, was internally generated as a result of the Commission’s review of information 

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in the normal course of carrying out its supervisory responsibilities indicating that Mr. Lynch 

and his principal authorized campaign committee may have violated, inter alia, FECA’s personal 

use provisions. 

24. On or about June 14, 2010, the Commission sent defendants Mr. Lynch and the 

Lynch Committee a letter notifying them that the Commission had ascertained information in the 

normal course of carrying out its supervisory responsibilities indicating that the Lynch 

Committee and Mr. Lynch, personally and in his official capacity as treasurer of the Lynch 

Committee, may have violated FECA by, inter alia, using campaign funds for personal expenses 

and that the matter had been referred to the Commission’s Office of General Counsel for 

possible enforcement action. The letter further informed defendants that the Commission’s 

Office of General Counsel was reviewing the information in connection with making a 

recommendation to the Commission as to whether there is reason to believe that defendants 

violated the Act, and that before the General Counsel makes such a recommendation, defendants 

may provide in writing any factual or legal materials that they believe are relevant to the matter, 

including any related documents. 

25. On July 6, 2010, the Commission received a letter from Mr. Lynch responding to 

the Commission’s June 14 notification letter. 

26. After reviewing the available information, on November 1, 2011, the FEC voted 

6-0 to find reason to believe that Mr. Lynch violated, inter alia, 2 U.S.C. § 439a(b) [now 52 

U.S.C. § 30114(b)] by using campaign funds for personal expenses, that the Lynch Committee 

and Mr. Lynch, in his official capacity as treasurer of the Lynch Committee, violated, inter alia, 

2 U.S.C. § 439a(b) [now 52 U.S.C. 30114(b)] by disbursing campaign funds for Mr. Lynch’s 

Case 9:15-cv-81732-XXXX Document 1 Entered on FLSD Docket 12/18/2015 Page 7 of 11
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personal expenses, and open an investigation. The Commission notified defendants of its 

reason-to-believe determination by letter sent on or about November 7, 2011. 

27. During the course of the Commission’s investigation of MUR 6498, the parties 

executed two tolling agreements, first on April 1, 2013, and second on May 28, 2013, each time 

allowing defendants additional time to respond to a letter and subpoena from the Commission 

and extending the Commission’s time to institute a civil law enforcement suit by a period of 60 

calendar days from the expiration date of the five-year statute of limitations found at 28 U.S.C. 

§ 2462.

28. On or about July 1, 2015, the Commission’s Office of General Counsel notified 

defendants that the Office of General Counsel was prepared to recommend that the Commission 

find “probable cause” to believe that the defendants had violated, inter alia, 2 U.S.C. § 439a(b) 

[now 52 U.S.C. § 30114(b)]. See 52 U.S.C. § 30109(a)(3). The Office of General Counsel also 

enclosed with its July 1 notification a brief stating the position of the Office on the legal and 

factual issues of the matter, and informed defendants that they may file a brief stating their 

position on the issues and replying to the brief of the Office of General Counsel. Defendants did 

not file a response to the General Counsel’s brief. 

29. On or about September 10, 2015, the Commission sent Mr. Lynch a letter 

referencing its July 1, 2015 notification and enclosed brief and the lack of any timely reply to 

that brief by defendants. The letter further referenced the Commission’s receipt on August 5, 

2015, of a notification from the defendants’ former counsel that he had withdrawn from further 

representation of the defendants. The letter advised Mr. Lynch of the Office General Counsel’s 

intent to proceed with recommending that the Commission find probable cause to believe that 

Case 9:15-cv-81732-XXXX Document 1 Entered on FLSD Docket 12/18/2015 Page 8 of 11
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defendants had violated, inter alia, 52 U.S.C. § 30114(b) based on the factual and legal analysis 

set forth in the Office of General Counsel’s brief.

30. After reviewing the information available, on October 1, 2015, the Commission 

voted 6-0 to find probable cause to believe that Lynch for Congress and Mr. Lynch, personally 

and in his official capacity as treasurer violated, inter alia, 52 U.S.C. § 30114(b). The 

Commission further authorized the Office of General Counsel to attempt to correct the 

defendants’ violations through informal methods of conference, conciliation, and persuasion.

31. The Commission notified the defendants on or about October 14, 2015, of the 

Commission’s October 1, 2015 findings, and, for a period of not less than 30 days, endeavored to 

correct the violations through informal methods of conference, conciliation, and persuasion. See 

52 U.S.C. § 30109(a)(4)(A). 

32. Unable to secure acceptable conciliation agreements with defendants, on 

December 10, 2015, the Commission voted 6-0 to authorize filing this civil lawsuit against 

defendants. See 52 U.S.C. § 30109(a)(6).

33. The Commission has satisfied all of the jurisdictional requirements in the Act that 

are prerequisites to filing this action.

FIRST CAUSE OF ACTION

34. Paragraphs 1 through 35, inclusive, are incorporated herein by reference.

35. On or after August 12, 2010, Edward J. Lynch, Sr. converted a total of 

approximately $1,622 of the Lynch Committee’s campaign funds to his personal use, including 

for monthly gym membership dues, a cash withdrawal, various automobile expenses, and retail 

purchases.

Case 9:15-cv-81732-XXXX Document 1 Entered on FLSD Docket 12/18/2015 Page 9 of 11
10 

36. By converting those Lynch Committee campaign funds to his own personal use, 

defendant Edward J. Lynch, Sr. violated 52 U.S.C. § 30114(b).

SECOND CAUSE OF ACTION

37. Paragraphs 1 through 38, inclusive, are incorporated herein by reference.

38. On or after August 12, 2010, the Lynch Committee and Edward J. Lynch, Sr., in 

his official capacity as treasurer for the Lynch Committee, disbursed approximately $1,622 in the 

Lynch Committee’s campaign funds for Mr. Lynch’s personal expenses, including for monthly 

gym membership dues, a cash withdrawal, various automobile expenses, and retail purchases.

39. By disbursing those Lynch Committee campaign funds for Mr. Lynch’s personal 

use, the Lynch Committee and Edward J. Lynch, Sr., in his official capacity as treasurer for the 

Lynch Committee, violated 52 U.S.C. § 30114(b).

PRAYER FOR RELIEF 

WHEREFORE, plaintiff Federal Election Commission prays that this Court: 

A. Declare that the Lynch Committee and Edward J. Lynch, Sr., personally and in 

his official capacity as treasurer of the Lynch Committee, violated 52 U.S.C. § 30114(b) by 

converting approximately $1,622 in the Lynch Committee’s campaign funds to the personal use 

of Mr. Lynch on or after August 12, 2010; 

B. Assess a $7,500 civil penalty against Edward Lynch, Sr. in his personal capacity 

and a $7,500 civil penalty against the Lynch Committee and Mr. Lynch in his official capacity as 

treasurer. 52 U.S.C. § 30109(a)(6)(B); 11 C.F.R. § 111.24(a)(1). 

C. Order defendant Edward J. Lynch, Sr. to disgorge the $1,622 in the Lynch 

Committee’s campaign funds that he converted for his personal use on or after August 12, 2010; 

D. Permanently enjoin the Lynch Committee and Edward J. Lynch, Sr., personally 

and in his official capacity as treasurer of the Lynch Committee, from converting campaign 

Case 9:15-cv-81732-XXXX Document 1 Entered on FLSD Docket 12/18/2015 Page 10 of 11
11 

funds to the personal use of Mr. Lynch; Award plaintiff Federal Election Commission its costs in 

this action; and 

E. Grant plaintiff Federal Election any other relief to which the Commission may be 

entitled. 

Respectfully submitted, 

Daniel A. Petalas 

Acting General Counsel 

dpetalas@fec.gov 

Lisa J. Stevenson 

Deputy General Counsel 

lstevenson@fec.gov 

Kevin Deeley 

Acting Associate General Counsel 

kdeeley@fec.gov 

 

December 18, 2015 

s/ Benjamin A. Streeter III

Benjamin A. Streeter III 

Attorney 

bstreeter@fec.gov 

Erin Chlopak 

Acting Assistant General Counsel 

echlopak@fec.gov 

COUNSEL FOR DEFENDANT 

FEDERAL ELECTION COMMISSION 

999 E Street, NW 

Washington, DC 20463 

202/694-1650 

202/219-0260 

Case 9:15-cv-81732-XXXX Document 1 Entered on FLSD Docket 12/18/2015 Page 11 of 11
JS44 (Rev. 11/15) CIVIL COVER SHEET 

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provtded by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the 

purpose of initiat1.ng the civil docket sheet. (SEE INSTRUC7JONS ON NEXT PAGE OF THIS FORM.) 

I. (a) PLAINTIFFS 

Federal Elect1on Commission, 

(b) County of Residence of First Listed Plaintiff 

(EXCEPT IN US. PLAINTIFF CASES) 

(C) Attorneys (Firm Name, Address, and Telephone Number) 

See attachment 

DEFENDANTS 

Edward J. Lynch, Sr.; Lynch for Congress; Edward J. Lynch, Sr., in his 

official capacity as Treasurer of Lynch for Congress 

County of Residence of First Listed Defendant _P..::a.c.lm'--_B..::e..::a...:cc_h _____ _ 

(IN U.S. PLAIN71FF CASES ONLY) 

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED. 

Attorneys (!{Known) 

II. BASIS OF JURISDICTION (Place an "X" in one Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" in One Box for Plaintiff 

~ I U.S. Government 

Plaintiff 

0 2 U.S. Government 

Defendant 

0 3 Federal Question 

(1/.S. Government Not a Party) 

0 4 Diversity 

(Indicate Citizemhip <ifParlles in Item Iff) 

(For Diversity Cases Only) 

PTF 

Citizen of This State 0 I 

Citizen of Another State 0 2 

Citizen or Subject of a 0 3 

and One Box for Defendant) 

DEF PTF DEF 

0 I Incorporated or Principal Place 0 4 0 4 

of Business In This State 

0 2 Incorporated and Principal Place 

of Business In Another State 

0 3 Foreign Nation 

0 5 0 5 

0 6 0 6 

IV NATURE OF SUIT (PI ace an X" in 0 ne Box 0 nty) I 

'< CONTRACT -"·•-"''' :·:· ·-:<.:. TORTS ·FORFEITURE/PENALTY ·· • · BANKRUPTCY OTlfER STATUTES 

0 II 0 Insurance PERSONAL INJURY PERSONAL INJURY 0 625 Drug Related Seizure 0 422 Appeal 28 USC 158 0 375 False Claims Act 

0 120 Marine 0 31 0 Airplane 0 365 Personal Injury • of Property 21 USC 881 0 423 Withdrawal 0 376 Qui Tarn (31 USC 

0 130 Miller Act 0 315 Airplane Product Product Liability 0 690 Other 28 usc 157 3729(a)) 

0 140 Negotiable Instrument Liability 0 367 Health Care/ 0 400 State Reapportionment 

0 150 Recovery of Overpayment 0 320 Assaul~ Libel & Pharmaceutical PR PERTYRI• urs 0 410 Antitrust 

& Enforcement of Judgment Slander Personal Injury 0 820 Copyrights 0 430 Banks and Banking 

0 151 Medicare Act 0 330 Federal Employers' Product Liability 0 830 Patent 0 450 Commerce 

0 152 Recovery ot' Defaulted Liability 0 368 Asbestos Personal 0 840 Trademark 0 460 Deportation 

Student Loans 0 340 Marine Injury Product 0 470 Racketeer Influenced and 

(Excludes \ eterans) 0 345 Marine Product Liability . AROR SOC'T . Corrupt Organizations 

0 153 Recovel)· of Overpayment Liability PERSONAL PROPERTY 0 710 Fair Labor Standards 0 861 HIA (I 395ft) 0 480 Consumer Credit 

of Veteran'~ Benefits 0 350 Motor Vehicle 0 370 Other Fraud Act 0 862 Black Lung (923) 0 490 Cable/Sat TV 

0 160 Stockholders' Suits 0 355 Motor Vehicle 0 371 Truth in Lending 0 720 Labor/Management 0 863 DIWC/DIWW (405(g)) 0 850 Securities/Commodities/ 

0 190 Other Cont:act Product Liability 0 380 Other Personal Relations 0 864 SSID Title XVI Exchange 

0 195 Contract Pnduct Liability 0 360 Other Personal Property Damage 0 740 Railway Labor Act 0 865 RSI (405(g)) 011: 890 Other Statutory Actions 

0 196 Franchise Injury 0 385 Property Damage 0 751 Family and Medical 0 891 Agricultural Acts 

0 362 Personal Injury· Product Liability Leave Act 0 893 Environmental Matters 

Medical Malpractice 0 790 Other Labor Litigation 0 895 Freedom of Information 

REAL PROPERTY •"' CIVIL RIGHTS PRISONER PETITIONS 0 791 Employee Retirement "FEDERAL TAX SUITS ... Act 

0 210 Land Condemnation 0 440 Other Civil Rights Habeas Corpus: Income Security Act 0 870 Taxes (U.S. Plaintiff 0 896 Arbitration 

0 220 Foreclosure 0 441 Voting 0 463 Alien Detainee or Defendant) 0 899 Administrative Procedure 

0 230 Rent Lease & Ejectment 0 442 Employment 0 510 Motions to Vacate 0 871 IRS-Third Party Act/Review or Appeal of 

0 240 Torts to Land 0 443 Housing! Sentence 26 usc 7609 Agency Decision 

0 245 Tort Product Liability Accommodations 0 530 General 0 950 Constitutionality of 

0 290 All Other Real Property 0 445 Alner. w!Disabilities- 0 535 Death Penalty IMMIGRATION State Statutes 

Employment Other: 0 462 Naturalization Application 

0 446 Amer. w/Disabilities · 0 540 Mandamus & Other 0 465 Other Immigration 

Other 0 550 Civil Rights Actions 

0 448 Education 0 555 Prison Condition 

0 560 Civil DetaineeConditions of 

Confinement 

V. ORIGIN (Place an "X" in One Box Only) 

~ I Original 0 2 Removed from 

Proceeding State Court 

0 3 Remanded from 

Appellate Court 

0 4 Reinstated or Reopened 0 5 Transferred from 

Another District 

(>pecijy) 

0 6 Multidistrict 

Litigation 

Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversitv): 

52 u.s.c. 30114(b) . 

VI. CAUSE OF ACTION 1-B-r-ie..,..fd-:-e-sc-r.,...ip""'ti-on-of,....c...:au-s:....e_: -----------------------------------

Civil enforcement action for converting federal campaign contributions to personal usage. 

VII. REQUESTED IN 

COMPLAINT: 

0 CHECK IF THIS IS A CLASS ACTION DEMAND$ CHECK YES only if demanded in complaint: 

VIII. RELATED CASE(S) 

IF ANY 

DATE 

12/18/2015 

FOR OFFICE l"SE ONLY 

RECEIPT# AMOUNT 

UNDER RULE 23, F.R.Cv.P. JURY DEMAND: 0 Yes ~No 

(See imtructions): 

JUDGE 

SIGNATURE OF ATTORNEY OF RECORD 

s/ Benjamin A. Streeter Ill 

APPLYING IFP 

DOCKET NUMBER 

JUDGE MAG. JUDGE 

Case 9:15-cv-81732-XXXX Document 1-1 Entered on FLSD Docket 12/18/2015 Page 1 of 2
Daniel A. Petalas 

Acting General Counsel 

Lisa J. Stevenson 

Deputy General Counsel 

Kevin Deeley 

Acting Associate General Counsel 

Erin Chlopak 

Acting Assistant General Counsel 

Benjamin A. Streeter III 

Attorney 

COUNSEL FOR DEFENDANT 

FEDERAL ELECTION COMMISSION 

999 E Street, NW 

Washington, DC 20463 

202/694-1650 

Case 9:15-cv-81732-XXXX Document 1-1 Entered on FLSD Docket 12/18/2015 Page 2 of 2