Case 2:08-cv-14125-DML-DAS Document 1-2 Filed 09/25/2008 Page 2 of 2

FIEGER, FIEGER, KENNEY, JOHNSON & GIRoux

Federal Election Commission
July 3, 2008
Page Two

1 look forward to your prompt response consistent with the requirements of the Freedom of
Information Act. Please do not hesitate to contact me with any questions. Thank you for your kind
attention to this matter.

Very truly yours,

FIEGER, FIEGER, KENNEY, JOHNSON
& GIROUX, PC

LEZ
Michael R. Dezsi

MRD/jn


Case 2:08-cv-14125-DML-DAS Document 1-2 Filed 09/25/2008 Page 1 of 2
FIEGER, FIEGER, Kenney, JOHNSON & GIROUX

A PROFESSIONAL CORPORATION

ATTORNEYS AND COUNSELORS AT LAW
19390 WEST TEN MiLE Roap
SoursFieLp, MICHIGAN 48075-2463
TBLEPHONE (248) 355-5555
Fax (248) 355-5148

Micuaz. R. Drzsi : WEBSITE: www.fiegerlaw.com DrrReEct DIAL (248) 355-3911
E-Max11: info@fiegerlaw.com E-Mat: m.dezsi@ fiegerlaw.com
July 3, 2008

CERTIFIED MAIL

Federal Election Commission
Attn: Candace J. Salley
Room 408

999 E. Street, N.W.
Washington, D.C. 20463

Re: FOIA Request
Dear Ms. Salley:
Pursuant to the Freedom of Information Act, I am hereby requesting the following:

L Any and all documents of any kind, including, but not limited to, memoranda,
correspondence and e-mails dated from January 2001 through the present between
officials, agents and/or employees of the FEC and officials, agents and/or employees
of the Department of Justice relating to possible violations of the Federal Election
Campaign Act by the law firm of Fieger, Fieger, Kenney & Johnson, P.C., including
its partners, employees, contractors, associates, and their children and spouses.

2. Any and all documents of any kind, including, but not limited to, memoranda,
correspondence and e-mails dated from January 2001 through the present between
(to/from) FEC officials, employees or agents, including former FEC Chairman
Michael E. Toner, and White House officials, employees or agents, including former
White House Aide Karl Rove and former White House Counsel! Harriet Miers, or
their agents and/or assistants, relating in any way to enforcement of federal criminal
statutes, including, but not limited to, the Federal Election Campaign Act.


Case 2:08-cv-14125-DML-DAS Document1 Filed 09/25/2008 Page 1 of 3

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

GEOFFREY NELS FIEGER
Plaintiff, CIVIL ACTION NO.

vs.
DISTRICT JUDGE

FEDERAL ELECTION COMMISSION,

Defendant.
/

MICHAEL R. DEZSI (P64530)
Counsel for Plaintiff
FIEGER, FIEGER, KENNEY, JOHNSON & GIROUX, P.C.,
19390 W. Ten Mile Rd.
Southfield, Ml 48075
(248) 355-5555
m.dezsi@fiegerlaw.com

/

COMPLAINT FOR INJUNCTIVE RELIEF

NOW COMES Plaintiff, Geoffrey N. Fieger, by and through counsel, and brings
this Complaint against the Federal Election Commission to order the production of
agency records which Defendant Federal Election Commission has failed to provide
pursuant to the Freedom of Information Act, 5 U.S.C. § 552. Plaintiff further states the
following:

1. Plaintiff, Geoffrey N. Fieger, is a duly licensed attorney who resides within
the geographical boundaries of the Eastern District of Michigan.

2. On multiple occasions, Mr. Fieger has accused the Bush Justice
Department of conspiring with the Federal Election Commission to politicize the

enforcement of federal campaign finance laws.



Case 2:08-cv-14125-DML-DAS Document1 Filed 09/25/2008 Page 2of3

3. During the relevant times in question, the Federal Election Commission
was headed by Chairman Michael E. Toner who was appointed by President George
W. Bush. Prior to his appointment by President Bush, Toner served as Chief Counsel
to the Republican National Committee, and prior to that Mr. Toner served as General
Counsel of the Bush-Cheney Transition Team and General Counsel of the Bush-
Cheney 2000 Presidential Campaign.

4. Pursuant to the Freedom of Information Act, Plaintiff Fieger requested, by
letter dated July 3, 2008, documents, memoranda, correspondences, and e-mails
relating to the enforcement of federal campaign finance laws sent between White
House officials and Federal Election Commission employees including Chairman Toner
(See Exhibit A).

5. The documents sought by Plaintiff are in the possession of the Federal
Election Commission, an agency of the United States and are subject to the provisions
of the Freedom of Information Act.

6. To date, Defendant Federal Election Commission has failed to provide
such documents in violation of federal law.

7. Plaintiff Fieger has a right of access to the requested information under 5
U.S.C. § 552, and there is no legal basis for Defendant's failure to comply with federal
law.

RELIEF REQUESTED
WHEREFORE, Plaintiff requests this Court:
(1) Order Defendant to provide access to the requested documents;

(2) Expedite this proceeding as provided for in 28 U.S.C. § 1657;


Case 2:08-cv-14125-DML-DAS Document1 Filed 09/25/2008 Page 3of3

(3) Award Plaintiff costs and reasonable attorney fees in this action, as provided

in 5 U.S.C. § 552(a)(4)(E); and

(4) Grant such other and further relief as it may deem just and proper.
Respectfully submitted,

FIEGER, FIEGER, KENNEY, JOHNSON & GIROUX, P.C.

\s\ Michael R. Dezsi
MICHAEL R. DEZSI (P64530)
Attorney for Plaintiffs

19390 W. Ten Mile Road
Southfield, Michigan 48075
(248) 355-5555
m.dezsi@fiegerlaw.com

Dated: September 25, 2008