1

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

_________________________________________

)

PURSUING AMERICA’S GREATNESS )

) Civil Case No. 15-1217 (TSC)

)

Plaintiff, )

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v. )

)

FEDERAL ELECTION COMMISSION )

)

Defendant. )

_________________________________________ )

PLAINTIFF’S REPLY TO DEFENDANT’S OPPOSITION TO 

MOTION FOR PRELIMINARY INJUNCTION 

Jason Torchinsky (D.C. Bar No. 976033)

J. Michael Bayes (D.C. Bar No. 501845)

Shawn Sheehy

HOLTZMAN VOGEL JOSEFIAK PLLC

45 North Hill Drive, Suite 100

Warrenton, VA 20186

Phone: (540) 341-8808

Fax: (540) 341-8809

Counsel for Plaintiff Pursuing America’s Greatness

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Pursuant to Federal Rule of Civil Procedure 65 and Local Rules 7(d) and 65.1,

Plaintiff Pursuing America’s Greatness (“Plaintiff” or “PAG”) hereby replies to 

Defendant’s opposition to Plaintiff’s motion for a preliminary injunction seeking 

invalidation and enjoining enforcement of 52 U.S.C. § 30102(e)(4) and 11 C.F.R. §

102.14(a) (the “PAC Naming Prohibition”) as applied to PAG’s use of a certain 

website Uniform Resource Locator (“URL”) and social media accounts that are not 

used for fundraising or solicitation purposes. 

I. Defendant Misconstrues the D.C. Circuit’s Holding In Common Cause v. 

FEC

a. Common Cause Upheld The FEC’s Narrower Interpretation of the 

Statute

Defendant seeks to characterize the nearly 30 year old holding in Common 

Cause v. FEC, 842 F.2d 436 (D.C. Cir. 1988), as foreclosing PAG’s challenge to the 

FEC’s current speech ban that did not exist when Common Cause was decided in 1988. 

D.E. 13, Def.’s Oppn. to Pl.’s Mot. For Prelim. Inj. at 4-6. The D.C. Circuit wrote, in 

dicta, that “Common Cause’s alternative construction” of the relevant statute – which 

of course had not been the subject of APA rulemaking – was “not a totally implausible 

interpretation of the statute’s language.” Common Cause, 842 F.2d at 440-41. The 

D.C. Circuit found “the likelihood remote that Congress set out stealthily to alter so 

dramatically the regulation of campaign advertisements and solicitations in the way 

Common Cause asserts,” but nevertheless determined that the statute was “ambiguous” 

for Chevron purposes. Id. at 444. The D.C. Circuit then deferred to the FEC’s 

judgment and upheld the FEC’s interpretation of the statute. 

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The D.C. Circuit’s Chevron analysis focused on whether the FEC’s 

interpretation was reasonable, not whether Common Cause’s alternative interpretation 

was reasonable. The D.C. Circuit did not subject Common Cause’s proffered alternative 

interpretation to Chevron analysis, or hold that Common Cause’s interpretation was 

reasonable and valid under the Administrative Procedures Act. 

The FEC relied on the Common Cause dictum, and its tepid endorsement of 

what was deemed “not a totally implausible interpretation,” when it revised its 

regulation in 1992 to effectively adopt Common Cause’s proposal. See Final Rule

Special Fundraising Projects and Other Use of Candidate Names by Unauthorized 

Committees, 57 Fed. Reg. 31,424 (July 15, 1992). Even if one concedes for the sake of 

argument that Common Cause supports the FEC’s 1992 rulemaking, no argument can 

be made that Common Cause somehow justifies transforming the 1992 rule into a 

content based speech ban that authorizes the use of a candidate’s name where 

opposition is demonstrated, but not where support is shown.

The FEC contends that the D.C. Circuit’s decision in Common Cause somehow

blesses the FEC’s current interpretation and application of the PAC Naming 

Prohibition to the Internet and social media when no fundraising occurs. Def.’s Oppn. 

to Pl.’s Mot. For Prelim. Inj. at 19-20. This cannot be, as the D.C. Circuit in 1988 did 

not consider the FEC’s 1992 rule directly, or the 1994 rule that transformed the 

statutory provision into a content-based speech regulation, or the application of the 

statute or any version of the FEC’s regulation to the Internet (which the FEC concluded 

in a 2006 rulemaking warranted a different regulatory approach). See Pl.’s Mot. For 

Prelim. Inj. at 13-14. In the course of upholding the FEC’s pre-1992 interpretation of 

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the statute, the D.C. Circuit merely indicated that Common Cause’s preferred reading 

of the statute was “not a totally implausible interpretation.” 

The FEC’s reliance on Common Cause is also misplaced because the Court 

noted that Common Cause’s interpretation stemmed from a generalized statement of 

legislative purpose to reduce confusion among the electorate. This purpose statement,

and Common Causes’ consequent interpretation, neglected the text of the statute and 

the complexities inherent in legislation regulating the First Amendment. See Common 

Cause, 842 F.3d at 445 (“To afford § 432(e) (4) so broad a scope as Common Cause 

and the district court's interpretation would, on the basis of a general statement of intent 

to reduce confusion among the electorate, would unduly elevate the rhetoric of purpose 

above the specifics of text, ignoring in the process the enormous subtleties and 

complexities inherent in the ‘FECA's first-amendment-sensitive regime.’”). 

The FEC overstates the import of Common Cause. The D.C. Circuit’s holding 

was limited, and its decision in 1988 in no way signals approval of the current content

based speech regulation that is challenged here.

II. The PAC Naming Prohibition Is Not An Ordinary Disclosure Provision 

The FEC attempts to characterize the PAC Naming Prohibition as “an integral 

part of FECA’s disclosure regime,” so basic and elementary that the FEC compares it to 

“players on opposing sports teams wear[ing] uniforms with contrasting colors.” (D.E. 

13, Def.’s Oppn. to Pl.’s Mot. For Prelim.Inj. at 24-25). They do so because it is the 

only remotely plausible path to a potentially reasonable justification for this direct ban 

on speech. However, if this were in fact part of a simple disclosure regime, PAG could 

speak freely and simply include an appropriate disclaimer on its communications or 

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make an appropriate filing with the FEC. Disclaimer requirements, of course, “do not 

prevent anyone from speaking.” Citizens United v. FEC, 558 U.S. 310, 366 (2010).

PAG, of course, cannot simply include a disclaimer because the PAC Naming 

Prohibition is not a disclosure provision. Rather, the PAC Naming Prohibition bars 

PAG from speaking in the manner it chooses, on the basis of the content of PAG’s 

speech. See Pl.’s Mot. For Prelim. Inj. at 22-23, 28-31. This serious limitation on

PAG’s constitutional rights is in no way comparable to permitting speech but 

nevertheless requiring a disclaimer on a communication or filing a disclosure report 

with the FEC. See AFL-CIO v. FEC, 333 F.3d 168, 179 (D.C. Cir. 2003) (noting that the 

FEC had a duty to avoid unnecessarily infringing First Amendment rights); Common 

Cause, 842 F.2d at 448 (“[The FEC] must allow the maximum of first amendment 

freedom of expression in political campaigns commensurate with Congress' regulatory 

aims.”).

PAG has, at all times since it acquired control of the website and Facebook 

page, maintained legally required disclaimers on its communications that state (1) that 

PAG paid for the communication, and (2) that the communication is not authorized by 

any candidate or candidate’s committee. These disclaimers also provide PAG’s web 

address so that recipients of the communication may learn more about PAG. The FEC 

maintains that this rather comprehensive source disclaimer is insufficient, and that PAG 

must be further restricted from even using the name “Mike Huckabee” in the title of its 

Facebook page (“I Like Mike Huckabee”), in a website address 

(www.ilikemikehuckabee), or in an associated Twitter handle – so long as PAG 

supports Mike Huckabee. The FEC suggests that “I Like Mike Huckabee” as a 

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“subheading” would be acceptable under the rule, but in the context of URLs and social 

media is both nonsensical and factually impossible. See Def.s’ Oppn. to Pl.’s Mot. For

Prelim. Inj. at 26-27. Twitter, for example, does not permit “subheadings” in its 140 

character messages. The URL PAG holds at www.facebook.com/ilikemikehuckabee is 

about as close to a “subheading” as is feasible on Facebook’s system, but appears 

otherwise prohibited under the FEC’s speech ban. Additionally, it appears from the 

FEC’s position that a URL located on PAG’s server at 

www.pagpac.com/ilikemikehuckabee is similarly impermissible - or a “redirect” from 

ilikemikehuckabee.com to this web address would also not be a permissible 

“subheading” exempt from the ban. The FEC’s focus and reasoning is not on what is 

typically thought of as “disclosure.” The FEC’s focus is on enforcing its speech ban 

because PAG’s speech satisfies certain content criteria. The notion that a government 

agency would suggest that a phrase used in a subheading is permissible, but not in the 

title of a document, is a classic (and absurd) example of government regulation of the 

content of speech.

The FEC’s reliance on Citizens United v. FEC, McCutcheon v. FEC, Buckley v. 

Valeo, and SpeechNow.org v. FEC with respect to the value of disclosure is misplaced. 

See Def.’s Oppn. to Pl.s’ Mot. For Prelim. Inj. at 25. The mandated disclosure 

discussed in these cases consisted of donor disclosure and disclaimers. None of the 

decisions cited by the FEC as being generally supportive of disclosure made any 

mention of the PAC Naming Prohibition, and none of these provisions are a ban on 

speech in any way comparable to what the FEC attempts to defend here. 

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III. Defendant Misinterprets Plaintiff’s Objection to the Name Identification Ban

The FEC challenges PAG’s standing, arguing that even if this court were to 

invalidate 11 C.F.R. §102.14(b)(3), PAG’s injury would not be redressed. (D.E. 13, 

Def.’s Oppn. to Pl.’s Mot. For Prelim. Inj. at 32). The FEC misstates PAG’s argument. 

To clarify, PAG is challenging the PAC Naming Prohibition at 11 C.F.R. §102.14(a), and 

PAG seeks the invalidation of subsection (a) as it applies to PAG. PAG’s injury would 

be redressed if this court invalidates the application of 11 C.F.R. § 102.14(a) to PAG. 

PAG’s position is that subsection (b)(3)’s exemption for names that show opposition to 

candidates acts together with subsection (a), as a unified whole, to create a content-based 

speech regulation that violates PAG’s constitutional rights. 

The FEC asserts that subsection (b)(3) is severable. Def.’s Oppn. to Pl.’s Mot. For

Prelm. Inj. at 32-33 n.7. That section is not severable from the general naming 

prohibition at 11 C.F.R § 102.14(a). First, the requisite intent to have severability is not 

present. See MD/DC/DE Broadcasters Ass'n v. FCC, 236 F.3d 13, 22 (D.C. Cir. 2001)

(“Whether the offending portion of a regulation is severable depends upon the intent of 

the agency and upon whether the remainder of the regulation could function sensibly 

without the stricken provision.”). The FEC’s 1994 rulemaking expressly acknowledged 

that the 1992 version of the regulation was overbroad and applied to situations in which 

the government’s purported interests were not advanced – namely, where an unauthorized 

political committee uses the name of a candidate in project titles that demonstrate 

opposition to that candidate. See 1994 Final Rule, 59 Fed. Reg. 17,267, 17,269 (April 12, 

1994) (”As stated in its summary of the petition ..., ‘There is no danger of confusion or 

abuse inherent in the use of a candidate’s name by a committee or project which opposes 

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the candidate.’ The Commission recognizes that the potential for fraud and abuse is 

significantly reduced in the case of such titles, and has accordingly revised its rules to 

permit them.”). See Pl.s’ Mot. For Prelim. Inj. at 7. 

Second, the regulation cannot function without the stricken provision. The current 

version of the regulation operates as a coherent whole because the exemption at 

subsection (b)(3) serves to better tailor the regulation to the government’s claimed 

interests. Because of this and based on the current administrative record, subsection 

(b)(3) cannot be regarded as severable. See MD/DC/DE Broadcasters Ass'n, 236 F.3d at 

22. 

IV. The FEC’s Claimed Government Interests Are Not Present In This Matter

The FEC contends that the governmental interests served by the PAC Naming 

Prohibition include limiting fraud, abuse, and confusion. Plaintiff’s prior submission 

argues in great detail that the FEC’s 1992 and 1994 rulemakings focus almost 

exclusively on the issue of fraudulent fundraising practices, and both iterations of the 

PAC Naming Prohibition are justified in those terms. PAG does not contend that 

preventing financial fraud and abuse is not a valid government interest. However, PAG 

does not seek to use its Facebook page, website, or associated Twitter account to 

engage in any fundraising. See Verified Compl. ¶ 12. Accordingly, an interest in 

preventing fraudulent fundraising cannot justify the FEC’s prohibition on PAG’s 

described activities.

As the FEC notes, the 1992 and 1994 rulemakings also assert that avoiding

“confusion” was one of the government’s interests that justified expanding the scope of 

the PAC naming regulation. Neither rulemaking, however, provided any concrete 

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example of confusion outside the fundraising context, and the underlying enforcement 

matter that resulting in the Common Cause litigation involved a fundraising matter. 

The FEC simply asserts its interest in combatting non-fundraising-related “confusion,” 

and claims that this interest is related to its mandate to “protect[] the integrity of the 

electoral process.” Def.s’ Oppn. to Pl.’s Mot. For Prelim. Inj. at 21. The FEC never 

explains what these terms mean, how they apply in a non-fundraising context, or how 

content-based speech regulation could possibly “protect the integrity of the electoral 

process.” Instead, the FEC simply refers to the “commonsense anti-confusion 

rationale.” Id. at 23. 

Prohibitions on PAG’s speech must be justified by more than this. Recently, 

the Supreme Court explained that the government has an interest in limiting false 

speech only in limited circumstances where false statements are made for material gain 

or for purposes of perpetuating criminal conduct. United States v. Alvarez, 132 S. Ct. 

2537, 2544 (2012) (government may proscribe the following forms of speech: speech 

that incites imminent unlawful action; obscenity; defamation; speech integral to criminal 

conduct; fighting words; child pornography; fraud; and speech “presenting some grave 

and imminent threat the government has the power to prevent”). The Supreme Court 

made clear, however, that the prevention of false statements alone is insufficient to 

proscribe speech. See id. at 2545. Rather, statutes that criminalize perjury or criminalize 

making false statements to a law enforcement officer are permissible because such 

statements inhibit the truth-seeking function of law enforcement investigations and court 

proceedings. See id. at 2546. False statement statutes do not grant the government 

general authority to regulate what can and cannot be said in the vigorous exchange of 

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ideas in the public square. See id. at 2544-45. 

The Supreme Judicial Court of Massachusetts recently invalidated a state statute 

that “criminalize[d] certain false statements about political candidates or questions 

submitted to voters.” Commonwealth of Massachusetts v. Lucas, 472 Mass. 387, 388 

(2015). The court explained:

The Commonwealth contends that fraudulent speech may nonetheless be 

unprotected absent a showing of concrete harm where the speech threatens 

“the integrity of Government processes.” United States v. Alvarez, 132 S. 

Ct. 2537, 2546, 183 L. Ed. 2d 574 (2012). However, the Commonwealth 

has not established that the range of speech proscribed by § 42 poses an 

actual and substantial threat to the electoral process. See 281 Care

Comm. v. Arneson, 766 F.3d 774, 790 (8th Cir. 2014), cert. denied, 135 S. 

Ct. 1550, 191 L. Ed. 2d 637 (2015) (“reliance upon ‘common sense’ to 

establish that the use of false statements impacts voters' understanding, 

influences votes and ultimately changes elections, is not enough on these 

facts to establish a direct causal link between [the statute] and an interest 

in preserving fair and honest elections”).

Lucas, 472 Mass. at 394 n.8.

As in Lucas, the FEC has never established, except by claiming it to be a matter 

of “common sense,” that speech such as PAG’s poses any actual threat to the integrity 

of the electoral process. In another recent matter, a federal court recognized that

although false statements in campaigns may have serious adverse consequences to the 

public at large, the interest in preventing false speech is only a legitimate interest, not a 

compelling interest. Susan B. Anthony List v. Ohio Elections Comm’n, 45 F. Supp. 3d 

765, (S.D. Ohio 2014) citing McIntyre v. Ohio Elections Comm’n, 514 US 334, 349-

351 (1995). The court struck down Ohio’s law prohibiting false statements about 

electoral candidates. If restrictions on false speech must be so carefully scrutinized and

justified, then surely the FEC’s speech prohibition must be justified by more than mere 

resort to claims of unspecified “confusion.”

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In the end, what the FEC is attempting to do violates the Supreme Court’s 

admonitions in Citizens United. The FEC’s interpretation of its rules would prohibit 

PAG from publishing a book entitled “I Like Mike Huckabee”, although the FEC seems 

to graciously concede that perhaps PAG could use “I Like Mike Huckabee” as a 

subheading to its title. Def.’s Oppn. to Pl.’s Mot. For Prelim. Inj. at 26-27. This violates 

the Supreme Court’s admonition that the FEC cannot save the constitutionality of a 

statute by “[c]arving out a limited exemption through an amorphous regulatory 

interpretation.” Citizens United v FEC, 558 U.S. 310, 324 (2010); see also id. at 334 

(discussing the uncertainty caused by the FEC’s litigating position that perhaps it may 

permit the challenger’s activity on narrower grounds but does not adopt the position in 

its litigation). It is—to say the least—confusing where the government says that to 

prevent fraud you cannot incorporate a candidate’s name into the name of a website, 

although you may do so in a subheading. 

The FEC claims that the messages disseminated by PAG, and committees like

PAG, implicate the government’s anti-confusion interest even where those messages

merely present information and do not request money. PAG has not be able to find any 

instances in which FEC previously asserted an interest in generally preventing 

confusion among voters (or the general public) with regard to its campaign finance

regulations.

1 Even if there were an instance where the FEC has sought to advance this 

interest as it pertains to campaign finance, the FEC’s only evidence of possible voter 

																																																												 1 The U.S. Supreme Court did note that disclaimers prevent the very confusion the FEC 

claims as its justification for prohibiting certain speech. See Citizens United v. FEC, 558 

U.S. 310, 368 (2010) (“At the very least, the disclaimers avoid confusion by making clear 

that the ads are not funded by a candidate or political party.”). The precise kinds of 

disclaimers mentioned here are present in all of PAG’s communications on these 

websites.

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confusion are some comments posted on the Plaintiff’s Facebook page, many of which 

were posted prior to the Plaintiff taking control of the Facebook page. Additionally, 

the FEC’s review of Facebook page comments made by a few hundred Facebook users 

fails to put the number or content of these comments in any context.

The FEC has no role in monitoring or evaluating the truthfulness or clarity of the 

messages disseminated by political committees. See, e.g., Riley v. Nat'l Fed'n of Blind, 

487 U.S. 781, 790-791 (1988) (the government may not substitute its judgment for that of 

speakers and listeners); Tashjian v. Republican Party of Connecticut, 479 U.S. 208, 224 

(1987) (criticizing State’s claimed interest in protecting the Republican Party on the 

ground that it viewed a particular expression as unwise or irrational); First National Bank 

of Boston v. Bellotti, 435 U.S. 765, 791-792, n. 31 (1978) (criticizing the government’s 

paternalistic interest to protect the political process by restricting speech); Linmark 

Associates, Inc. v. Willingboro, 431 U.S. 85, 97 (1977) (criticizing the government’s 

paternalistic interest in maintaining the quality of neighborhoods by restricting speech). 

The FEC may require disclaimers be placed on specified communications, and 

FECA includes specific provisions directed to fraudulent fundraising (52 U.S.C. § 

30124). The FEC’s role and responsibility is to regulate campaign finance; the scope 

of the FEC’s authority does not extend to evaluating and approving messages 

disseminated by such committees on the grounds that these messages might perhaps 

confuse someone. The FEC’s paternalistic claim that “permitting PAG to imply that its 

speech is Mr. Huckabee’s by using the candidate’s name in the title to PAG’s message 

would disserve the public” amply demonstrates that the FEC has veered far off course 

from its role as a campaign finance regulator. It is not the FEC’s role to determine 

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what speech should be “permitted” nor is it the FEC’s role to determine what speech 

serves or disserves the public.

V. Defendant Misconstrues Reed v. Town of Gilbert

The FEC contends that the PAC Naming Prohibition is content-neutral because it 

is “justified without reference to the content of the regulated speech,” and that as a result, 

the Supreme Court’s recent decision in Reed v. Town of Gilbert has no bearing on the 

present matter. See Def.’s Oppn. to Pl.’s Mot. For Prelim. Inj. at 36. The FEC cites 

Republican National Committee v. FEC, 76 F.3d 400 (D.C. Cir. 1996) and Ward v. Rock 

Against Racism, 491 U.S. 781 (1989). Both of these decisions involved regulations that 

were content-neutral on their face, and the courts’ inquiries were directed to whether they 

should be treated as content-based on account of the motivations behind their adoptions. 

The PAC Naming Prohibition, on the other hand, is very plainly content-based on its 

face.

The Reed Court explained that “[g]overnment regulation of speech is content 

based if a law applies to particular speech because of the topic discussed or the idea or 

message expressed. . . . This commonsense meaning of the phrase ‘content based’ 

requires a court to consider whether a regulation of speech ‘on its face’ draws distinctions 

based on the message a speaker conveys.” Reed v. Town of Gilbert, 135 S. Ct. 2218, 

2227 (2015) (emphasis added). The PAC Naming Prohibition, on its face,

unquestionably meets this standard. See Pl.’s Mot. For Prelim. Inj. at 28-31. It is not a 

Ward-style regulation that is content-neutral on its face but adopted for content-based 

reasons.

Under Reed, the court must first “consider whether a regulation of speech ‘on its 

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face’ draws distinctions based on the message a speaker conveys.” A regulation that 

draws such distinctions “on its face” cannot be treated as content-neutral, regardless of its 

justifications. The Fourth Circuit Court of Appeals recently recognized that the Reed

“formulation conflicts with, and therefore abrogates ... previous descriptions of content 

neutrality.” Cahaly v. Larosa, Nos. 14-1651 & 14-1680, 2015 U.S. App. LEXIS 13736, 

*9 (4th Cir. Aug. 6, 2015). To the extent that prior cases may have treated regulations 

that, on their face, distinguish between content as content-neutral because of their 

underlying justifications, that approach is on longer the law. See id. (“Our earlier cases 

held that, when conducting the content-neutrality inquiry, ‘[t]he government's purpose is 

the controlling consideration.’ Clatterbuck v. City of Charlottesville, 708 F.3d 549, 555 

(4th Cir. 2013) (quoting Ward, 491 U.S. at 791). But Reed has made clear that, at the first 

step, the government's justification or purpose in enacting the law is irrelevant.”). 

The FEC’s contention that Reed does not apply here is incorrect; it is the FEC’s 

approach that no longer applies.

VI. The FEC’s Regulation Acts As A Prior Restraint

The FEC contends that its regulation does not act as a prior restraint. Def.’s Oppn. 

to Pl.’s Mot. For Prelim. Inj. at 29-31. The FEC is wrong. 

The FEC’s PAC Name Prohibition does act as a prior restraint. The FEC itself 

describes its own regulation as a ban on an unauthorized political committee using the 

name of a candidate in its PAC name, its URL, special projects, etc. See 1994 Final Rule, 

59 Fed. Reg. at 17,268; see also Advisory Opinion 2015-04 (Collective Actions PAC) at 

3 (D.E. 1-2) (“The Commission therefore determined that a “total ban” on the use of 

candidate names in committee names was more “responsive to the problem,” as well as 

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easier to monitor and enforce.”). It explicitly forbids speech prior to that speech 

occurring, and if someone does speak that person is subject to prison for knowing and 

willful violations the FECA. Recognizing the FEC’s regulation— and the FEC’s 

application of the regulation to Collective Action PAC— as a prior restraint maintains 

the “[t]ime-honored distinction between barring speech in the future and penalizing past 

speech.” Alexander v. United States, 509 U.S. 544, 553 (1993). As Alexander

demonstrates, the RICO order at issue there did not forbid speech or require prior 

approval before speaking. Id. at 551. As in Alexander, the FEC’s regulation is in fact 

closer to those obscenity cases where the government restrained certain materials as 

obscene without a judge determining that the materials were obscene. Id. at 551. The 

FEC is restraining PAG’s speech prohibiting, under any circumstances, it from having the 

phrase “I like Mike Huckabee” in PAG’s URL. That is a classic example of a prior 

restraint of speech. See Pl.’s Mot. For Prelim. Inj. at 23-28. 

Respectfully Submitted,

/s/ Jason Torchinsky

Jason Torchinsky (D.C. Bar No. 976033)

J. Michael Bayes (D.C. Bar No. 501845)

Shawn Sheehy

HOLTZMAN VOGEL JOSEFIAK PLLC

45 North Hill Drive, Suite 100

Warrenton, VA 20186

Phone: (540) 341-8808

Fax: (540) 341-8809

Counsel for Plaintiff Pursuing America’s Greatness

August 17, 2015

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