UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

_________________________________________

RALPH NADER, 

 PLAINTIFF, 

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 V. 

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Civ. No. 10-989 (HHK) 

FEDERAL ELECTION COMMISSION, 

 DEFENDANT. 

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ANSWER 

DEFENDANT FEDERAL ELECTION COMMISSION’S ANSWER 

 Defendant Federal Election Commission (FEC or Commission) submits this answer to 

the Complaint of plaintiff Ralph Nader. Any allegation not specifically responded to below is 

DENIED. 

1. DENY that the Commission’s disposition of plaintiff’s administrative complaint was 

“wrongful.” The Commission is without knowledge or information sufficient to admit or 

deny the remaining factual allegations in this paragraph. 

2. DENY that the Commission acted in “clear violation of the Federal Campaign Act of 

1971 and its own regulations.” ADMIT that the Commission did not treat all of the over 100 

individuals and entities referenced in the administrative complaint as respondents required to 

respond to the complaint. ADMIT that the Commission did not send the administrative 

complaint, which was improperly filed with a faulty signature, to some respondents until a 

few months after it was filed due to administrative oversight, but that those respondents were 

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sent the administrative complaint prior to the time when the signature defect was corrected.1

 

DENY that the Commission “relied on its own failure and delay as grounds for dismissal.” 

DENY that any of the Commission’s determinations were “wrongful” or “contrary to law” 

and that “reversal is necessary.” 

3. DENY that “[r]eversal is also necessary” and that the FEC’s conclusions were 

“arbitrary and capricious and an abuse of discretion.” ADMIT that the First General 

Counsel’s Report described Count 1 of the administrative complaint as “based on a viable 

theory” but the Report also concluded that “the available facts do not support the 

allegations.” The Commission is without knowledge or information sufficient to admit or 

deny the factual allegations in the third sentence of this paragraph. ADMIT that the 

Commission chose to dismiss this matter and/or find no reason to believe violations occurred 

rather than open an investigation. DENY the factual allegations in the remainder of the 

paragraph. The last sentence of the paragraph contains legal conclusions to which no 

response is required. 

4. ADMIT that the administrative complaint contains the allegations in the first sentence 

of this paragraph. The Commission is without knowledge or information sufficient to admit 

or deny the remaining factual allegations in this paragraph. 

5. DENY that the Commission’s disposition of plaintiff’s administrative complaint was 

“wrongful.” DENY that the FEC was “presented with clear evidence that Respondents 

committed numerous violations of the Act, including knowing and willful violations, and that 

certain Respondents may have criminally interfered with Plaintiff’s 2004 presidential 

campaign.” ADMIT that the Commission found no reason to believe that some of the 

                                                           

1

 The Commission objects to Mr. Hall’s affidavit as improperly filed outside the 

administrative record. 

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conduct alleged in the administrative complaint violated the law and exercised its 

prosecutorial discretion to dismiss the administrative complaint with respect to the remaining 

allegations. ADMIT that the Commission did not refer this matter to the Justice Department. 

DENY that the FEC “deprived Plaintiff of the protection of federal law.” DENY that the 

Commission’s dismissal of the administrative complaint threatens plaintiff with imminent 

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

remaining factual allegations in this paragraph and is not required to respond to the 

conclusions of law in the paragraph. 

6. ADMIT the allegations in the first and second sentences of this paragraph. The 

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

allegations in the third sentence of this paragraph. 

7. ADMIT. 

8. DENY the first sentence to the extent it asserts that the Declaratory Judgment Act is 

an independent source of federal jurisdiction. ADMIT that the referenced statutes provide 

statutory standing. 

9. ADMIT, upon information and belief, that at least some of the individuals and 

organizations identified in the administrative complaint as “Respondents” are or were 

affiliated with the Democratic Party and that at least some of them challenged Nader-Camejo 

nomination papers in the 2004 presidential election in certain states. The Commission is 

without knowledge or information sufficient to admit or deny the remaining factual 

allegations in this paragraph. 

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

factual allegations in this paragraph. 

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11. ADMIT that the 2004 Democratic National Convention began on July 26, 2004, and 

was held at Boston’s Fleet Center. The Commission is without knowledge or information 

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

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

factual allegations in this paragraph. 

13. ADMIT that the administrative complaint contains allegations regarding a national 

campaign by the DNC and Kerry-Edwards campaign. The Commission is without 

knowledge or information sufficient to admit or deny any of the remaining factual allegations 

in this paragraph. The last sentence of the paragraph contains legal conclusions to which no 

response is required. 

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

factual allegations in this paragraph. 

15. ADMIT that the first two sentences of this paragraph and the block quote accurately 

quote from the Act and from FEC Advisory Opinion 1980-57, respectively. The 

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

factual allegations in this paragraph and is required to respond to neither the legal 

conclusions nor the characterizations of past Advisory Opinions therein. 

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

factual allegations in this paragraph. The paragraph also contains conclusions of law to 

which no response is required. 

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

factual allegations in the first sentence of this paragraph. ADMIT that the Washington Post

article cited in the administrative complaint states that “[Toby] Moffett says [The Ballot 

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Project] ... is relying on pro bono work from lawyers across the country who have 

contributed up to $2 million worth of labor.” The Commission is without knowledge or 

information sufficient to admit or deny the factual allegations in the last two sentences of this 

paragraph and is not required to respond to the legal conclusions therein. 

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

factual allegations in first sentence of this paragraph. ADMIT that the block quotes 

accurately quote both the New York Times article and Associate Press articles identified. The 

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

factual allegations in this paragraph. 

19. ADMIT that copies of emails with text similar to what is described in the second and 

fourth sentences were attached to the administrative complaint. The Commission is without 

knowledge or information sufficient to admit or deny any of the remaining factual allegations 

in this paragraph and is not required to respond to the paragraph’s legal conclusions. 

20. ADMIT that at least some of the law firms identified in the administrative complaint 

are also identified in FEC filings as having been paid by either the DNC or state party 

affiliates and the same law firms also represented clients challenging Nader-Camejo 

nomination papers. The Commission is without knowledge or information sufficient to 

admit or deny the factual allegations in this paragraph with greater specificity. 

21. ADMIT that Dorothy Melanson testified that the Democratic Party contacted her and 

stated that it would support her financially with respect to her ballot challenge. The 

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

allegations in the remainder of the paragraph. 

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

factual allegations in this paragraph. 

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

factual allegations in this paragraph and is not required to respond to the paragraph’s legal 

conclusions. 

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

factual allegations in this paragraph (including the footnote to this paragraph) and is not 

required to respond to the paragraph’s legal conclusions. 

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

factual allegations in this paragraph. 

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

factual allegations in this paragraph. 

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

factual allegations in this paragraph. 

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

factual allegations in the first sentence of this paragraph. ADMIT that an exhibit to the 

administrative complaint is an April 2004 CBS News report stating that an ACT 

spokesperson made the statement quoted in the second sentence of this paragraph. The 

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

allegations in the third sentence of this paragraph. ADMIT that an SEIU press release and 

accompanying document indicated that SEIU gave $1 million to the DNC. 

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29. This paragraph contains conclusions of law to which no response is required and 

factual allegations about which the Commission is without knowledge or information 

sufficient to admit or deny. 

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

factual allegations in this paragraph and is not required to respond to the paragraph’s legal 

conclusions. 

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

factual allegations in this paragraph. 

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

factual allegations in the first sentence of this paragraph. ADMIT that IRS Reports attached 

to the administrative complaint indicate that the National Progress Fund paid Greenberg 

Research $25,000 in June 2004 for “Polling, Focus Groups” and the Ballot Project paid 

Greenberg Research $10,000 in July 2004 for “consulting fees-political research.” The 

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

allegations in the third sentence of this paragraph. 

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

factual allegations in this paragraph and is not required to respond to the paragraph’s legal 

conclusions. 

34. ADMIT that publicly available information indicates that Uniting People for Victory 

reportedly disseminated “open letters” via newspaper advertisements signed by numerous 

people urging people to vote for Senator John Kerry rather than plaintiff Nader. The 

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

factual allegations in this paragraph. 

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35. ADMIT that IRS Reports attached to the administrative complaint and reports filed 

with the FEC indicate that the National Progress Fund, Uniting People for Victory and 

United Progressives for Victory made expenditures of approximately the amounts indicated 

in this paragraph. The Commission is without knowledge or information sufficient to admit 

or deny the remaining factual allegations in this paragraph. 

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

factual allegations in the first two sentences of this paragraph. ADMIT that the Ballot 

Project, National Progress Fund, and Uniting People for Victory have now all either 

dissolved, became defunct, or ceased operations. The Commission is without knowledge or 

information sufficient to admit or deny the remaining factual allegations in the third sentence 

of this paragraph. 

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

factual allegations in this paragraph. The statements that these organizations were required 

to file as political committees or satisfied the “major purpose” test are conclusions of law to 

which no response is required. 

38. ADMIT that The Ballot Project, the National Progress Fund, Uniting People for 

Victory and Americans for Jobs did not register with the Commission as political 

committees. The Commission is without knowledge or information sufficient to admit or 

deny the remaining factual allegations in this paragraph and is not required to respond to the 

paragraph’s legal conclusions. 

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

factual allegations in the first two sentences of this paragraph. ADMIT that United 

Progressives for Victory registered with the FEC as a political committee in June 2004. 

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ADMIT that Uniting People for Victory did not register with the Commission as a political 

committee. ADMIT that United Progressives for Victory did not respond to the FEC’s letter 

requesting identification of “any affiliated or connected organization,” if any. The 

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

factual allegations in this paragraph and is not required to respond to the paragraph’s legal 

conclusions. 

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

factual allegations in this paragraph and is not required to respond to the paragraph’s legal 

conclusions. 

41. DENY that the plaintiff “clearly provided the FEC with reason to believe that 

Respondents committed the ... violations [ ] as set forth in the administrative complaint.” 

ADMIT that the paragraph accurately quotes the administrative complaint. 

42. DENY the factual allegations in the first two sentences of this paragraph. ADMIT 

that plaintiff submitted two supplements to the administrative complaint, on or about 

September 24, 2008 and January 7, 2010 (mistakenly dated January 7, 2009). 

43. The first sentence of this paragraph contains plaintiff’s characterization of a Grand 

Jury Presentment, which speaks for itself. ADMIT that a transcript attached to a supplement 

to the administrative complaint indicates that Melissa Lewis testified that Efrem Grail 

coordinated the effort described in the Presentment. The Commission is without knowledge 

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

44. ADMIT that the block quote in this paragraph accurately quotes a Grand Jury 

Presentment. The remainder of this paragraph contains plaintiff’s characterization of the 

Grand Jury Presentment, which speaks for itself. 

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

factual allegations in this paragraph. 

46. DENY the factual allegations in the first sentence of the complaint. The second 

sentence of this paragraph contain plaintiff’s characterization of a Grand Jury Presentment, 

which speaks for itself. The Commission is without knowledge or information sufficient to 

admit or deny the factual allegations in the third sentence of this paragraph. 

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

factual allegations in the first sentence of this paragraph. ADMIT that the supplements to the 

administrative complaint named additional respondents and requested that the FEC refer this 

matter to the Justice Department. 

48. DENY that the FEC’s actions were “arbitrary and capricious.” ADMIT that the 

Commission’s regulations provide that the General Counsel shall send “each respondent” a 

copy of the complaint. DENY that the Commission acted “[i]n direct violation of the Act 

and its own regulations.” ADMIT that the FEC notified neither SEIU nor the law firms, state 

Democratic Parties, and individuals named in the administrative complaint as allegedly 

affiliated with the Section 527 Respondents. 

49. DENY that the Commission “violated the Act and its own regulations.” ADMIT that 

the Ballot Project was first notified approximately four months after the initial (defective) 

administrative complaint was filed and the Commission attributed the lack of earlier 

notification to an “administrative oversight.” ADMIT that America Coming Together 

claimed to have not received notice until approximately six months after the initial 

(defective) administrative complaint was filed, despite having been sent notice by the 

Commission two months earlier. DENY that the “FEC relied on its failure to serve certain 

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Respondents, and its delay in serving others, as grounds to dismiss the entire administrative 

complaint.” DENY that the Commission acted “contrary to law” and that “the FEC must be 

reversed.” 

50. DENY that “the FEC apparently faulted Plaintiff for the length of the administrative 

complaint, as supplemented.” The Commission is without knowledge or information 

sufficient to admit or deny the remaining factual allegations in the first two sentences of this 

paragraph. DENY that the Commission acted with a “willful failure even to process the 

administrative complaint.” The Commission is without knowledge or information sufficient 

to admit or deny the remaining factual allegations in this paragraph. 

51. DENY that the Commission “requires reversal,” “erred as a matter of law,” “had a 

statutory duty to investigate,” and acted in a manner that was “arbitrary, capricious and an 

abuse of discretion.” DENY all remaining factual allegations in this paragraph. 

52. The first sentence of this paragraph characterizes the Commission’s First General 

Counsel’s Report, which speaks for itself. The next three sentences of this paragraph contain 

plaintiff’s characterizations of judicial decisions, to which no response is required. ADMIT 

that the claims in the administrative complaint are generally governed by a five-year statute 

of limitations. DENY any remaining factual allegations in this paragraph. 

53. DENY that the Commission acted “[i]n clear violation of the Act and its regulations.” 

DENY that claims against law firms identified in the administrative complaint were 

“dismissed.” ADMIT that the law firms identified in the administrative complaint were not 

notified of the complaint. ADMIT that the First General Counsel’s Report stated that Count 

1 of the administrative complaint was “based on a viable theory” but the Report concluded 

that “the available facts do not support the allegations.” The assertions that “the FEC’s duty 

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to serve the administrative complaint on respondent parties is mandatory” and that “this error 

alone requires reversal” are conclusions of law to which no response is required. 

54. DENY the factual allegations in the first sentence of this paragraph. ADMIT that the 

second sentence quotes from the Factual and Legal Analyses for the Commision’s 

determination. The third and fourth sentences characterize and quote from the administrative 

complaint, which speaks for itself. The Commission is without knowledge or information 

sufficient to admit or deny the factual allegations in the last sentence of this paragraph. 

55. DENY that the “FEC also imposed an impossible burden by requiring direct evidence 

amounting to proof that Respondent law firms compensated Respondent lawyers who 

challenged Nader-Camejo nomination papers.” The Commission is without knowledge or 

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

56. ADMIT that the quotes from the Factual and Legal Analyses for the Commission’s 

determination in the first sentence of this paragraph are accurate. DENY the remaining 

factual allegations in this paragraph. 

57. This paragraph contains solely conclusions of law to which no response is required. 

58. The first sentence of this paragraph contains a conclusion of law to which no response 

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

deny the remaining factual allegations in this paragraph. 

59. DENY the factual allegations in the first sentence of this paragraph. The Commission 

is without knowledge or information sufficient to admit or deny the factual allegations in the 

second and third sentences of this paragraph. DENY the factual allegations in the last 

sentence of this paragraph. 

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60. DENY the factual allegations in the first sentence of this paragraph. The second 

sentence characterizes and quotes from the Factual and Legal Analyses for the Commision’s 

determination, which speak for themselves. The Commission is without knowledge or 

information sufficient to admit or deny the factual allegations in the third sentence of this 

paragraph and is not required to respond to its legal conclusions. DENY the allegations in 

the last sentence of this paragraph. 

61. DENY. 

62. DENY that the FEC’s determination “violated the Act and its own regulations.” 

ADMIT that the Commission did not notify SEIU of the administrative complaint. The 

second sentence of this paragraph contains plaintiff’s characterizations of the administrative 

complaint, which speaks for itself. The assertions that “the FEC’s duty to serve the 

administrative complaint on respondent parties is mandatory” and that “this error alone 

requires reversal” are conclusions of law to which no response is required. 

63. DENY the allegations in the first sentence of this paragraph. The second sentence 

characterizes and quotes from the Factual and Legal Analyses for the Commision’s 

determination, which speak for themselves. The third and fourth sentences of this paragraph 

contain conclusions of law to which no response is required. DENY the allegations in the 

last sentence of this paragraph. 

64. The first two sentences of this paragraph characterize the Factual and Legal Analysis 

for the Commision’s determination as to ACT, which speaks for itself. ADMIT, upon 

information and belief, that SEIU is not “essentially defunct.” DENY any remaining 

allegations in the last sentence of this paragraph. 

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65. ADMIT that the Commission did not notify SEIU of the administrative complaint. 

DENY the remaining allegations in the first two sentences of this paragraph. The third 

sentence of this paragraph characterizes the Factual and Legal Analysis for the Commission’s 

determination as to DNC, which speaks for itself. DENY the allegations in the last sentence 

of this paragraph. 

66. DENY the allegations in the first sentence of this paragraph. ADMIT that the 

administrative complaint contains the assertions in the second sentence of this paragraph. 

The third sentence of this paragraph characterizes the Factual and Legal Analysis for the 

Commission’s determination as to DNC, which speaks for itself. 

67. The first sentence of this paragraph characterizes the Factual and Legal Analysis for 

the Commission’s determination as to DNC, which speaks for itself. DENY the allegations 

in the second and third sentences of this paragraph. The fourth sentence of this paragraph 

characterizes the Factual and Legal Analysis for the Commission’s determination as to DNC, 

which speaks for itself. The fifth sentence of this paragraph characterizes the administrative 

complaint, which speaks for itself. The Commission is without knowledge or information 

sufficient to admit or deny the factual allegations in the last sentence of this paragraph. The 

implication in the last sentence that the Commission violated the Act by not serving the 

administrative complaint on SEIU is a conclusion of law to which no response is required. 

68. DENY that the FEC’s determination “violat[ed] the Act and its own regulations.” 

ADMIT that the Commission did not notify the individuals alleged in Count 3 of the 

administrative complaint to have violated the Act. The Commission is without knowledge or 

information sufficient to admit or deny the factual allegations in the second sentence of this 

paragraph. The third sentence and accompanying of this paragraph characterize the 

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administrative complaint and one of the Commision’s Factual and Legal Analyses, which 

speak for themselves. The assertions that “the FEC’s duty to serve the administrative 

complaint on such Respondent parties is mandatory” and that “its failure to do so is contrary 

to law and requires reversal” are conclusions of law to which no response is required. 

69. The first sentence of this paragraph characterizes and quotes from the Factual and 

Legal Analyses for the Commision’s determination, which speak for themselves. The second 

sentence is a conclusion of law to which no response is required. ADMIT, upon information 

and belief, that the individuals identified in the administrative complaint are not “defunct.” 

DENY the allegations in the last sentence of this paragraph. 

70. ADMIT that the first sentence of this paragraph quotes from either the Commission’s 

First General Counsel’s Report or one of the Factual and Legal Analyses for the 

Commission’s determination. ADMIT that the initial (defective) administrative complaint 

was filed on May 30, 2008. The Commission is without knowledge or information sufficient 

to admit or deny the remaining factual allegations in the second sentence of this paragraph. 

ADMIT that the Commission’s “administrative oversight” resulted in The Ballot Project and 

ACT receiving notification of the administrative complaint several months later than 

intended by the Commission. DENY the remaining allegations in this paragraph. 

71. DENY that the Commission’s actions were “contrary to law,” “an abuse of 

discretion,” and “arbitrary and capricious.” DENY the remaining allegations in this 

paragraph. 

72. DENY. 

73. The first sentence of this paragraph characterizes the administrative complaint, which 

speaks for itself. DENY that the Commission caused plaintiff ongoing reputational harm. 

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The remainder of the second sentence of this paragraph contains legal conclusions, to which 

no response is required. 

74. DENY that the Commission’s actions were “wrongful” or threaten plaintiff with 

imminent harm. ADMIT that the Commission did not refer this matter to the Justice 

Department. The Commission is without knowledge or information sufficient to admit or 

deny the factual allegations in the remainder of this paragraph. 

75. The Commission incorporates by reference all responses contained in the preceding 

paragraphs. 

76. DENY. 

77. DENY. 

PRAYER FOR RELIEF

 No response is required, but the relief requested by plaintiff should be denied. 

AFFIRMATIVE DEFENSES 

The Complaint fails to state a claim upon which relief may be granted. 

Plaintiff lacks standing to bring some of the claims in this lawsuit. 

Respectfully submitted, 

Phillip Christopher Hughey 

Acting General Counsel 

David Kolker (D.C. Bar No. 394558)

Associate General Counsel 

Kevin Deeley 

Assistant General Counsel 

/s/ Seth Nesin 

Seth Nesin 

Attorney 

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COUNSEL FOR DEFENDANT 

FEDERAL ELECTION COMMISSION 

999 E Street NW 

Washington, DC 20463 

Telephone: (202) 694-1650 

Fax: (202) 219-0260 

August 23, 2010 

 

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18 

CERTIFICATE OF SERVICE

I hereby certify that I caused the foregoing to be delivered through the ECF electronic 

filing system on the 23rd day of August, 2010, to: 

Oliver B. Hall 

1835 16th Street NW 

Washington, D.C. 20009 

oliverbhall@gmail.com

/s/ Seth Nesin 

Seth Nesin 

COUNSEL FOR DEFENDANT 

FEDERAL ELECTION COMMISSION 

999 E Street NW 

Washington, DC 20463 

Telephone: (202) 694-1650 

Fax: (202) 219-0260 

snesin@fec.gov 

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