UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

FEDERAL ELECTION COMMISSION, )

)

Plaintiff, )

) Civil Case No. 1:12-CV-00958

v. )

)

CRAIG FOR U.S. SENATE, et. al., )

)

Defendants. )

_________________________________________)

DEFENDANTS CRAIG FOR U.S. SENATE’S, KAYE O’RIORDAN’S

AND LARRY E. CRAIG’S ANSWER

Defendants through their undersigned counsel, responds as follows to the original 

complaint in this litigation. Everything not given a specific response is DENIED.

1. No response is required to this paragraph, which contains plaintiff’s 

characterizations of the legal claims in the complaint.

2. ADMIT regarding the type of relief sought in this matter.

3. ADMIT that this Court has jurisdiction over this suit.

4. ADMIT that venue is proper.

5. ADMIT that the Federal Election Commission (“Commission”) is a federal 

agency created by the Federal Election Campaign Act (“Act”) and that it is authorized to initiate 

civil actions to obtain judicial enforcement of the Act.

6. ADMIT.

7. ADMIT.

8. ADMIT as to factual allegations. Defendants note that on April 8, 2013, Kaye L. 

O’Riordan resigned as Treasurer of Craig for U.S. Senate Committee and the Committee is in the 

process of notifying the Commission and naming a new Treasurer. The last sentence of this 

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paragraph contains conclusions of law and plaintiff’s characterizations of the Act to which no 

response is required.

9. This paragraph contains conclusions of law and plaintiff’s characterizations of the 

Act to which no response is required.

10. This paragraph contains conclusions of law and plaintiff’s characterizations of the 

Act to which no response is required.

11. This paragraph contains conclusions of law and plaintiff’s characterizations of the 

Act and related materials to which no response is required. However, plaintiff’s factual and legal 

assertions relating to its determinations in its advisory opinions are DENIED.

12. ADMIT. 

13. ADMIT. 

14. ADMIT. 

15. ADMIT. 

16. ADMIT. 

17. ADMIT. 

18. ADMIT. 

19. ADMIT. 

20. ADMIT. 

21. ADMIT. 

22. ADMIT that the paragraph accurately quotes the content of the letter. To the 

extent that this paragraph is deemed an admission regarding Senator Craig’s conduct, then this 

paragraph is DENIED.

23. ADMIT that the paragraph accurately quotes the content of the “Public Letter of 

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Admonition.” To the extent that this paragraph alleges that Senator Craig failed to comply with 

the rules of the United States Senate, it is DENIED.

24. ADMIT. 

25. ADMIT. 

26. ADMIT. 

27. ADMIT. 

28. ADMIT. 

29. ADMIT. 

30. ADMIT. 

31. ADMIT. 

32. This paragraph requires no response.

33. Defendants ADMIT the first sentences of this paragraph. The remainder of this 

paragraph contains conclusions of law and plaintiff’s characterizations of the Act to which no 

response is required. However, if any answer may be deemed necessary, defendants DENY that 

disbursements were not ordinary and necessary expenses incurred in connection with official 

duties or that they would have existed irrespective of Senator Craig’s duties as a Senator.

34. This paragraph contains conclusions of law and plaintiff’s characterizations of the 

Act to which no response is required. However, if any answer may be deemed necessary, 

defendants DENY that they have violated 2 U.S.C. § 439a(b).

PRAYER FOR RELIEF. Defendants are not required to respond to plaintiff’s prayer 

for relief. But, if a response is deemed necessary, defendants DENY that any relief should be 

granted.

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Dated: April 11, 2013 Respectfully Submitted,

STANLEY M. BRAND

D.C. Bar # 213082

ANDREW D. HERMAN

D.C. Bar # 462334

BRAND LAW GROUP, PC

923 Fifteenth Street, N.W.

Washington, D.C. 20005

(202) 662-9700

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