UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

 

 ) 

CENTER FOR PUBLIC INTEGRITY, ) 

 ) 

 Plaintiff, ) Civ. No. 17-1162 (CRC) 

 ) 

 ) 

 v. ) 

 ) 

 ) ANSWER 

FEDERAL ELECTION COMMISSION, ) 

 ) 

 Defendant. ) 

 ) 

DEFENDANT FEDERAL ELECTION COMMISSION’S ANSWER 

 Defendant Federal Election Commission (“FEC” or “Commission”) submits this answer 

to the Complaint for Declaratory and Injunctive Relief filed by plaintiff Center for Public 

Integrity. Any allegation not specifically responded to below is DENIED. 

1. This paragraph summarizes plaintiffs’ complaint, the allegations of which speak 

for themselves, and requires no response. To the extent a response is required, ADMIT that this 

case is an action under the Freedom of Information Act (“FOIA”) to compel the production of 

certain agency records. 

2. ADMIT that the Court has jurisdiction pursuant to 5 U.S.C. § 552(a)(4)(B) and 28 

U.S.C. § 1331. DENY that 28 U.S.C. § 2201(a) grants the Court jurisdiction. 

3. ADMIT. 

4. ADMIT that plaintiff is the requester of the records at issue in this case. The 

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

allegations in this paragraph. 

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5. ADMIT the first sentence on this paragraph. ADMIT the Commission is in 

possession of certain records referenced in paragraphs 6 and 11 of plaintiff’s complaint, but 

DENY that the Commission has exclusive possession and control over all of those records at this 

time. 

6. This paragraph describes the first FOIA request at issue in this case, which 

speaks for itself, and requires no response. To the extent a response is required, ADMIT that 

plaintiff submitted a FOIA request on February 1, 2017, and that the request contained the 

language quoted in this paragraph. 

7. ADMIT. 

8. ADMIT. 

9. ADMIT. 

10. This paragraph contains plaintiff’s legal conclusion, to which no response is 

required. To the extent a response is required, DENY. 

11. This paragraph describes the second FOIA request at issue in this case, which 

speaks for itself, and requires no response. To the extent a response is required, ADMIT that 

plaintiff submitted a FOIA request on February 6, 2017, and that the request contained the 

language quoted in this paragraph. 

12. ADMIT. 

13. ADMIT. 

14. ADMIT the first sentence of this paragraph. The remainder of this paragraph is a 

legal conclusion and does not require a response. 

15. This paragraph contains plaintiff’s legal conclusion, to which no response is 

required. To the extent a response is required, DENY that plaintiffs have an immediate right to 

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all of the requested records. DENY that there is no legal basis for the Commission not making 

all of the requested records available at this time. 

REQUESTED RELIEF 

The Court should deny plaintiff’s requested relief. 

 Respectfully submitted, 

Lisa J. Stevenson (D.C. Bar No. 457628) 

Acting General Counsel 

lstevenson@fec.gov 

Kevin Deeley 

Associate General Counsel 

kdeeley@fec.gov 

 

Harry J. Summers 

Assistant General Counsel 

hsummers@fec.gov 

/s/ Seth Nesin 

Seth Nesin 

Attorney 

snesin@fec.gov 

COUNSEL FOR DEFENDANT 

FEDERAL ELECTION COMMISSION 

999 E Street NW 

Washington, DC 20463 

(202) 694-1650 

July 19, 2017 

 

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