Lisa J. Stevenson (lstevenson@fec.gov) 

Deputy General Counsel – Law 

Kevin Deeley (kdeeley@fec.gov) 

Acting Associate General Counsel 

Harry J. Summers (hsummers@fec.gov) 

Assistant General Counsel 

Kevin P. Hancock (khancock@fec.gov) 

Attorney 

FOR THE PLAINTIFF 

FEDERAL ELECTION COMMISSION 

999 E Street NW 

Washington, DC 20463 

(202) 694-1650 

IN THE UNITED STATES DISTRICT COURT 

DISTRICT OF UTAH, CENTRAL DIVISION 

_______________________________________ 

 ) 

FEDERAL ELECTION COMMISSION, ) 

 ) 

 Plaintiff, ) Case No. 2:15CV00439 TC 

 ) 

 v. ) 

 ) 

JEREMY JOHNSON, ) COMPLAINT 

 ) 

 Defendant. ) District Judge Tena Campbell 

 ) 

PLAINTIFF FEDERAL ELECTION COMMISSION’S COMPLAINT FOR CIVIL 

PENALTY, DECLARATORY, INJUNCTIVE, AND OTHER APPROPRIATE RELIEF

 

 Plaintiff Federal Election Commission (“Commission” or “FEC”), for its Complaint 

against defendant Jeremy Johnson, alleges as follows: 

INTRODUCTION 

1. During the 2009-2010 campaign cycle for federal elections, Utah businessman 

Jeremy Johnson knowingly and willfully made campaign contributions that violated the Federal 

Case 2:15-cv-00439-DB Document 2 Filed 06/19/15 Page 1 of 14
2

Election Campaign Act (“FECA” or “Act”) because they exceeded applicable limits and were 

made in the names of other persons. 

2. In 2009 and 2010, FECA provided that no person could contribute in excess of 

$2,400 per election to any federal candidate. During that time, however, Johnson contributed 

approximately $100,000 to Mark Shurtleff’s United States Senate campaign, about $50,000 to 

Mike Lee’s Senate campaign, and about $20,000 to then-Senate Majority Leader Harry Reid’s 

Senate campaign. Johnson contributed at least a substantial part of these unlawful amounts with 

the hope that doing so would help protect Johnson’s business interests from federal prosecution. 

3. To contribute these excessive amounts, Johnson unlawfully used “straw donors” 

— that is, contributors who gave funds ostensibly in their own names to the candidates but with 

the understanding that Johnson would either advance them the funds or reimburse them after the 

contributions were made. Johnson advanced or reimbursed approximately $170,000 to the straw 

donors he recruited, who in turn gave funds to the Shurtleff, Lee, and Reid campaigns. 

4. To remedy these violations, the Commission seeks a declaration that Johnson 

violated FECA’s limit on the amount a person may contribute per election to a federal candidate, 

see 52 U.S.C. § 30116(a)(1)(A), and FECA’s prohibition on any person contributing to a federal 

candidate in the name of another person, see 52 U.S.C. § 30122. The FEC also requests that the 

Court assess appropriate civil penalties against Johnson, permanently enjoin Johnson from 

committing future similar violations, and impose any other appropriate relief. 

JURISDICTION AND VENUE

 5. This action seeks civil penalties, a declaratory judgment, a permanent injunction, 

and other appropriate relief as authorized by the Federal Election Campaign Act, 52 U.S.C. 

Case 2:15-cv-00439-DB Document 2 Filed 06/19/15 Page 2 of 14
3

§§ 30101-46 (formerly 2 U.S.C. §§ 431-57).1

 6. This Court has jurisdiction over this suit pursuant to 28 U.S.C. § 1345, since it is 

an action brought by an agency of the United States expressly authorized to sue by an act of 

Congress. See 52 U.S.C. §§ 30107(a)(6), 30109(a)(6). 

 7. Venue is properly found in the United States District Court for the District of 

Utah pursuant to 28 U.S.C. § 1391(b) and 52 U.S.C. § 30109(a)(6)(A), because Johnson is 

found, resides, and transacts business in this District and because a substantial part of the acts or 

omissions giving rise to this suit occurred in this District. 

THE PARTIES 

 8. Plaintiff FEC is the independent agency of the United States government with 

exclusive jurisdiction over the administration, interpretation, and civil enforcement of FECA. 

See 52 U.S.C. §§ 30106(b)(1), 30107(a), 30109. The Commission is authorized to investigate 

possible violations of the Act, id. § 30109(a)(1)-(2), and to file civil lawsuits in the United States 

district courts to enforce the Act, id. §§ 30107(e), 30109(a)(6). 

 9. Defendant Jeremy Johnson is a Utah resident who has conducted business in 

Utah. At all times relevant to this case, Johnson has owned or effectively controlled a company 

named Triple 7, an internet-marketing company named I Works, Inc. (“I Works”), and other 

businesses that processed transactions for online-poker companies. 

RELEVANT STATUTORY AND REGULATORY PROVISIONS

10. During the 2009-2010 election cycle, FECA prohibited any person from 

contributing in excess of $2,400 per election to any candidate for federal office and his or her 

                                                           

1

 On September 1, 2014, FECA’s provisions moved from Title 2 of the United States Code 

to newly created Title 52. The alleged violations and some of the administrative actions in this 

matter occurred prior to this change. A full transfer table is available at http://uscode.house.gov/ 

editorialreclassification/t52/Reclassifications_Title_52.html. 

Case 2:15-cv-00439-DB Document 2 Filed 06/19/15 Page 3 of 14
4

authorized political committees. 52 U.S.C. § 30116(a)(1)(A) (formerly 2 U.S.C. 

§ 441a(a)(1)(A)); Price Index Increases for Contribution and Expenditure Limitations, 74 Fed. 

Reg. 7435-02, 7437 (Feb. 17, 2009). 

11. The Act further provides that “[n]o person shall make a contribution in the name 

of another person.” 52 U.S.C. § 30122 (formerly 2 U.S.C. § 441f). Additionally, no person may 

“[k]nowingly help or assist” any person contribute in the name of another. 11 C.F.R. 

§ 110.4(b)(iii). A person has knowingly helped or assisted a person to contribute in the name of 

another when he or she has “initiate[d] or instigate[d] or ha[d] some significant participation in a 

plan or scheme to make a contribution in the name of another.” Prohibited Contributions, 

54 Fed. Reg. 34,098, 34,105 (Aug. 17, 1989) (Explanation and Justification for 11 C.F.R. 

§ 110.4). 

12. The Act authorizes a United States district court to order a defendant who has 

knowingly and willfully contributed excessive amounts to a federal candidate in violation of 52 

U.S.C. § 30116(a) to pay a civil penalty. That civil penalty may not exceed the greater of 

$16,000 or 200% of the contributions involved in the violation. See 52 U.S.C. 

§ 30109(a)(6)(C); 11 C.F.R. § 111.24(a)(2)(i) (2010). 

13. The Act authorizes a United States district court to order a defendant who has 

knowingly and willfully made contributions in the name of another in violation of 52 U.S.C. 

§ 30122 to pay a civil penalty. That civil penalty may not be less than 300% of the contributions 

involved in the violation and may not be more than the greater of $60,000 or 1,000% of the 

contributions involved in the violation. 52 U.S.C. § 30109(a)(6)(C); 11 C.F.R. § 111.24(a)(2)(ii) 

(2010). 

Case 2:15-cv-00439-DB Document 2 Filed 06/19/15 Page 4 of 14
5

14. For a defendant who has violated FECA, but has not done so knowingly and 

willfully, the Act authorizes a United States district court to order that defendant to pay a civil 

penalty that does not exceed the greater of $7,500 or an amount equal to any contribution 

involved in the violation. 52 U.S.C. § 30109(a)(6)(B); 11 C.F.R. § 111.24(a)(1) (2010). 

15. In addition to imposing civil penalties, FECA authorizes a United States district 

court to “grant a permanent or temporary injunction, restraining order, or other order” against 

any defendant who has violated the Act. 52 U.S.C. § 30109(a)(6)(B). 

FACTUAL BACKGROUND 

16. During the 2009-2010 election cycle, Johnson knowingly and willfully used straw 

donors to contribute amounts in excess of FECA’s limits to three candidates for United States 

Senate at least in part in an attempt to further and protect his business interests. 

Johnson’s Unlawful Contributions to the Shurtleff Campaign 

17. In 2009, Johnson used the names of others to contribute approximately $100,000 

to Mark Shurtleff, who was then the Attorney General of Utah and a candidate in the June 2010 

Republican primary election for United States Senate in Utah. 

18. During the time relevant to this case, Johnson’s business interests included 

companies that made tens of millions of dollars by processing financial transactions for onlinepoker companies. Also during the time relevant to this case, Johnson was aware that the United 

States Attorney’s Office in the Southern District of New York had been filing lawsuits to seize 

the assets of online-poker companies, including those like Johnson’s companies that processed 

financial transactions relating to online poker games. 

Case 2:15-cv-00439-DB Document 2 Filed 06/19/15 Page 5 of 14
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19. In 2009, Johnson met John Swallow, Utah’s Chief Deputy Attorney General and a 

fundraiser for the Shurtleff campaign. Johnson agreed with Swallow to contribute amounts in 

excess of FECA’s limits to the Shurtleff campaign. 

20. Johnson offered to write a check for Shurtleff’s campaign in an amount in excess 

of FECA’s limits. Swallow told Johnson, however, about the statutory limit to the amount that 

any one person could legally contribute to a federal candidate. Swallow and Johnson then 

discussed the possibility of illicitly contributing additional amounts to Shurtleff’s campaign by 

giving the funds to straw donors and arranging for those straw donors to pass on the funds to the 

Shurtleff campaign. 

21. Johnson entered into arrangements or understandings with his straw donors that 

they would contribute funds to Shurtleff’s campaign and that Johnson would supply them with 

the funds for those contributions. 

22. Johnson’s straw donors transmitted funds to Shurtleff’s campaign that collectively 

amounted to approximately $100,000. Johnson supplied his straw donors with those funds by 

either advancing them the money for the donations they would make to Shurtleff’s campaign, or 

reimbursing them for the donations they had already made to Shurtleff’s campaign. 

23. Johnson made the contributions described in paragraphs 17-22 for the purpose of 

influencing the 2010 Republican primary election for United States Senate in Utah. 

24. Johnson made the contributions described in paragraphs 17-22 voluntarily and 

with an awareness that they were unlawful. 

Johnson’s Unlawful Contributions to the Lee Campaign 

25. In 2010, Johnson used the names of others to contribute approximately $50,000 to 

Mike Lee, who was then a candidate in the June 2010 Republican primary election for United 

Case 2:15-cv-00439-DB Document 2 Filed 06/19/15 Page 6 of 14
7

States Senate in Utah, and who, after winning that election, became a candidate in the November 

2010 general election for United States Senate in Utah. 

26. In November 2009, Shurtleff ended his campaign, and in January 2010, Mike Lee 

entered the race for the Republican nomination for Senate in Utah, with Shurtleff’s endorsement. 

27. Johnson agreed with Swallow to contribute amounts in excess of FECA’s limits to 

the Lee campaign, just as Johnson had for Shurtleff. Swallow and Johnson discussed how 

contributing to Lee’s campaign would help protect and advance Johnson’s business interests. In 

particular, Swallow told Johnson that if Johnson contributed to Lee, and if Lee won election to 

the Senate, Lee could then play a key role in the appointment of a United States Attorney in Utah 

who could protect Johnson’s business interests from prosecution by other United States 

Attorneys. 

28. For example, Johnson has reported that Swallow said to him: “[I]t is important 

that we raise this money and make Mike Lee our guy. . . . [H]e is going to be choosing the next 

U.S. Attorney and you gotta have him in your corner and you gotta have the U.S. Attorney in 

your corner especially while you are processing poker in this district.” 

29. Johnson entered into arrangements or understandings with his straw donors that 

they would contribute funds to Lee’s campaign and that Johnson would supply them with the 

funds for those contributions. As Johnson has described, he would simply tell a potential straw 

donor: “Hey would you donate to Mike Lee? I’ll get you the money.” 

30. Johnson’s straw donors transmitted funds to Lee’s campaign that collectively 

amounted to approximately $50,000. Johnson supplied his straw donors with those funds by 

either advancing them the money for the contributions they would make to Lee’s campaign or 

reimbursing them for the contributions they had already made to Lee’s campaign. 

Case 2:15-cv-00439-DB Document 2 Filed 06/19/15 Page 7 of 14
8

31. Johnson made the contributions described in paragraphs 25-30 for the purpose of 

influencing the 2010 Republican primary election for United States Senate in Utah or the 2010 

general election for United States Senate in Utah. 

32. Johnson made the contributions described in paragraphs 25-30 voluntarily and 

with an awareness that they were unlawful. 

Johnson’s Unlawful Contributions to the Reid Campaign 

33. In 2010, Johnson used the names of others to contribute approximately $20,000 to 

then-Majority Leader Harry Reid, who was a candidate in the June 2010 primary election for the 

Democratic nomination for United States Senate in Nevada, and who, after winning that election, 

became a candidate in the November 2010 general election for United States Senate in Nevada. 

34. In 2010, Johnson discussed with individuals in the online-poker gaming industry, 

including Ray Bitar, a principal of an internet-poker company called Full Tilt Poker, using straw 

donors to contribute unlawful amounts to federal candidates, including Majority Leader Reid, in 

an attempt to protect or further their business interests. Full Tilt Poker became a defendant in a 

civil asset forfeiture case brought by the United States Attorney’s Office in the Southern District 

of New York in 2011. See United States v. Pokerstars, et al., No. 11-cv-2564 (S.D.N.Y.). 

35. During the time relevant to this case, Johnson owned an internet-marketing 

company named I Works. In 2010, the Federal Trade Commission was investigating complaints 

that I Works charged customers without authorization and engaged in other fraudulent trade 

practices. In the latter half of 2010, Johnson unsuccessfully sought Majority Leader Reid’s 

assistance in halting the Federal Trade Commission’s investigation. In December 2010, the 

Federal Trade Commission filed suit against Johnson and some of his associates and businesses, 

including I Works, in the United States District Court for the District of Nevada. See FTC v. 

Case 2:15-cv-00439-DB Document 2 Filed 06/19/15 Page 8 of 14
9

Johnson, et al., No. 2:10-cv-2203 (D. Nev.). Also as a result of I Works’ allegedly unlawful 

business practices, Johnson was criminally indicted in June 2011 in the United States District 

Court for the District of Utah. See United States v. Johnson et al., No. 2:11-cr-0501 (D. Utah). 

36. Johnson entered into arrangements or understandings with his straw donors that 

they would contribute funds to Majority Leader Reid’s campaign, and that Johnson would supply 

them with the funds for those contributions. 

37. Johnson’s straw donors transmitted funds to Majority Leader Reid’s campaign 

that collectively amounted to approximately $20,000. Johnson supplied his straw donors with 

those funds by either advancing them the money for the contributions they would make, or 

reimbursing them for the contributions they had already made, to the Reid campaign. 

38. Johnson made the contributions described in paragraphs 33-37 for the purpose of 

influencing the 2010 Democratic primary election for United States Senate in Nevada or the 

2010 general election for United States Senate in Nevada. 

39. Johnson made the contributions described in paragraphs 33-37 voluntarily and 

with an awareness that they were unlawful. 

Johnson’s Straw Donors and Efforts to Conceal His Unlawful Contributions 

 40. The straw donors for Johnson’s unlawful contributions to the Shurtleff, Lee, and 

Reid campaigns included Johnson’s family members, employees, friends, and business 

associates. 

41. In an attempt to conceal his illicit scheme, Johnson sometimes used cash to 

advance funds to his straw donors or to reimburse them for their donations to the candidates. 

Case 2:15-cv-00439-DB Document 2 Filed 06/19/15 Page 9 of 14
10

42. Also, Johnson and his straw donors at times used companies and accounts that 

they owned or effectively controlled to execute and attempt to conceal Johnson’s illegal 

contributions. 

43. For example, Johnson enlisted one of his business associates, Arvin Lee Black II, 

to act as a straw donor and to recruit other straw donors for Johnson’s illicit contributions. On 

June 14, 2010, Triple 7, a company Johnson owned or effectively controlled, issued a check for 

$14,400 to Sole Group LLC, a company owned or controlled by Black. The $14,400 amount of 

that check was the exact amount needed to fund six contributions of $2,400 each, which was 

FECA’s applicable limit for contributions to federal candidates in the 2009-2010 election cycle. 

44. The same day that Triple 7 issued its $14,400 check to Sole Group LLC, Sole 

Group LLC issued six checks for $2,400 each (totaling $14,400) made payable sequentially to 

Arvin Lee Black II, Atia Black, Matthew Black, Savannah Jones, Kyle Boyer, and Tiffany 

Boyer. Each of those six individuals attempted to make contributions in the amount of $2,400 

each to the Lee campaign in June 2010. Some of their checks bounced, but at least four of the 

contributions, for a total of $9,600, were successfully made. 

45. Swallow informed Johnson about the four bounced contribution checks, and 

Johnson responded that he would “fix” the problem immediately. The following day, three of 

the four contributors whose contributions had bounced issued new contribution checks to the Lee 

campaign. 

ADMINISTRATIVE PROCEEDINGS 

 46. On June 30, 2014, the Commission received an administrative complaint alleging, 

among other things, that Johnson used the names of others to contribute $50,000 to the Lee 

Senate campaign; that Black was one of Johnson’s straw donors; and that Swallow had 

Case 2:15-cv-00439-DB Document 2 Filed 06/19/15 Page 10 of 14
11

previously discussed with Johnson using the names of others to contribute to Shurtleff’s 2010 

Senate campaign. 

47. On July 3, 2014, the Commission notified Johnson that the administrative 

complaint had been filed. The Commission provided Johnson with a copy of the administrative 

complaint and an opportunity to respond. See 52 U.S.C. § 30109(a)(1). Johnson did not submit 

a written response to the administrative complaint. 

48. After reviewing the then-available information, on November 18, 2014, the 

Commission, by an affirmative vote of at least four of its members, found reason to believe that 

Johnson had violated 52 U.S.C. §§ 30116(a)(1)(A) and 30122 by making excessive contributions 

in the names of others to the Lee campaign. The Commission notified Johnson of its reason-tobelieve findings in a letter dated December 22, 2014. See 52 U.S.C. § 30109(a)(2). 

49. After conducting an investigation, the Commission’s Office of the General 

Counsel notified Johnson by letter dated March 11, 2015 that it was prepared to recommend that 

the Commission find probable cause to believe that Johnson knowingly and willfully violated 52 

U.S.C. §§ 30116(a)(1)(A) and 30122. The Office of the General Counsel also provided Johnson 

with a brief stating its position on the legal and factual issues of the matter. See 52 U.S.C. 

§ 30109(a)(3). Johnson did not submit a reply. 

50. After reviewing the information then available, on April 16, 2015, the 

Commission, by an affirmative vote of at least four of its members, found probable cause to 

believe that Johnson knowingly and willfully violated 52 U.S.C. §§ 30116(a)(1)(A) and 30122 

by making excessive contributions in the names of others to federal campaigns. See 52 U.S.C. 

§ 30109(a)(3). 

51. The Commission notified Johnson of its probable cause findings against him by 

Case 2:15-cv-00439-DB Document 2 Filed 06/19/15 Page 11 of 14
12

letter dated April 20, 2015. The Commission then endeavored to correct Johnson’s violations 

through informal methods of conference, conciliation, and persuasion, for a period of not less 

than 30 days. See 52 U.S.C. § 30109(a)(4)(A). 

52. On May 15, 2015, Johnson signed an agreement tolling the statute of limitations 

for 30 days. 

53. Unable to secure an acceptable conciliation agreement, on June 15, 2015, the 

Commission, by an affirmative vote of at least four of its members, authorized filing this suit 

against Johnson. See 52 U.S.C. § 30109(a)(6). 

54. The Commission has satisfied all of the jurisdictional requirements in FECA that 

are prerequisites to filing this action. 

FIRST CAUSE OF ACTION

55. Paragraphs 1 through 54, inclusive, are incorporated herein by reference. 

56. Defendant Jeremy Johnson knowingly and willfully violated 52 U.S.C. 

§ 30116(a)(1)(A) by contributing approximately $100,000 to Mark Shurtleff’s United States 

Senate campaign, about $50,000 to Mike Lee’s Senate campaign, and about $20,000 to Majority 

Leader Harry Reid’s Senate campaign during the 2009-2010 election cycle. 

SECOND CAUSE OF ACTION

57. Paragraphs 1 through 54, inclusive, are incorporated herein by reference. 

58. Defendant Jeremy Johnson knowingly and willfully violated 52 U.S.C. § 30122 

by using straw donors to contribute approximately $100,000 to Mark Shurtleff’s United States 

Senate campaign, about $50,000 to Mike Lee’s Senate campaign, and about $20,000 to Majority 

Leader Harry Reid’s Senate campaign during the 2009-2010 election cycle. 

 

Case 2:15-cv-00439-DB Document 2 Filed 06/19/15 Page 12 of 14
13

PRAYER FOR RELIEF 

WHEREFORE, plaintiff Federal Election Commission prays that this Court: 

A. Declare that defendant Jeremy Johnson knowingly and willfully violated 52 

U.S.C. § 30116(a)(1)(A) by making contributions in excess of the lawful limits. 

B. Declare that defendant Jeremy Johnson knowingly and willfully violated 52 

U.S.C. § 30122 by contributing money in the names of others. 

C. Permanently enjoin defendant Jeremy Johnson from contributing amounts in 

excess of FECA’s limits to federal candidates. 

D. Permanently enjoin defendant Jeremy Johnson from contributing money in the 

names of others to federal candidates. 

E. Assess an appropriate civil penalty against defendant Jeremy Johnson: 

1. for each knowing and willful violation of 52 U.S.C. § 30116(a), a civil 

penalty that is not more than the greater of $16,000 or 200% of the amount involved in the 

violation, see 52 U.S.C. § 30109(a)(6)(C), 11 C.F.R. § 111.24(a)(2)(i) (2010); 

2. for each knowing and willful violation of 52 U.S.C. § 30122, a civil 

penalty that is not less than 300% of the amount involved in the violation and is not more than 

the greater of $60,000 or 1,000% of the amount involved in the violation, see 52 U.S.C. § 

30109(a)(6)(C), 11 C.F.R. § 111.24(a)(2)(ii) (2010); and 

 3. for any violation that the Court may find to be not knowing and willful, a 

civil penalty not to exceed the greater of $7,500 or the amount of any contributions or 

expenditures involved, see 52 U.S.C. § 30109(a)(6)(B), 11 C.F.R. § 111.24(a)(1) (2010). 

F. Award plaintiff Federal Election Commission its costs in this action; and 

Case 2:15-cv-00439-DB Document 2 Filed 06/19/15 Page 13 of 14
14

G. Grant plaintiff Federal Election Commission such other relief as may 

be appropriate. 

Respectfully submitted, 

/s/ Lisa J. Stevenson (Signed by Filing Attorney with permission of Plaintiff Attorney) 

Lisa J. Stevenson (lstevenson@fec.gov) 

Deputy General Counsel – Law 

/s/ Kevin Deeley (Signed by Filing Attorney with permission of Plaintiff Attorney) 

Kevin Deeley (kdeeley@fec.gov) 

Acting Associate General Counsel 

/s/ Harry J. Summers 

(Signed by Filing Attorney with permission of Plaintiff Attorney) 

Harry J. Summers (hsummers@fec.gov) 

Assistant General Counsel 

/s/ Kevin P. Hancock 

Kevin P. Hancock (khancock@fec.gov) 

Attorney 

June 19, 2015 FOR THE PLAINTIFF 

FEDERAL ELECTION COMMISSION 

999 E Street, NW 

Washington, DC 20463 

(202) 694-1650 

Case 2:15-cv-00439-DB Document 2 Filed 06/19/15 Page 14 of 14
JS 44 (Rev. 12112) CIVIL COVER SHEET 

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the tiling and service of pleadings or other papers as required by law except as 

provided by local rules ofcourt. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the 

purpose of Inlliatmg the CIVIl docket sheet (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM) 

I. (a) PLAINTIFFS 

Federal Election Commission 

(b) County of Residence of First Listed Plaintiff 

(EXCHPT IN U.S PLAINTIFF CASES) 

(C) Attorneys (Firm Name, Addre.r.v, and Telephone Numher) 

See Attachment 

DEFENDANTS 

Johnson, Jeremy 

County of Residence of First Listed Defendant Washington County 

(IN US PLAINTIFF CASES ONLY) 

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED. 

Attorneys (!/Known) 

II. BASIS OF JURISDICTION (Place an "X" mOneBoxOnly) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" in one Boxfi" Plaintiff 

l!'l I U S Government 

Plaintiff 

0 2 U S. Goverrunent 

Defendant 

0 3 Federal Question 

(l!..)'. Clovernmenl Not a Party) 

0 4 Diversity 

(Indicate Cillzenship ojParties in Item Ill) 

IV NATURE OF SUIT (Place an "X" in One Box Only) 

CONTRACT TORTS 

0 II 0 Insurance PERSONAL INJURY PERSONAL INJURY 

0 120 Marine 0 310Airplane 0 365 Personal InJury -

0 130 Miller Act 0 315 Airplane Product Product Liability 

0 140 Negotiable Instrument Liability 0 367 Health Care/ 

0 !50 Recovery of Overpayment 0 320 Assault, Libel & Pharmaceutical 

& Enforcement of Judgment Slander Personal Injury 

0 !51 Medicare Act 0 330 Federal Employers' Product Liability 

0 !52 Recovery of Defaulted Liability 0 368 Asbestos Personal 

Student Loans 0 340 Marine Injury Product 

(Excludes Veterans) 0 345 Marine Product Liability 

0 !53 Recovery of Overpayment Liability PERSONAL PROPERTY 

of Veteran's Benefits 0 350 Motor Vehicle 0 370 Other Fraud 

0 160 Stockholders Suits 0 355 Motor Vehicle 0 371 Truth 111 Lendmg 

0 190 Other Contract Product Ltability 0 380 Other Personal 

0 195 Contract Product Liability 0 360 Other Personal Property Damage 

0 196 Franchise Injury 0 385 Property Damage 

0 362 Personal Injury - Product Liability 

Medical Malpractice 

REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 

0 210 Land Condemnation 0 440 Other Civil Rights Habeas Corpus: 

0 220 Foreclosure 0 441 Voting 0 463 Alien Detainee 

0 230 Rent Lease & Ejectment 0 442 Employment 0 510 Motions to Vacate 

0 240 Torts to Land 0 443 Housing/ Sentence 

0 245 Tort Product Liability Accommodations 0 53 0 General 

0 290 All Other Real Property 0 445 Amer. w/Disabilities- 0 535 Death Penalty 

Employment Other: 

0 446 Amer. w/Disabilities- 0 540 Mandamus & Other 

Other 0 550 Civil Rights 

0 448 Education 0 555 Prison Condition 

0 560 Civil Detainee -

Conditions of 

Confinement 

V, 0 RIG IN (F/ace an "X" tn One Box Only) 

(For Dtvewty Cases Only) 

PTF 

and One Box jiJr Defendant) 

PTF DEF 

Citizen of This State 0 1 

DEF 

0 Incorporated or Principal Place 

of Business In This State 

0 4 0 4 

Citizen of Another State 

Citizen or Subject of a 

F orei rn Count 

F RFEI URE/PENAI TY 

0 625 Drug Related Seizure 

of Property 21 USC 88 I 

0 690 Other 

~ABOR 

0 710 Fair Labor Standards 

Act 

0 720 Labor/Management 

Relattons 

0 740 Railway Labor Act 

0 751 Family and Medical 

Leave Act 

0 790 Other Labor Litigation 

0 791 Employee Retirement 

Income Security Act 

IMMIGRATION 

0 2 0 2 Incorporated and Principal Place 

of Business In Another State 

0 5 0 5 

0 3 0 3 Foreign Nation 0 6 0 6 

BANKRUPTCY OTHERS ATUTES 

0 422 Appeal 28 USC !58 0 375 False Claims Act 

0 423 Withdrawal 0 400 State Reapportiorunent 

28 usc 157 0 410 Antiuust 

0 430 Banks and Banking 

PKOPEK' .'Y KIGH ns 0 450 Commerce 

0 820 Copyrights 0 460 Deportation 

0 830 Patent 0 4 70 Racketeer Influenced and 

0 840 Trademark Corrupt Organizations 

0 480 Consumer Credit 

SOCIAL SEC !JRITY 0 490 Cable/Sat TV 

0 861 HIA (I 395ft) 0 850 Securities/Commodities/ 

0 862 Black Lung (923) Exchange 

0 863 DIWC/DIWW (405(g)) l!!l 890 Other Statutory Actions 

0 864 SSID Title XVI 0 891 Agricultural Acts 

0 865 RSI (405(g)) 0 893 Environmental Matters 

0 895 Freedom of Information 

Act 

0 896 Arbitration 

FEDERAL TAX StilTS 0 899 Administrative Procedure 

0 870 Taxes (U.S. Plaintiff Act/Review or Appeal of 

or Defendant) Agency Decision 

0 87 I IRS-Third Party 0 950 Constitutionality of 

26 usc 7609 State Statutes 

0 462 Naturalization Application 

0 465 Other Immigration 

Actions 

)ll! I Origmal 0 2 Removed trom Proceeding State Court 

0 3 Remanded from 

Appellate Court 

0 4 Remstated or 

Reopened 

0 5 Transferred trom Another District 

(.'pecifY) 

0 6 Multidistrict 

Litigation 

Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity): 

VI. CAUSE OF ACTION 52 U.S.C. 30116 a 1 A, 30122 Federal Election Cam ai n Act. t-=::....,::.;=:.;:~~-=-=~"'--'L:...::..::....:.==----;..,;:..:;:=;;._::;,;..::.=.:..:..:...=,;,;,t;;,;;=..;,.;,.:;.:.;__ __________ _ 

Brief description of cause: 

VII. REQUESTED IN 

COMPLAINT: 

VIII. RELATED CASE(S) 

IF ANY 

DATE 

FOR OFFICE liSE ONLY 

Illegal contributions in the names of others to federal candidates 

0 CHECK IF THIS IS A CLASS ACTION DEMAND$ 

UNDER RULE 23, F.R Cv P 

(See mstruct1om): 

RECEIPT# AMOUNT APPLYING IFP JUDGE 

CHECK YES only if demanded in complaint 

JURY DEMAND: 0 Yes )!!(No 

DOCKET NUMBER 

MAG. JUDGE 

Case 2:15-cv-00439-DB Document 2-1 Filed 06/19/15 Page 1 of 2
Attorneys for Plaintiff Federal Election Commission 

FEDERAL ELECTION COMMISSION 

999 E Street, N.W. 

Washington, DC 20463 

(202) 694-1650 

Lisa J. Stevenson 

Deputy General Counsel - Law 

lstevenson@fec.gov 

Kevin Deeley 

Acting Associate General Counsel 

kdeeley@fec.gov 

Harry J. Summers 

Assistant General Counsel 

hsummers@fec.gov 

Kevin P. Hancock 

Attorney 

khancock@fec.gov 

Case 2:15-cv-00439-DB Document 2-1 Filed 06/19/15 Page 2 of 2