UNITED STATES COURT OF APPEALS

FOR THE DISTRICT OF COLUMBIA CIRCUIT

STEVE SCHONBERG, )

)

Plaintiff-Appellant, ) No. 11-5199

)

v. )

)

 MOTION 

 

FEDERAL ELECTION COMMISSION

and UNITED STATES OF AMERICA,

)

)

)

 

 Defendants-Appellees. )

APPELLEE FEDERAL ELECTION COMMISSION’S 

MOTION FOR SUMMARY AFFIRMANCE

Appellee Federal Election Commission (“Commission” or “FEC”) 

respectfully moves for summary affirmance of the district court‟s Memorandum 

Opinion and Order insofar as it granted the Commission‟s motion to dismiss. (See

Mem. Op. and Order (“Op.”), Civ. No. 10-2040 (D.D.C. June 23, 2011) (copy 

attached as Exh. 1)). As the district court held, appellant Steve Schonberg lacks 

Article III standing to maintain his claims seeking to invalidate the Federal 

Election Campaign Act (“FECA”), 2 U.S.C. §§ 431-57, and to abolish the 

Commission that administers and civilly enforces that statute. Schonberg‟s claims 

all rest on the flawed premise that without FECA, other statutes or the Constitution 

would limit campaign contributions, and the public financing of elections would 

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inevitably follow. In fact, without FECA, campaign contributions would have no 

limits, and the defects Schonberg perceives would only worsen.

Schonberg unsuccessfully ran for Congress in 2010, and then brought this 

suit claiming that FECA gives incumbents like his opponent an unconstitutional 

election advantage by authorizing them to accept campaign contributions.

Schonberg chose not to accept contributions because he contends they are

unconstitutional “bribes” that would be illegal but for FECA. 

Schonberg lacks standing. As the district court held, Schonberg‟s alleged

injuries are not redressable because FECA does not make campaign contributions

lawful as a matter of legislative grace — the statute limits contributions, which are 

otherwise lawful and unrestrained. Indeed, the Constitution does not bar campaign 

contributions; although Congress may subject them to certain limits, contributions 

are protected by the First Amendment. Thus, a ruling striking down FECA would 

allow incumbents to accept unlimited contributions, which according to 

Schonberg‟s own theories would exacerbate, not remedy, the electoral 

disadvantages and legislative ills about which he complains. Schonberg has also 

failed to show that FECA has caused him any cognizable injury-in-fact.

In any event, Schonberg‟s constitutional challenges to FECA are frivolous. 

FECA treats all candidates equally and creates no federal “office” that would 

implicate the various constitutional clauses Schonberg invokes. Thus, because 

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“the merits . . . are so clear that expedited action is justified” and “no benefit will 

be gained from further briefing and argument of the issues presented,” Taxpayers 

Watchdog, Inc. v. Stanley, 819 F.2d 294, 297-98 (D.C. Cir. 1987), summary 

affirmance is appropriate in this case. 

BACKGROUND

A. The Federal Election Commission and FECA

The Commission is an independent agency of the United States government 

with exclusive jurisdiction over the administration, interpretation, and civil 

enforcement of FECA. See generally 2 U.S.C. §§ 437c(b)(1), 437d(a), 437g. 

Congress enacted FECA primarily “to limit the actuality and appearance of 

corruption resulting from large individual financial contributions[.]” Buckley v. 

Valeo, 424 U.S. 1, 26 (1976). Congress later amended FECA with the Bipartisan 

Campaign Reform Act of 2002 (“BCRA”), Pub. L. No. 107, 116 Stat. 81 (Mar. 27, 

2002), which was similarly “designed to purge national politics of what was 

conceived to be the pernicious influence of „big money‟ campaign contributions.” 

McConnell v. FEC, 540 U.S. 93, 114-15 (2003) (internal quotation marks omitted).

FECA places dollar limitations on contributions by individuals and political 

committees to candidates for federal office. 2 U.S.C. § 441a(a). Additionally, 

FECA prohibits corporations from making campaign contributions from their 

treasury funds, id. § 441b(a), and instead requires them to use a “separate 

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segregated fund” consisting of money donated by their stockholders and 

employees, id. § 441b(b)(2). FECA also limits the ways in which candidates may 

use contributions they accept, specifically barring “personal use” of such 

contributions. Id. § 439a. FECA requires that candidates for Congress designate a 

principal campaign committee and serve as an agent of that committee. Id.

§§ 432(e)(1)-(2). Principal campaign committees are responsible for complying 

with FECA‟s recordkeeping and reporting requirements and the statute‟s 

contribution restrictions. See generally id. § 432.

B. Schonberg and His Claims Regarding FECA

Schonberg was an unaffiliated candidate for the United States House of 

Representatives in Florida‟s Sixth District in 2010. (See Second Am. Compl. for 

Declaratory J. and Inj. (“Compl.”), Civil No. 10-2040, at ¶ 11 (filed Feb. 15, 2011) 

(copy attached as Exh. 2)). Schonberg lost to incumbent Representative Cliff 

Stearns, and Schonberg states that he intends to run again in 2012. (Id.)

On February 15, 2011, Schonberg filed a Second Amended Complaint 

(“Complaint”). The Complaint contains, among other things, wide-ranging 

allegations against FECA, as amended by BCRA. First, Schonberg claims that 

FECA grants an unconstitutional advantage in federal election campaigns to 

incumbents like Representative Stearns, in violation of the Fifth Amendment‟s 

guarantee of equal protection. (See, e.g., id. ¶¶ 203, 233.) Schonberg chose not to 

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accept contributions during his campaign because he asserts that they are 

“unconstitutional bribes,” which FECA allegedly authorizes corporations to give to 

incumbents and their campaign committees (see, e.g., id. ¶¶ 24, 33, 62-67, 203, 

233). Schonberg contends that this gives incumbents an unconstitutional 

“monetary campaign advantage” because FECA allows Members to use 

contributions — and allegedly other benefits, including legislative earmarks and

the Members‟ Representational Allowance — to aid their campaigns. (See, e.g., 

Compl. ¶¶ 37, 203, 218, 233, 248.) Second, the Complaint alleges that FECA 

violates the Emoluments Clause, U.S. Const. Art. I, § 6, cl. 2, and the 

Appointments Clause, id. Art. II, § 2, cl. 2, by requiring federal candidates to 

designate and become agents of a principal campaign committee, which allegedly

permits Members of Congress to appoint themselves as “Officers” of a “civil 

Office under the Authority of the United States.” (Compl. ¶¶ 205-08, 211-17, 235-

38, 241-47.) Third, the Complaint alleges that FECA violates the Ascertainment 

Clause, U.S. Const. Art. I, § 6, cl. 1, by allowing incumbents to accept campaign 

contributions and other benefits Schonberg characterizes as “unconstitutional 

compensation.” (Compl. ¶¶ 3, 209, 239.)

Schonberg contends that these alleged constitutional violations injured him 

in two ways: (1) by giving incumbent candidates a “monetary campaign 

advantage” over challengers, which supposedly benefited his opponent in the 2010

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election and will benefit him again in 2012 (“election-disadvantage injury”) (id.

¶¶ 38-44); and (2) by allowing Members of Congress to be “bribed by the health 

care industry” with contributions, resulting in a failure to pass legislation that

would provide the kind of health insurance that Schonberg and his spouse would 

prefer (“health-care injury”) (id. ¶¶ 89-104). (See also Op. at 5.)

Schonberg seeks, inter alia, a sweeping declaration that FECA is

unconstitutional and an order “freezing all the assets of all campaign committees 

under the authority of [the FEC] and ordering the funds returned to donors.” 

(Compl. at 65 ¶¶ A-D.) Schonberg also seeks to “[a]bolish[] the FEC” in order to

achieve “public-only campaign financing” which he claims will achieve his goal of 

“reduc[ing] bribery and corruption in Congress.” (Id. ¶ 249.)

The Complaint also asserts claims against the United States, challenging the 

constitutionality of the Members‟ Representational Allowance (“MRA”), 2 U.S.C. 

§ 57b, and the congressional practice of earmarking funds in legislation. The 

Department of Justice has defended the government against these claims, and they 

are therefore not further discussed here.

On March 15, 2011, the Commission moved to dismiss the Complaint‟s 

FECA and BCRA claims for lack of standing and failure to state a claim. 

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C. The District Court’s Ruling

On June 23, 2011, the district court granted the FEC‟s motion to dismiss. 

(Op. at 16.) The court held that Schonberg lacked standing because a ruling 

striking down FECA and BCRA in their entirety would not redress his alleged 

injuries. (Id. at 4-6.) Such a ruling, the court observed, “would not further 

Schonberg‟s goal of more stringent regulation of the federal campaign finance 

system and elimination of the alleged competitive advantages for incumbent 

federal candidates.” (Id. at 5 (internal quotation marks omitted).) Schonberg 

failed to show that candidates, “free from the constraints imposed by [FECA or 

BCRA,] would be more restricted in their use of campaign funds, or that the 

Constitution itself forbids the pecuniary evils of the federal campaign finance 

system that he alleges persist. To the contrary, removing these limits would 

exacerbate, rather than remedy, the perceived ills.” (Id. (internal quotation marks 

omitted; alteration in original).) The district court alternatively held that even if a 

favorable decision might arguably redress Schonberg‟s alleged competitive injury,

the Complaint nevertheless failed to state claims as to the Emoluments Clause, the 

Appointments Clause, or the Ascertainment Clause. (Id. at 6 n.3.)

1

 

1

 Even if this portion of the district court‟s opinion were not considered an 

alternative holding, on appeal the Commission may defend its victory below on 

any ground. See, e.g., U.S. v. Garrett, 720 F.2d 705, 710 (D.C. Cir. 1983).

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Schonberg filed his notice of appeal on August 7, 2011.

2

 

D. Standard of Review

This Court reviews the ruling below de novo. Stokes v. Cross, 327 F.3d 

1210, 1214 (D.C. Cir. 2003). 

ARGUMENT

I. THIS COURT SHOULD SUMMARILY AFFIRM THE RULING 

BELOW THAT SCHONBERG LACKS STANDING TO ASSERT HIS 

CLAIMS AGAINST FECA

Schonberg lacks standing because his FECA claims are not redressable and 

because he has failed to establish that he suffered an “injury in fact” that was 

caused by the conduct of which he complains. See Lujan v. Defenders of Wildlife, 

504 U.S. 555, 560-61 (1992).3

A. Schonberg’s Alleged Injuries Are Not Redressable by Any Court

The district court correctly held that a ruling invalidating FECA would not 

redress either Schonberg‟s alleged election-disadvantage or health-care injuries. 

 

2 The district court also granted the United States‟ separate motion to dismiss

the MRA and earmarking claims (Op. at 16), and Schonberg has appealed that 

ruling. Schonberg has not sought expedition in this Court as to those claims. The 

United States has informed the Commission that it intends to address those claims 

in accord with the briefing schedule this Court sets, but has authorized the 

Commission to represent that the United States supports the Commission‟s motion 

for summary affirmance as to the FECA and BCRA claims.

3 Because Schonberg lacks standing, the district court also denied his request

to trifurcate his various claims into separate proceedings and to certify his FECA 

claims to this Court sitting en banc pursuant to 2 U.S.C. § 437h. (Op. at 7 n.4.) 

That ruling should also be summarily affirmed. 

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(Op. at 4-6.) Schonberg claims that these injuries were caused by FECA‟s 

supposed authorization of campaign contributions and other allegedly 

unconstitutional benefits to incumbent officeholders, and that in the absence of this 

authorization, contributions would be banned by federal bribery laws or the 

Constitution. (See, e.g., Compl. ¶¶ 24, 38-44, 89-104, 203, 218, 233, 248.) But as 

the district court recognized, FECA does not make otherwise illegal contributions

lawful — it limits contributions, which are otherwise legal and protected, not 

banned, by the Constitution. (Op. at 5.) As a result, invalidating FECA would, 

according to Schonberg‟s theories, worsen his alleged injuries by letting

incumbents accept unlimited contributions and use them in a far greater number of 

ways, presumably even for personal use. 

Schonberg does not, and cannot, point to any provision of FECA that 

affirmatively authorizes private citizens or groups to make contributions. He 

simply assumes that FECA enables what it does not ban. However, this 

assumption “is foreign to our libertarian tradition,” since it “assumes that conduct 

is restricted except insofar as a statute permits it”; to the contrary, “[c]ampaign 

conduct is unrestricted, except to the extent that the law limits it.” Whitmore v. 

FEC, 68 F.3d 1212, 1215 (9th Cir. 1996). “People do not depend on 

Congressional „authorization,‟ as [Schonberg] assume[s], for their liberty to 

express their political preferences.” Id. Indeed, individuals and groups made 

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contributions long before FECA was enacted. See, e.g., Cal. Med. Ass’n v. FEC, 

641 F.2d 619, 623 n.2 (9th Cir. 1980) (en banc) (contributions by individuals to 

political committees were not limited before FECA), aff’d, 453 U.S. 182 (1981). 

Moreover, far from banning contributions, the Constitution protects them: 

“Spending for political ends and contributing to political candidates both fall 

within the First Amendment‟s protection of speech and political association.” FEC 

v. Colo. Republican Fed. Campaign Comm., 533 U.S. 431, 440 (2001). And 

consistent with this protected status, the Supreme Court has made clear that

“Congress has no constitutional obligation to limit contributions at all[, and] a 

candidate who wishes to restrict an opponent‟s fundraising cannot argue that the 

Constitution demands that contributions be regulated more strictly.” Davis v. FEC, 

554 U.S. 724, 737 (2008).

Finally, federal bribery laws do not ban campaign contributions — nor 

would they if FECA were struck down. Schonberg repeatedly characterizes 

campaign contributions as “bribes,” but “neither law nor morals equate all political 

contributions, without more, with bribes.” Nixon v. Shrink Mo. Gov’t PAC, 528 

U.S. 377, 390 (2000); see also U.S. v. Tomblin, 46 F.3d 1369, 1379 (5th Cir. 1995) 

(“Intending to make a campaign contribution does not constitute bribery, even 

though many contributors hope that the official will act favorably because of their 

contributions.”); U.S. v. Allen, 10 F.3d 405, 411 (7th Cir. 1993) (“[A]ccepting a 

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campaign contribution does not equal taking a bribe unless the payment is made in 

exchange for an explicit promise to perform or not perform an official act.”). 

Accordingly, if FECA‟s contribution limits were stuck down as Schonberg 

requests, individuals, corporations, and other groups could contribute unlimited 

amounts of money to incumbents, who could then use the contributions in many 

more ways.

4

 As the district court recognized, “this result would not further 

Schonberg‟s goal of more stringent regulation of the federal campaign finance 

system and elimination of the alleged competitive advantages for incumbent 

federal candidates.” (Op. at 5 (internal quotation marks omitted).) Nor would it 

lead to health-care legislation that Schonberg finds acceptable. Thus, Schonberg‟s 

alleged injuries are not redressable by any court.

B. Schonberg Also Failed To Allege a Valid Injury-In-Fact or Show 

That His Alleged Injuries Were Caused By FECA

Schonberg also lacks standing because he cannot show (1) that he suffered 

an injury-in-fact or (2) that his alleged injuries were caused by FECA.

First, Schonberg cannot demonstrate an injury-in-fact. An “injury in fact” is 

“an invasion of a legally protected interest.” Lujan, 504 U.S. at 560. Schonberg

 

4 Contrary to Schonberg‟s claims, even if FECA were invalidated, the MRA

and legislative earmarks would still exist and allegedly cause him injury. (See, 

e.g., Compl. ¶¶ 218, 248.) FECA does not regulate the MRA or earmarks at all, let 

alone “allow[]” them. (Id.) Furthermore, invalidating FECA and “[a]bolish[ing] 

the FEC” would not lead to the “public-only campaign financing” Schonberg seeks 

(id. ¶ 249), since Congress has no constitutional duty to appropriate funds to 

finance political campaigns. See Buckley, 424 U.S. at 97-98. 

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does not have a legally protected interest in having financial resources equal to his

opponents. See McConnell, 540 U.S. at 227 (holding that “an equal ability to 

participate in the election process based on . . . economic status” is not a legally 

protected interest); Sykes v. FEC, 335 F. Supp. 2d 84, 89-90 (D.D.C. 2004) 

(following McConnell in holding that an alleged “inability to compete equally 

against opponents with more money” due to FECA is not a valid injury-in-fact). 

Schonberg also fails to allege a particularized health-care injury because millions 

of other Americans could also allege that health insurance is expensive and that 

Congress has failed to enact an optimal health-care program. This alleged injury 

amounts to no more than a generalized grievance about government, which is not a 

valid injury-in-fact. See Lujan, 504 U.S. at 573-74.

Second, Schonberg cannot show that his claimed injuries were caused by 

FECA rather than the result of independent action by “third part[ies] not before the 

court.” Id. at 560. As explained supra Part I.A., FECA did not cause Schonberg‟s

alleged injuries because the statute does not authorize contributions in general or 

require anyone in particular to give contributions to his opponent or withhold them 

from him. Instead, Schonberg‟s alleged electoral disadvantage was caused by his 

own choice not to accept campaign contributions, and by the independent decisions 

of individuals and groups to contribute money to his opponent. Cf. McConnell, 

540 U.S. at 228 (no causation where plaintiffs‟ “alleged inability to compete stems 

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not from the operation of [FECA], but from their own personal „wish‟ not to solicit 

or accept large contributions, i.e., their personal choice”). Schonberg‟s alleged

health-care injury similarly results not from FECA, but from the vast number of 

third parties involved in passing (or not passing) legislation. See, e.g., Page v. 

Shelby, 995 F. Supp. 23, 29 (D.D.C. 1998) (“[A]ny possible injury suffered by 

[plaintiff] stemming from the failure of unspecified legislation to be enacted is far 

too remote to satisfy [the causation] element of standing.”).

In sum, the Court should summarily affirm the district court‟s ruling that 

Schonberg lacks standing because he cannot meet any of the three requirements 

under Article III: injury-in-fact, causation, or redressability.

II. THE COMPLAINT FAILS TO STATE A CLAIM AGAINST FECA 

OR BCRA 

Although the district court‟s ruling on standing was sufficient to dispose of 

the Complaint‟s claims against FECA (as amended by BCRA), its alternative 

holding that the Emoluments, Appointments, and Ascertainment Clause allegations 

fail to state a claimshould also be summarily affirmed because Schonberg can

“prove no set of facts in support of his claim[s] which would entitle him to relief.” 

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Browning v. Clinton, 292 F.3d 235, 242 (D.C. Cir. 2002).5 The Complaint also 

fails to state a valid Fifth Amendment claim.

A. The District Court Correctly Dismissed the Emoluments and

Appointments Clause Claims Against FECA

Schonberg invokes various constitutional clauses to challenge FECA, but his 

arguments rest largely on the frivolous assertion that federal candidates act as 

“officers” of the United States when they serve as agents of their own campaign 

committees.

The Appointments Clause mandates that the President, with the advice and 

consent of the Senate, shall appoint “Officers of the United States.” U.S. Const. 

Art. II, § 2, cl. 2. What Schonberg refers to as the Emoluments Clause bars sitting

Members of Congress from being “appointed to any civil Office under the 

 

5 After finding Schonberg lacked standing, the district court considered the 

merits of the Emoluments, Appointments, and Ascertainment Clause claims 

because “[a]rguably, a favorable decision might redress any competitive 

disadvantage Schonberg suffers from the existence of campaign committees, since 

such committees would not exist absent their authorization in FECA.” (Op. at 6 

n.3.) However, this is incorrect. First, campaign committees could exist absent 

FECA, as they existed before FECA. See Cal. Med. Ass’n, 641 F.2d at 623 n.2 

(political committees existed before FECA). Second, even if campaign 

committees did not exist, Schonberg‟s alleged injuries would still not be redressed 

since they arise not from the existence of campaign committees per se, but from 

their ability to accept and spend contributions and other benefits on behalf of 

incumbents. (See, e.g., Compl. ¶¶ 213, 243.) Absent committees, incumbentcandidates themselves could still accept and spend contributions, allegedly injuring 

Schonberg. (See, e.g., id. ¶ 43.) Finally, even if Schonberg‟s alleged injuries were 

redressable, he would still lack standing for failure to show a valid injury-in-fact 

caused by FECA. See supra Part I.B.

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Authority of the United States.” U.S. Const. Art. I, § 6, cl. 2. Schonberg contends 

that FECA‟s requirement that a candidate act as an agent of his or her principal 

campaign committee, see 2 U.S.C. § 432(e)(2), violates these Clauses because it 

allows Members of Congress to appoint themselves as “Officers of the United 

States,” and to a “civil Office under the Authority of the United States.” (Compl. 

¶¶ 205-08, 211-17, 235-38, 241-47.)

However, as the Supreme Court has explained while interpreting the 

Emoluments and Appointments Clauses, to qualify as an officer of the United 

States an appointee must “exercis[e] significant authority pursuant to the laws of 

the United States.” Buckley, 424 U.S. at 124-26; see id. at 140-41 (holding that 

FEC Commissioners are “Officers” since they perform a “significant governmental 

duty exercised pursuant to a public law”). As the district court explained, 

Schonberg cannot demonstrate that “incumbents exercise any, yet alone 

significant, authority of the United States as agents of their campaign committees.” 

(Op. at 6 n.3.) Political committees are private entities, which FECA regulates. 

Cf. Johnson v. Knowles, 113 F.3d 1114, 1118 (9th Cir. 1997) (“[C]ommittees of 

political parties are private actors, not public agencies, even though they are 

regulated by the state.”). They perform no governmental duties, but merely receive 

and spend campaign money and report that activity to the Commission on behalf of 

a candidate for office. See 2 U.S.C. § 432. Thus, candidates who serve as agents

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for their campaign committees under section 432(e)(2) are not “Officers” under the 

Appointments Clause nor do they hold an “Office” under the Emoluments Clause.

B. The District Court Correctly Dismissed the Ascertainment 

Clause Claim Against FECA

The district court also correctly dismissed Schonberg‟s claim that FECA 

violates the Ascertainment Clause because it allegedly allows Members of 

Congress to accept “unconstitutional compensation” in the form of campaign 

contributions and other benefits as candidates and officeholders. (Op. at 6 n.3; 

Compl. ¶¶ 3, 209, 239.) The Ascertainment Clause states that “[t]he Senators and 

Representatives shall receive a Compensation for their Services, to be ascertained 

by Law, and paid out of the Treasury of the United States.” Art. I, § 6, cl. 1. But 

as the district court observed, the Clause “does not provide a substantive limit on 

the amount or Congressional source of members‟ compensation.” (Op. at 6 n.3.) 

The Clause merely serves “to affix political responsibility for the level of 

Members‟ pay ultimately with Congress itself.” Humphrey v. Baker, 848 F.2d 211, 

215 (D.C. Cir. 1988). Thus, even if FECA authorized candidates and their 

committees to accept contributions — which it does not, see supra Part I.A — and 

even if campaign contributions were “compensation” to a Member — which they 

are not, see 2 U.S.C. § 439a(b) (prohibiting candidates from using contributions for 

personal use) — Schonberg‟s Ascertainment Clause claim would still fail because 

the Clause does not limit the receipt of compensation by Members of Congress.

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C. The Complaint Fails to State a Fifth Amendment Claim

Although the district court properly dismissed Schonberg‟s Fifth 

Amendment claim for lack of standing, the allegation also fails to state a valid

equal protection claim, since FECA treats incumbents and challengers the same. 

See Cal. Med. Ass’n, 453 U.S. at 200 (an essential element of an equal protection 

claim is that the challenged statute treats similarly situated entities differently); 

Buckley, 424 U.S. at 30-33 (rejecting the argument that FECA‟s contribution limits 

“work . . . an invidious discrimination between incumbents and challengers”; 

explaining that “the Act applies the same limitations on contributions to all 

candidates”). 

CONCLUSION

 For the foregoing reasons, this Court should summarily affirm the district 

court‟s grant of the Commission‟s motion to dismiss. 

Respectfully submitted,

Anthony Herman

General Counsel

David Kolker 

Associate General Counsel

/s/ Harry J. Summers 

Harry J. Summers 

Assistant General Counsel 

Robert W. Bonham III 

Senior Attorney

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Kevin P. Hancock

Attorney

September 22, 2011 FEDERAL ELECTION COMMISSION

999 E Street, N.W.

Washington, D.C. 20463

(202) 694-1650 

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CERTIFICATE OF SERVICE

I hereby certify that on September 22, 2011, I will file the foregoing 

electronically via the Court‟s ECF system pursuant to D.C. Cir. R. 25(a), 

I will cause four paper copies to be hand-delivered to the Court pursuant to 

D.C. Cir. R. 27(b), and I will serve a copy on the following by e-mail pursuant to 

Fed. R. App. P. 25(c)(1)(D):

Steve Schonberg, Sschonberg@aol.com

/s/ Harry J. Summers 

Harry J. Summers 

Assistant General Counsel 

FEDERAL ELECTION COMMISSION

999 E Street NW

Washington, DC 20463

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