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UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Alexandria Division 

_______________________________________ 

 ) 

STOP RECKLESS ECONOMIC ) Civ. No. 1:14-397 (AJT-IDD) 

INSTABILITY CAUSED BY DEMOCRATS, ) 

NIGER INNIS, NIGER INNIS FOR ) 

CONGRESS, TEA PARTY LEADERSHIP ) 

FUND, and ALEXANDRIA REPUBLICAN ) 

CITY COMMITTEE, ) 

 ) 

Plaintiffs, ) 

 ) 

 v. ) 

 ) 

FEDERAL ELECTION COMMISSION, ) 

 ) 

 Defendant. ) 

_______________________________________) 

 

MOTION OF PLAINTIFFS STOP RECKLESS ECONOMIC INSTABILITY 

CAUSED BY DEMOCRATS, TEA PARTY LEADERSHIP FUND, AND 

ALEXANDRIA REPUBLICAN CITY COMMITTEE TO AMEND AND/OR 

SUPPLEMENT COMPLAINT PURSUANT TO FED. R. CIV. P. 15(a) and/or (d) 

 Plaintiffs Stop Reckless Economic Instability Caused by Democrats (“Stop PAC”), Tea 

Party Leadership Fund (“the Fund”), and Alexandria Republican City Committee (“ARCC”) 

respectfully move that this Court accept the attached exhibit as an Amended Complaint pursuant 

to Fed. R. Civ. P. 15(a)(1)(B). That Rule provides, “A party may amend its pleading once as a 

matter of course within . . . , 21 days after service of a responsive pleading.” 

 In the alternative, Plaintiffs Stop PAC, the Fund, and ARCC respectfully request that this 

Court accept the attached exhibit as an Amended and Supplemental Complaint pursuant to Fed. 

R. Civ. P. 15(a)(2) and (d). 

Case 1:14-cv-00397-AJT-IDD Document 36 Filed 07/07/14 Page 1 of 3 PageID# 287
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 The proposed new complaint also is attached as Exhibit 1 and the “red line” tracked 

changes version as Exhibit 2. A Memorandum in Support of Plaintiffs’ Motion and Proposed 

Order are attached. 

 Plaintiffs met and conferred by telephone on July 3, 2014. Defendant Federal Election 

Commission has not consented to this motion. 

 The parties agree that no hearing or oral argument is required on this motion. 

Dated this 7th day of July 2014. 

 

 Respectfully submitted, 

 

 /s/ Michael T. Morley 

 Michael T. Morley, Esq. 

 Virginia State Bar # 65762 

 COOLIDGE-REAGAN FOUNDATION

 1629 K Street, Suite 300 

 Washington, DC 20006 

 Phone: (202) 603-5397 

 Fax: (202) 331-3759 

 E-mail: Morley@coolidgereagan.org 

 /s/ Dan Backer 

 Dan Backer, Esq. 

 Virginia State Bar # 78256 

 DB CAPITOL STRATEGIES PLLC 

 203 South Union Street, Suite 300 

 Alexandria, VA 22314 

 Phone: (202) 210-5431 

 Fax: (202) 478-0750 

 E-mail: DBacker@DBCapitolStrategies.com

Attorneys for Plaintiffs 

 

 

Case 1:14-cv-00397-AJT-IDD Document 36 Filed 07/07/14 Page 2 of 3 PageID# 288
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CERTIFICATE OF SERVICE

 I, Dan Backer, hereby certify that on this 7th day of July 2014, I did cause a true and 

complete copy of the foregoing Motion of Plaintiffs Stop Reckless Economic Insecurity Caused 

by Democrats, Tea Party Leadership Fund, and Alexandria Republican City Committee to 

Amend and/or Supplement Complaint Pursuant to Fed. R. Civ. P. 15(a) and/or (d); the exhibits 

thereto, supporting memorandum, and proposed order to be electronically filed with the Clerk of 

Court using the CM/ECF system, which will then send a notification of such filing to the 

following counsel for the plaintiff: 

 Kevin Deeley 

 Harry J. Summers 

 Holly J. Baker 

 Kevin P. Hancock 

 Esther D. Gyory 

 FEDERAL ELECTION COMMISSION 

 999 E Street, N.W. 

 Washington, D.C. 20463 

 /s/ Dan Backer 

 Dan Backer 

 Virginia State Bar # 78256 

Attorney for Plaintiffs

Case 1:14-cv-00397-AJT-IDD Document 36 Filed 07/07/14 Page 3 of 3 PageID# 289