IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

__________________________________________ 

) 

RUDY TAKALA ) 

1100 First Street, NE #913 ) 

Washington, DC 20003, ) 

) 

Plaintiff, ) 

) 

v. ) Civil Action No. 17-1715

) 

FEDERAL ELECTION COMMISSION ) 

999 E Street, NW ) 

Washington, DC 20004, ) 

) 

Defendant. ) 

__________________________________________) 

COMPLAINT 

1. Plaintiff Rudy Takala (“Mr. Takala”) brings this action under the Freedom of

Information Act (“FOIA”), 5 U.S.C. § 552, seeking access to Defendant Federal Election 

Commission (“FEC”) records revealing, inter alia, taxpayer money spent on political and other 

travel expenses.

2. Mr. Takala submitted a FOIA request seeking access to these records but the FEC

has failed to comply with FOIA’s statutory deadlines. 

JURISDICTION AND VENUE

3. Jurisdiction is asserted pursuant to 28 U.S.C. § 1331 and 5 U.S.C. § 552(a)(4)(B).

4. Venue is proper pursuant to 28 U.S.C. § 1391(e) and 5 U.S.C. § 552(a)(4)(B).

PARTIES 

5. Plaintiff Rudy Takala in an associate editor at The Hill newspaper, a position he

has held since November 2016. He was previously a reporter at the Washington Examiner, and it 

was in that capacity that he filed the FOIA request at issue. His focus at both publications has 

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included technology, cybersecurity, and federal regulatory agencies, including the Federal 

Communications Commission and the FEC. He has used FOIA in both positions to engage in 

investigative activity relevant to his work. 

6. Defendant FEC is an agency within the meaning of 5 U.S.C. § 552(f)(1). It has 

possession, custody, and control of records to which Mr. Takala seeks access and that are the 

subject of this Complaint.

FACTS

7. By letter, dated October 21, 2016, Mr. Takala sent a FOIA request to the FEC 

seeking access to records related to, inter alia, expenses incurred for FEC travel. Text of 

original request reproduced as Ex. 1; see also Ex. 2.

8. Specifically, the request sought the following records: 

a. All receipts, reimbursement forms, or other documents identifying the 

amounts sought by or paid to commissioners Matthew Petersen, Steven 

Walther, Lee Goodman, Caroline Hunter, Ellen Weintraub, and Ann Ravel to 

attend the 2016 Republican or Democratic conventions.

b. All receipts, reimbursement forms, or other documents identifying the 

amounts sought by or paid to any commission staff (including a 

commissioner’s staffer) to attend the 2016 Republican or Democratic 

Conventions.

c. A copy of any document listing all FEC Commissioners, members of their 

staff, or other FEC employees who attended either the 2016 Republican or 

Democratic Conventions.

d. A copy of the most recent report used by FEC staff to track the status of 

pending FOIA requests.

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e. All documents produced pursuant to a FOIA request made within the past 

seven years by: Center for Public Integrity, the Wall Street Journal, NBC 

News, Fox News, CBS News, CNN, the Republican National Lawyers 

Association, the Democratic National Committee, or the Foundation for 

Accountability and Civic Trust.

f. All communications between Commissioner Ravel and (A) the White House 

and (B) any current or former member of Commissioner Ravel’s staff about 

Commissioner Ravel visiting the White House or meeting with White House 

personnel or the President himself.

g. All emails between Commissioner Ravel and anyone at an email address 

ending in @doj.ca.gov, @governor.ca.gov, or fppc.ca.gov.

h. All emails between Commissioners Goodman, Petersen, or Hunter and anyone 

at an email address ending in @doj.wi.gov or @doj.fl.gov.

i. All emails or documents in the possession of Commissioner Ravel, her staff, 

or FEC staff more generally concerning her October 2 travels to Columbia 

regarding the plebiscite, “Final Agreement for the Termination of Conflict and 

Construction of a Stable and Lasting Peace.”

9. For fee purposes, Mr. Takala sought to be classified as a representative of the 

news media. Ex. 1 at 2.

10. Mr. Takala also requested a public-interest fee waiver. Ex. 1 at 2.

11. By email, dated November 17, 2016, the FEC acknowledged receipt of the FOIA 

request, assigned it case number 2017-003, and invoked a ten-day statutory extension for its 

response deadline. Ex. 2. 

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12. By email, dated December 6, 2016, the FEC invoked a second response extension, 

invited Mr. Takala to narrow the scope of this request, and provided an estimated response 

deadline of December 23, 2016. Ex 3.

13. Mr. Takala did not narrow the scope of his request in response to this email from 

the FEC.

14. Mr. Takala has received one production of responsive documents.

15. The FEC has not reached a final determination on this request, otherwise 

completed production, or responded to Mr. Takala’s fee waiver and classification requests.

COUNT 1

Violation of the FOIA: Failure to Comply with Statutory Deadlines

16. Mr. Takala repeats all of the above paragraphs.

17. The FOIA requires agencies to respond to requests within twenty (20) business 

days or, in “unusual circumstances,” within thirty (30) business days. 5 U.S.C. §§ 552(a)(6)(A)–

(B). 

18. More than thirty (30) business days have passed since the FEC received the FOIA 

request at issue in this suit.

19. The FEC has not issued a final determination on the FOIA request at issue within 

the applicable statutory time limits. The FEC, therefore, has failed to comply with the FOIA’s 

statutory deadline to issue a final determination.

20. Mr. Takala has exhausted his administrative remedies under 5 U.S.C. 

§ 552(a)(6)(C).

RELIEF REQUESTED

WHEREFORE, Plaintiff Rudy Takala respectfully requests and prays that this Court:

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a. order the FEC to issue a final determination within twenty (20) business days of 

the date of the Order;

b. order the FEC to produce all responsive, non-exempt records promptly after 

issuing the final determination;

c. award Mr. Takala his costs and reasonable attorney fees incurred in this action, 

pursuant to 5 U.S.C. § 552(a)(4)(E); and

d. grant such other relief as the Court may deem just and proper.

Date: August 23, 2017 Respectfully submitted,

/s/ R. James Valvo, III 

R. James Valvo, III (D.C. Bar No. 1017390)

Lee A. Steven (D.C. Bar No. 468543)

CAUSE OF ACTION INSTITUTE

1875 Eye St., NW, Suite 800

Washington, DC 20006

Telephone: (202) 499-4232

Facsimile: (202) 330-5842

james.valvo@causeofaction.org

lee.steven@causeofaction.org

Counsel for Plaintiff Rudy Takala

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