UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

 

 ) 

CENTER FOR COMPETITIVE POLITICS, ) 

 ) 

 Plaintiff, ) Civ. No. 14-970 (RDM) 

 ) 

 v. ) 

 ) STIPULATION OF 

FEDERAL ELECTION COMMISSION, ) DISMISSAL 

 ) 

 Defendant. ) 

 ) 

STIPULATION OF DISMISSAL 

On December 4, 2015, Judge Richard J. Leon issued a minute order in Public Citizen v. 

FEC, No. 14-148 (D.D.C.), ordering the Commission to file in Public Citizen “a complete 

administrative record, including the First General Counsel’s Report and accompanying Factual 

and Legal Analysis circulated to the Federal Election Commission on or about June 21, 2011, 

and certify the same.”1

 Minute Order, Public Citizen v. FEC, No. 14-148 (D.D.C. Dec. 4, 2015) 

(attached as Exhibit 1). 

 

1

 In both Public Citizen and here, the Commission argued that the June 2011 Report and its 

accompanying documents were protected from release by the work product doctrine and the 

deliberative process privilege. Federal Election Commission’s Opposition to Crossroads 

Grassroots Policy Strategies’ Motion to Supplement the Administrative Record, at 15-24 (ECF 

No. 45), Public Citizen v. FEC, No. 14-148 (D.D.C. Aug. 24, 2015). In Public Citizen, 

intervenor Crossroads Grassroots Policy Strategies (“Crossroads“) argued that the June 2011 

Report was not protected by those privileges and that even if it were, Crossroads’s alleged 

“particularized need” for the report overcame both privileges. Crossroads Grassroots Policy 

Strategies’ Motion to Direct the Federal Election Commission to Complete the Administrative 

Record, at 10 (ECF No. 42), Public Citizen v. FEC, No. 14-148 (D.D.C. Aug. 8, 2015). The 

Minute Order issued in Public Citizen does not indicate the basis for the court’s order that the 

Commission include the June 2011 Report in the administrative record in that case. 

Case 1:14-cv-00970-RDM Document 16 Filed 12/16/15 Page 1 of 3
2 

In light of that order, which requires the public filing in the Public Citizen litigation of 

the same document requested here, the Commission has provided Plaintiff Center for 

Competitive Politics (“CCP”) with a copy of the report. 

In light of the foregoing, plaintiff CCP and defendant Federal Election Commission 

hereby jointly stipulate to the dismissal of this action pursuant to Federal Rule Civil Procedure 

41(a)(1)(A)(ii). As a stipulation made pursuant to Rule 41(a)(1)(A)(ii), this dismissal is effective 

without court order. Each side bears its own fees and costs. 

Respectfully submitted, 

/s/ Allen Dickerson

Allen Dickerson 

(D.C. Bar No. 1003781) 

Center for Competitive Politics 

124 S. West Street, Suite 201 

Alexandria, VA 22314 

Telephone: (703) 894-6800 

Fax: (703) 894-6811 

adickerson@campaignfreedom.org 

Counsel for Plaintiff 

Center for Competitive Politics

Daniel A. Petalas 

(D.C. Bar No. 467908) 

Acting General Counsel 

dpetalas@fec.gov 

Lisa Stevenson 

Deputy General Counsel — Law 

(D.C. Bar No. 457628) 

lstevenson@fec.gov 

Kevin Deeley 

Acting Associate General Counsel 

kdeeley@fec.gov 

/s/ Erin Chlopak

Erin Chlopak 

Acting Assistant General Counsel 

(D.C. Bar No. 496370) 

echlopak@fec.gov 

Case 1:14-cv-00970-RDM Document 16 Filed 12/16/15 Page 2 of 3
3 

Steve Hajjar 

Attorney 

shajjar@fec.gov 

Federal Election Commission 

999 E Street, N.W. 

Washington, DC 20463 

(202) 694-1650 

 Counsel for Defendant 

 Federal Election Commission 

December 16, 2015 

Case 1:14-cv-00970-RDM Document 16 Filed 12/16/15 Page 3 of 3
U.S. District Court

District of Columbia (Washington, DC)

CIVIL DOCKET FOR CASE #: 1:14ícví00148íRJ

PUBLIC CITIZEN et al v. FEDERAL ELECTIONCOMMISSIONAssigned to: Judge Richard J. Leon

Case in other court: USCA, 14í05199

Cause: 02:431 Fed. Election Commission: Failure Enforce C

Date Filed: 01/31/20Jury Demand: NoneNature of Suit: 890 OActionsJurisdiction: U.S. Go

Date Filed # Docket Text

12/04/2015 MINUTE ORDER granting 42 Crossroads Grassroots Policy Stra

Direct the Federal Election Commission to Complete the Adminishereby ORDERED that this motion is GRANTED. It is further Odefendant Federal Election Commission shall file a complete admincluding the First General Counsel's Report and accompanying FAnalysis circulated to the Federal Election Commission on or abocertify the same. It is further ORDERED that the parties shall subscheduling order to govern summary judgment briefing within 30 this Order. SO ORDERED. Signed by Judge Richard J. Leon on 1(Entered: 12/04/2015)

Case 1:14-cv-00970-RDM Document 16-1 Filed 12/16/15 Page 1 of 1