*Enclosures and attachments identified with an asterisk are not included in the administrative 

record.

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

 

 ) 

PUBLIC CITIZEN, et al., ) 

 ) 

 Plaintiffs, ) Civ. No. 14-148 (RJL) 

 ) 

 v. ) 

 ) 

FEDERAL ELECTION COMMISSION, ) AMENDED CERTIFIED LIST OF 

 ) CONTENTS OF ADMINISTRATIVE 

 ) RECORD 

 Defendant. ) 

 ) 

DEFENDANT FEDERAL ELECTION COMMISSION’S AMENDED 

CERTIFIED LIST OF CONTENTS OF THE ADMINISTRATIVE RECORD 

 The Federal Election Commission (“FEC” or “Commission”), by its Secretary and Clerk, 

hereby certifies that the documents listed below constitute the administrative record in Matter 

Under Review (“MUR”) 6396. See LCvR 7(n)(1). The pages, beginning with the prefix “AR,” 

have been sequentially numbered from AR 1-564. 

Included in the administrative record for this case are some documents from MUR 6368, 

a small portion of which concerned allegations similar to those at issue in MUR 6396 that 

accordingly were severed from that matter and merged into MUR 6396. Documents concerning 

the allegations originally presented in MUR 6368 that were subsequently severed and merged 

into MUR 6396 are included at pages AR 519-64. 

1. Administrative Complaint (date-stamped Oct. 13, 2010). AR 1-22 

2. Letter from Jeff Jordan, Supervisory Attorney, FEC 

Complaints Examination & Legal Administration Division, to 

Kevin Zeese, Complainant (date-stamped Oct. 21, 2010) 

(acknowledging receipt of administrative complaint) and 

Enclosure* (description of FEC procedures for handling 

complaints). 

AR 23 

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3. Letter from Jeff Jordan, Supervisory Attorney, FEC 

Complaints Examination & Legal Administration Division, to 

Glen Allen, CT Corporation System (date-stamped Oct. 21, 

2010) (advising of receipt of administrative complaint) and 

Enclosures* (copy of Administrative Complaint included at 

AR 1-22; description of FEC procedures for handling 

complaints and Designation of Counsel form). 

AR 24-25 

4. Letter from Thomas Josefiak and Michael Bayes, Counsel for 

Crossroads Grassroots Policy Strategies (“Crossroads GPS”), 

to Christopher Hughey, Esq., FEC Acting General Counsel 

(dated Oct. 28, 2010) (requesting extension of time to respond 

re: FEC letter advising of administrative complaint) and 

Enclosure (completed Designation of Counsel form). 

AR 26-27 

5. Letter from Frankie Hampton, Paralegal, FEC Complaints 

Examination & Legal Administration Division, to Thomas 

Josefiak and Michael Bayes, Counsel for Crossroads GPS 

(dated Nov. 4, 2010) (notifying that requested extension of 

time was granted) and Attachment (tolling agreement). 

AR 28-29 

6. Letter from Michael Bayes, Counsel for Crossroads GPS, to 

Frankie Hampton, Paralegal, FEC Complaints Examination & 

Legal Administration Division (dated Nov. 9, 2010) (noting 

enclosure of signed tolling agreement) and Enclosure (signed 

copy of tolling agreement (dated Nov. 9, 2010)). 

AR 30-31 

7.

8.

Response of Crossroads GPS (Letter from Thomas Josefiak 

and Michael Bayes, Counsel to Crossroads GPS, to 

Christopher Hughey, Esq., FEC Acting General Counsel (dated 

Dec. 22, 2010)) and Attachments (materials referenced in 

Response). 

Email from Mike Bayes, Counsel to Crossroads GPS, to 

Christopher Hughey, Kathleen Guith, and Frankie Hampton in 

the FEC Office of General Counsel, with copies to Tom 

Josefiak and Mike Bayes, re: Crossroads GPS response (dated 

Dec. 22, 2010) (noting dispatch of hard copy of response for 

delivery on December 23, 2010) and Attachment* (Response 

of Crossroads GPS and attachments thereto, included at AR 

32-90). 

AR 32-90 

AR 91 

9. FEC First General Counsel’s Report and proposed Factual and 

Legal Analyses (date-stamped June 22, 2011), later withdrawn. 

AR 91.1-91.76 

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10. Supplemental Response of Crossroads GPS (Letter from 

Thomas Josefiak and Michael Bayes, Counsel to Crossroads 

GPS, to Christopher Hughey, Esq., FEC Acting General 

Counsel (dated Sept. 9, 2011)) and Exhibits 1-21. 

AR 92-176 

11. Letter from Mark Shonkwiler, FEC Assistant General Counsel 

for Enforcement, to Thomas Josefiak and Michael Bayes, 

Counsel to Crossroads GPS (attaching articles that the FEC’s 

Office of General Counsel reviewed and inviting Crossroads 

GPS to submit any supplemental response by Oct. 11, 2011). 

AR 177-227

12. Letter from Thomas Josefiak and Michael Bayes, Counsel to 

Crossroads GPS, to Mark Shonkwiler, FEC Assistant General 

Counsel for Enforcement (dated Oct. 10, 2011) (supplementing 

Crossroads GPS’s prior responses). 

AR 228-37 

13. Letter from William Powers, Staff Attorney, FEC Enforcement 

Division, to Thomas Josefiak and Michael Bayes, Counsel to 

Crossroads GPS (dated Jan. 17, 2012) (providing status report). 

AR 238 

14. Letter from Thomas Josefiak and Michael Bayes, Counsel to 

Crossroads GPS, to Anthony Herman, FEC General Counsel, 

copying FEC Chair Caroline Hunter and FEC Vice Chair Ellen 

Weintraub (dated Apr. 23, 2012) (enclosing two of Crossroads 

GPS’s IRS Form 990 annual returns filed with the Internal 

Revenue Service). 

AR 239-339 

15. FEC First General Counsel’s Report and proposed Factual and 

Legal Analysis (date-stamped Nov. 21, 2012). 

AR 340-93 

16. Letter from Peter Reynolds, Staff Attorney, FEC Enforcement 

Division, to Thomas J. Josefiak and Michael Bayes, Counsel to 

Crossroads GPS (dated Jan. 23, 2013) (providing status report). 

AR 394 

17. Certification by the FEC Deputy Secretary of Commissioners’ 

December 3, 2013 votes in MUR 6396 (certification signed 

and dated Dec. 5, 2013). 

AR 395 

18. Letter from William Powers, Assistant General Counsel, FEC 

Enforcement Division, to Corey Platt, Missouri Democratic 

Party, Complainant (date-stamped Dec. 12, 2013) (providing 

notification of file closure and noting severance and 

subsequent merger of allegations originally asserted in MUR 

6368 into MUR 6396). 

AR 396 

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19. Letter from William Powers, Assistant General Counsel, FEC 

Enforcement Division, to Kevin Zeese, Complainant (datestamped Dec. 12, 2013) (providing notification of file closure). 

AR 397 

20. Letter from William Powers, Assistant General Counsel, FEC 

Enforcement Division, to Thomas Josefiak and Michael Bayes, 

Counsel to Crossroads GPS (date-stamped Dec. 12, 2013) 

(providing notification of file closure). 

AR 398 

21. Letter from William Powers, Assistant General Counsel, FEC 

Enforcement Division, to Craig Holman, Complainant (datestamped Dec. 23, 2013) (providing notification of file closure). 

AR 399 

22. Statement of Reasons of FEC Chairman Lee E. Goodman and 

Commissioners Caroline C. Hunter and Matthew S. Petersen 

(signed and dated Jan. 8, 2014) and Attachment (copy of First 

General Counsel’s Report (dated June 22, 2011), later 

withdrawn). 

AR 400-504 

23. Statement of Reasons of FEC Vice Chair Ann M. Ravel, 

Commissioner Steven T. Walther, and Commissioner Ellen L. 

Weintraub (signed and dated Jan. 9 and 10, 2014). 

AR 505-09 

24. Letter from William Powers, Assistant General Counsel, FEC 

Enforcement Division, to Kevin Zeese, Complainant (datestamped Jan. 17, 2014) and Enclosures* (copies of 

Commissioners’ statements of reasons included at AR 400-504 

and AR 505-09). 

AR 510 

25. Letter from William Powers, Assistant General Counsel, FEC 

Enforcement Division, to Kevin Zeese, Complainant (datestamped Jan. 17, 2014) and Enclosures* (copies of 

Commissioners’ statements of reasons included at AR 400-504 

and AR 505-09). 

AR 511 

26. Letter from William Powers, Assistant General Counsel, FEC 

Enforcement Division, to Craig Holman, Complainant (datestamped Jan. 17, 2014) and Enclosures* (copies of 

Commissioners’ statements of reasons included at AR 400-504 

and AR 505-09). 

AR 512 

27. Letter from William Powers, Assistant General Counsel, FEC 

Enforcement Division, to Corey Platt, Missouri Democratic 

Party, Complainant (date-stamped Jan. 17, 2014) and 

Enclosures* (copies of Commissioners’ statements of reasons 

included at AR 400-504 and AR 505-09). 

AR 513 

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28. Letter from William Powers, Assistant General Counsel, FEC 

Enforcement Division, to Thomas Josefiak and Michael Bayes, 

Counsel to Crossroads GPS (date-stamped Jan. 17, 2014) and 

Enclosures* (copies of Commissioners’ statements of reasons 

included at AR 400-504 and AR 505-09). 

AR 514 

29. Supplemental Statement of Reasons of FEC Chairman Lee E. 

Goodman and Commissioners Caroline C. Hunter and 

Matthew S. Petersen (signed and dated Mar. 25, 2014). 

AR 515-18 

Documents from MUR 63681 

30. Administrative Complaint (date-stamped Sept 2, 2010). AR 519-24 

31. Letter from Jeff Jordan, Supervisory Attorney, FEC 

Complaints Examination & Legal Administration Division, to 

Corey Platt, Complainant (date-stamped Sept. 8, 2010) 

(acknowledging receipt of administrative complaint) and 

Enclosure* (description of FEC procedures for handling 

complaints).

AR 525 

32. Letter from Jeff Jordan, Supervisory Attorney, FEC 

Complaints Examination & Legal Administration Division, to 

Glen Allen, CT Corporation System (date-stamped Sept. 8, 

2010) (advising of receipt of administrative complaint) and 

Enclosures* (copy of Administrative Complaint included at 

AR 520-25; description of FEC procedures for handling 

complaints and Designation of Counsel form). 

AR 526-27 

33. Letter from Thomas Josefiak and Michael Bayes, Counsel to 

Crossroads GPS, to Christopher Hughey, Esq., FEC Acting 

General Counsel (dated Sept. 16, 2010) (requesting extension 

of time to respond re: FEC letter advising of administrative 

complaint) and Enclosure (completed Designation of Counsel 

form). 

AR 528-29 

34. Letter from Frankie Hampton, Paralegal, FEC Complaints 

Examination & Legal Administration Division, to Thomas 

Josefiak and Michael Bayes, Counsel to Crossroads GPS 

(dated Sept. 21, 2010) (notifying that requested extension of 

AR 530 

                                                           

1

   As explained earlier, these documents concern allegations from MUR 6368 that were 

severed from that MUR and merged into MUR 6396, as well as other alleged violations that 

were not merged into MUR 6396. The complete versions of the documents are included because 

the relevant portions are not easily segregable from the portions involving allegations that are not 

at issue in this case. 

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