UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

 

 ) 

CHRIS RUFER, et al., ) 

 ) 

 Plaintiffs, ) Civ. No. 14-837 (CRC) 

 ) 

 v. ) 

 ) 

FEDERAL ELECTION COMMISSION, ) ANSWER 

 ) 

 Defendant. ) 

 ) 

DEFENDANT FEDERAL ELECTION COMMISSION’S 

ANSWER TO PLAINTIFFS’ COMPLAINT 

Defendant Federal Election Commission (“FEC” or “Commission”) submits this answer 

to plaintiffs’ Complaint (Docket No. 1). Any allegation not specifically responded to below, 

including allegations that appear in headings, is DENIED. The Commission responds as 

follows: 

1. This paragraph contains plaintiffs’ characterizations of unspecified judicial 

decisions and conclusions of law concerning the Federal Election Campaign Act of 1971, as 

amended, 2 U.S.C. §§ 431-57 (“FECA”), to which no response is required. To the extent a 

response is required: Admit that this paragraph appears to characterize portions of the holdings 

in Buckley v. Valeo, 424 U.S. 1 (1976), and Citizens United v. FEC, 558 U.S. 310 (2010), which 

speak for themselves. The phrase “maximum constitutional protection” is plaintiffs’ 

characterization and is not a quote from these judicial opinions. 

2. This paragraph contains plaintiffs’ characterizations of an unspecified judicial 

decision and conclusions of law, to which no response is required. To the extent a response is 

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required: Admit that this paragraph appears to characterize portions of holdings in Carey v. 

FEC, 791 F. Supp. 2d 121 (D.D.C. 2011), which speaks for itself. 

3. The first sentence of this paragraph contains plaintiffs’ characterizations of a 

judicial decision, to which no response is required. To the extent a response is required: Admit 

that the first sentence of this paragraph appears to characterize the holding in Colorado 

Republican Federal Campaign Committee v. FEC, 518 U.S. 604 (1996) (“Colorado I”), which 

speaks for itself. Deny the second and third sentences of this paragraph. 

4. Admit that this is a constitutional challenge to a federal statute and that this Court 

has jurisdiction over the claims of the Libertarian Party of Indiana pursuant to 28 U.S.C. § 1331 

and 28 U.S.C. §§ 2201-02. Pursuant to Wagner v. FEC, 717 F.3d 1007 (D.C. Cir. 2013),

jurisdiction over the claims of plaintiffs Chris Rufer and Libertarian National Congressional 

Committee Inc. exists only to the extent provided in 2 U.S.C. § 437h. 

5. Deny that this Court has jurisdiction under the Bipartisan Campaign Reform Act 

(“BCRA”), Pub. L. No. 107-155, § 403(a)(1), 116 Stat. 81, 113-14, because plaintiffs’ claims are 

neither substantial nor justiciable under that special review provision. Admit that venue is 

proper under 28 U.S.C. § 1391(e)(1). 

6. Deny. 

7. Admit. 

8. Admit the first sentence of this paragraph. The Commission is without 

knowledge or information sufficient to admit or deny the second sentence of this paragraph. 

9. Admit that plaintiff Chris Rufer has contributed the maximum amounts allowed 

for 2014 (1) to the Libertarian National Congressional Committee and (2) to the federal political 

committee established by the Libertarian Party of Indiana. 

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10. Admit. 

11. This paragraph is a statement of law to which no response is required. To the 

extent a response is required: Admit that 2 U.S.C. § 441a(a)(1)(B) limits the amount that 

persons may contribute annually to national political party committees and the current limit is 

$32,400. Price Index Adjustments for Contribution and Expenditure Limitations and Lobbyist 

Bundling Disclosure Threshold, 78 Fed. Reg. 8530-32 (Feb. 6, 2013). 

12. This paragraph is a statement of law to which no response is required. To the 

extent a response is required: Admit that 2 U.S.C. § 441a(a)(1)(D) limits the amount that 

persons may contribute annually to federal political committees established by state and local 

political party committees, and the limit is $10,000. 

13. This paragraph merely defines a term used in the Complaint and therefore no 

response is required. 

14. This paragraph is a statement of law to which no response is required. To the 

extent a response is required: Admit that 2 U.S.C. § 441i(a) prohibits national party committees 

and their officers and agents from soliciting or receiving contributions, or spending funds, that 

are not subject to the limitations, prohibitions, and reporting requirements of FECA. 

15. This paragraph is a statement of law to which no response is required. To the 

extent a response is required: Admit that (subject to certain exceptions in 2 U.S.C. § 441i(b)(2)) 

2 U.S.C. § 441i(b)(1) prohibits state and local party committees and their officers and agents 

from spending or disbursing money for federal election activity, as defined by 2 U.S.C. 

§ 431(20), unless those funds are subject to the limitations, prohibitions, and reporting 

requirements of FECA. 

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16. This paragraph is a statement of law to which no response is required. To the 

extent a response is required: Admit that 2 U.S.C. § 441i(c) prohibits state and local party 

committees and their officers and agents from spending or disbursing money for fundraising for 

federal election activity, as defined by 2 U.S.C. § 431(20), unless those funds are subject to the 

limitations, prohibitions, and reporting requirements of FECA. 

17. This paragraph merely defines a term used in the Complaint and therefore no 

response is required. 

18. This paragraph contains plaintiffs’ characterizations of FECA and judicial 

decisions, to which no response is required. To the extent a response is required: Admit that this 

paragraph appears to characterize portions of FECA and the holding in Buckley, 424 U.S. 1, and 

subsequent cases, which speak for themselves. The Commission notes that 2 U.S.C. § 431(17) 

defines “independent expenditure” as an expenditure “(A) expressly advocating the election or 

defeat of a clearly identified candidate; and (B) that is not made in concert or cooperation with or 

at the request or suggestion of such candidate, the candidate’s authorized political committee, or 

their agents, or a political party committee or its agents.” The phrase “maximum constitutional 

protection” is plaintiffs’ characterization and is not a quote from these judicial opinions. 

19. This paragraph contains plaintiffs’ characterizations of judicial decisions and 

conclusions of law, to which no response is required. To the extent a response is required: 

Admit that this paragraph appears to characterize portions of the holding in Buckley, 424 U.S. 1, 

and subsequent cases, which speak for themselves. 

20. This paragraph contains plaintiffs’ characterizations of judicial decisions and 

conclusions of law, to which no response is required. To the extent a response is required: 

Admit that this paragraph appears to characterize portions of the holding in McCutcheon v. FEC, 

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134 S. Ct. 1434 (2014), and other cases, which speak for themselves. The Commission denies 

that Citizens United, 558 U.S. 310, is about political contributions. 

21. This paragraph contains conclusions of law to which no response is required. The 

first sentence of this paragraph is vague and ambiguous, as it does not identify which courts it is 

referring to, and therefore the Commission is without knowledge or information sufficient to 

admit or deny the plaintiffs’ characterization of these judicial decisions. The Commission notes 

that 2 U.S.C. § 431(17) defines “independent expenditure” as an expenditure “(A) expressly 

advocating the election or defeat of a clearly identified candidate; and (B) that is not made in 

concert or cooperation with or at the request or suggestion of such candidate, the candidate’s 

authorized political committee, or their agents, or a political party committee or its agents.” The 

second sentence of this paragraph contains plaintiffs’ characterizations of unspecified judicial 

decisions, to which no response is required. To the extent a response is required: Admit that the 

second sentence of this paragraph appears to characterize portions of the holding in Citizens 

United, 558 U.S. 310 which speaks for itself. 

22. This paragraph contains plaintiffs’ characterizations of judicial decisions and 

conclusions of law, to which no response is required. To the extent a response is required: 

Admit that this paragraph appears to characterize portions of the holding in Buckley, 424 U.S. 1, 

and subsequent cases, including FEC v. Nat’l Conservative Political Action Comm., 470 U.S. 

480 (1985), which speak for themselves. 

23. This paragraph contains plaintiffs’ characterizations of unspecified judicial 

decisions and conclusions of law, to which no response is required. To the extent a response is 

required: Admit that this paragraph appears to characterize the holding in Carey, 791 F. Supp. 

2d 121, which speaks for itself. 

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24. This paragraph contains plaintiffs’ characterizations of a judicial decision and 

conclusions of law, to which no response is required. To the extent a response is required: 

Admit that this paragraph appears to characterize the holding in SpeechNow.org v. FEC, 599 

F.3d 686 (D.C. Cir. 2010), which speaks for itself. 

25. This paragraph contains plaintiffs’ characterizations of a judicial decision and 

conclusions of law, to which no response is required. To the extent a response is required: 

Admit that this paragraph appears to characterize the holding in Carey, 791 F. Supp. 2d 121, 

which speaks for itself. 

26. This paragraph contains plaintiffs’ characterizations of a judicial decision and 

conclusions of law, to which no response is required. To the extent a response is required: 

Admit that this paragraph accurately quotes the opinion in Carey, 791 F. Supp. 2d 121, 135, with 

the words “soft money” omitted and replaced by ellipses and other alterations that are identified 

by brackets. 

27. This paragraph contains plaintiffs’ characterizations of a judicial decision and 

conclusions of law, to which no response is required. To the extent a response is required: 

Admit that this paragraph appears to characterize the holding in EMILY’s List v. FEC, 581 F.3d 1 

(D.C. Cir. 2009), which speaks for itself. 

28. This paragraph contains plaintiffs’ characterizations of unspecified judicial 

decisions and conclusions of law, to which no response is required. To the extent a response is 

required: Admit that this paragraph appears to characterize the holding in Carey, 791 F. Supp. 

2d 121, which speaks for itself. 

29. Deny. 

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30. This paragraph contains plaintiffs’ characterizations of legal claims in its own 

Complaint, to which no response is required. To the extent a response is required: Deny that the 

conduct described in this paragraph would give political parties the First Amendment right to 

accept unlimited contributions. 

31. This paragraph contains plaintiffs’ characterizations of a judicial decision and 

conclusions of law, to which no response is required. To the extent a response is required: 

Admit that this paragraph appears to characterize the holding in Colorado I, 518 U.S. 604, which 

speaks for itself. 

32. This paragraph contains plaintiffs’ characterizations of a judicial decision and 

conclusions of law, to which no response is required. To the extent a response is required: 

Admit that the language identified in quotation marks appeared in the plurality opinion in 

Colorado I, 518 U.S. 604, which speaks for itself. 

33. This paragraph contains plaintiffs’ characterizations of a judicial decision and 

conclusions of law, to which no response is required. To the extent a response is required: Deny 

that subsection a accurately characterizes the Commission’s regulations defining coordination. 

Deny subsection b. Admit that the remainder of this paragraph appears to characterize portions 

of the holding from the plurality opinion in Colorado I, 518 U.S. 604, which speaks for itself. 

34. This paragraph contains plaintiffs’ characterizations of a judicial decision and 

conclusions of law, to which no response is required. To the extent a response is required: Deny 

that the paragraph accurately summarizes the plurality opinion in Colorado I, 518 U.S. 604. 

35. Deny, except the portion of this paragraph discussing the amount of independent 

expenditures a political party makes, which appears to characterize portions of the holding from 

the plurality opinion in Colorado I, 518 U.S. 604, which speaks for itself. 

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36. Deny the introductory sentence of this paragraph. 

 a. Admit the first sentence of subsection a. The second sentence of subsection a 

contains plaintiffs’ characterizations of a judicial decision, to which no response is required. To 

the extent a response is required: Deny that the opinion in McCutcheon, 134 S. Ct. 1434 speaks 

to the issue of contributions made to an independent expenditure account maintained by a 

political party. 

 b. Admit the first sentence of subsection b. The second sentence of subsection b 

contains plaintiffs’ characterizations of a judicial decision, to which no response is required. To 

the extent a response is required: Admit that this paragraph appears to characterize portions of 

the holdings in McCutcheon, 134 S. Ct. 1434, and Citizens United, 558 U.S. 310, which speak 

for themselves. 

 c. The first sentence of subsection c contains plaintiffs’ characterizations of legal 

claims in its own Complaint, to which no response is required. To the extent a response is 

required: The first sentence of subsection c is vague and ambiguous, as it does not define the 

term “constitutional equivalent,” and therefore the Commission is without knowledge or 

information sufficient to admit or deny the plaintiffs’ characterization. Admit the second 

sentence of subsection c. 

 d. Deny subsection d. 

37. Deny the first sentence of this paragraph. The remainder of this paragraph 

contains plaintiffs’ characterizations of legal claims in its own Complaint, to which no response 

is required. To the extent a response is required: Deny. 

38. Admit. 

39. Admit. 

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40. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

41. This paragraph contains plaintiffs’ characterizations of legal claims in its own 

Complaint, to which no response is required. To the extent a response is required: The 

Commission is without knowledge or information sufficient to admit or deny this paragraph, 

except deny that the Libertarian National Campaign Committee, Inc. (“LNCC”) has a First 

Amendment right to accept unlimited contributions. 

42. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

43. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

44. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

45. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

46. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

47. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

48. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

49. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

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50. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

51. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph, except deny that any “prophylactic safeguards” would justify striking down the 

provisions of FECA plaintiffs challenge in this case. 

52. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

53. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

54. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

55. Admit. 

56. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

57. Admit. 

58. This paragraph contains plaintiffs’ characterizations of legal claims in its own 

Complaint, to which no response is required. To the extent a response is required: The 

Commission is without knowledge or information sufficient to admit or deny this paragraph, 

except deny that the Libertarian Party of Indiana (“LPIN”) has a First Amendment right to accept 

unlimited contributions. 

59. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

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60. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

61. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

62. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

63. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

64. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

65. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

66. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

67. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

68. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph, except deny that any “prophylactic safeguards” would justify striking down the 

provisions of FECA plaintiffs challenge in this case. 

69. This paragraph is a statement of law to which no response is required. To the 

extent a response is required: Admit that 2 U.S.C. § 441a(a)(1)(B) limits contributions by 

individuals to national political party committees and the current annual limit is $32,400. 

70. Admit. 

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71. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

72. Admit that LNCC has accepted Rufer’s $32,400 contribution. The Commission is 

without knowledge or information sufficient to admit or deny the remainder of this paragraph. 

73. This paragraph is a statement of law to which no response is required. To the 

extent a response is required: Admit that 2 U.S.C. § 441a(a)(1)(B) limits contributions by 

individuals to national political party committees such as LNCC and the current limit is $32,400 

for all purposes. As a state party, LPIN is prohibited by 2 U.S.C. § 441a(a)(1)(D) from accepting 

more than $10,000 annually from a contributor for its federal political committee or for federal 

election activity as defined by 2 U.S.C. § 431(20). 

74. This paragraph is a statement of law to which no response is required. To the 

extent a response is required: Admit that 2 U.S.C. § 441i(a) prohibits national party committees 

and their officers and agents from soliciting or receiving contributions, or spending funds, that 

are not subject to the limitations, prohibitions, and reporting requirements of FECA. 

75. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

76. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

77. This paragraph is a statement of law to which no response is required. To the 

extent a response is required: Admit that 2 U.S.C. § 441a(a)(1)(D) limits contributions by 

individuals to federal committees established by state party committees, and that the annual limit 

is $10,000. 

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78. Admit that Rufer has contributed the maximum allowed for 2014 to LPIN’s 

federal political committee. 

79. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

80. Admit that LPIN has accepted Rufer’s $10,000 contribution. The Commission is 

without knowledge or information sufficient to admit or deny the remainder of this paragraph. 

81. This paragraph is a statement of law to which no response is required. To the 

extent a response is required: Admit that LPIN is prohibited by 2 U.S.C. § 441a(a)(1)(D) from 

accepting more than $10,000 annually from an individual contributor for its federal political 

committee or for federal election activity as defined by 2 U.S.C. § 431(20). 

82. This paragraph is a statement of law to which no response is required. To the 

extent a response is required: Admit that 2 U.S.C. § 441i(b)-(c) prohibits state and local party 

committees and their officers and agents from soliciting or receiving contributions for federal 

election activity as defined by 2 U.S.C. § 431(20) or spending funds on such activity that are not 

subject to the limitations, prohibitions, and reporting requirements of FECA. 

83. This paragraph is a statement of law to which no response is required. To the 

extent a response is required: Admit that 2 U.S.C. § 441i(c) prohibits the LPIN and other state 

and local party committees and their officers and agents from spending or disbursing money in 

connection with fundraising for federal election activity as defined by 2 U.S.C. § 431(20) unless 

those funds are subject to the limitations, prohibitions, and reporting requirements of FECA. 

84. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

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85. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

86. This paragraph re-alleges and incorporates by reference the allegations contained 

in paragraphs 1-85 of plaintiffs’ Complaint, and the Commission therefore incorporates by 

reference its responses to those paragraphs. 

87. This paragraph is a statement of law to which no response is required. To the 

extent a response is required: Admit that 2 U.S.C. § 441a(a)(1)(B) limits contributions by 

individuals to national political parties. 

88. This paragraph is a statement of law to which no response is required. To the 

extent a response is required: Admit that 2 U.S.C. § 441a(a)(1)(D) limits contributions by 

individuals to state political party committees for the purpose of federal election activity as 

defined by 2 U.S.C. § 431(20). 

89. Deny. 

90. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

91. Deny. 

92. Deny. 

93. Deny. 

94. This paragraph re-alleges and incorporates by reference the allegations contained 

in paragraphs 1-93 of plaintiffs’ Complaint, and the Commission therefore incorporates by 

reference its responses to those paragraphs. 

95. Deny. 

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96. This paragraph contains plaintiffs’ characterizations of a judicial decision, to 

which no response is required. To the extent a response is required: Admit that this paragraph 

appears to characterize portions of the holding in McConnell v. FEC, 540 U.S. 93, 154 (2003) 

which speaks for itself. To the extent the paragraph contains a factual allegation about minor 

and third parties, deny. 

97. Deny. 

98. The Commission is without knowledge or information sufficient to admit or deny 

the first sentence of this paragraph. The third sentence in part contains plaintiffs’ 

characterizations of a judicial decision, to which no response is required. To the extent a 

response is required: Admit that a portion of this sentence appears to characterize portions of the 

holding in McConnell, 540 U.S. at 154, which speaks for itself. Deny the remainder of this 

paragraph. 

99. Deny. 

100. Deny. 

101. Deny. 

102. Deny. 

103. This paragraph re-alleges and incorporates by reference the allegations contained 

in paragraphs 1-102 of plaintiffs’ Complaint, and the Commission therefore incorporates by 

reference its responses to those paragraphs. 

104. This paragraph is a statement of law to which no response is required. To the 

extent a response is required: Admit that 2 U.S.C. § 441i(a) prohibits national party committees 

and their officers and agents from soliciting or receiving contributions, or spending funds, that 

are not subject to the limitations, prohibitions, and reporting requirements of FECA. 

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105. This paragraph is a statement of law to which no response is required. To the 

extent a response is required: Admit that (subject to certain exceptions in 2 U.S.C. § 441i(b)(2)), 

2 U.S.C. § 441i(b)(1) prohibits state and local party committees and their officers and agents 

from spending or disbursing money for federal election activity, as defined by 2 U.S.C. 

§ 431(20), unless those funds are subject to the limitations, prohibitions, and reporting 

requirements of FECA. 

106. This paragraph is a statement of law to which no response is required. To the 

extent a response is required: Admit that 2 U.S.C. § 441i(c) prohibits state and local party 

committees and their officers and agents from spending or disbursing money in connection with 

fundraising for federal election activity, as defined by 2 U.S.C. § 431(20), unless those funds are 

subject to the limitations, prohibitions, and reporting requirements of FECA. 

107. This paragraph contains plaintiffs’ characterizations of legal claims in its own 

Complaint and conclusions of law, to which no response is required. To the extent a response is 

required: Deny the first sentence of this paragraph. Admit that 2 U.S.C. § 441i(a) prohibits 

national party committees and their officers and agents from soliciting or receiving contributions, 

or spending funds, that are not subject to the limitations, prohibitions, and reporting requirements 

of FECA. Admit that (subject to certain exceptions in 2 U.S.C. § 441i(b)(2)), 2 U.S.C. § 

441i(b)(1) prohibits state party committees and their officers and agents from spending or 

disbursing money for federal election activity, as defined by 2 U.S.C. § 431(20), unless those 

funds are subject to the limitations, prohibitions, and reporting requirements of FECA. Admit 

that 2 U.S.C. § 441i(c) prohibits state party committees and their officers and agents from 

spending or disbursing money in connection with fundraising for federal election activity, as 

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defined by 2 U.S.C. § 431(20), unless those funds are subject to the limitations, prohibitions, and 

reporting requirements of FECA. 

108. Deny. 

109. Deny. 

110. Deny. 

111. Deny. 

112. This paragraph re-alleges and incorporates by reference the allegations contained 

in paragraphs 1-111 of plaintiffs’ Complaint, and the Commission therefore incorporates by 

reference its responses to those paragraphs. 

113. Deny. 

114. This paragraph contains plaintiffs’ characterizations of a judicial decision and 

conclusions of law, to which no response is required. To the extent a response is required: 

Admit that a portion of this paragraph appears to characterize portions of the holding in 

McConnell, 540 U.S. 93, which speaks for itself. To the extent the paragraph contains a factual 

allegation about minor and third parties, deny. 

115. Deny. 

116. The Commission is without knowledge or information sufficient to admit or deny 

the first sentence of this paragraph. The third sentence in part contains plaintiffs’ 

characterizations of a judicial decision, to which no response is required. To the extent a 

response is required: Admit that a portion of this sentence appears to characterize portions of the 

holding in McConnell, 540 U.S. 93, which speaks for itself. Deny the remainder of this 

paragraph. 

117. Deny. 

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118. Deny. 

119. Deny. 

120. Deny. 

121. Deny. 

THE COMPLAINT’S PRAYER FOR RELIEF

1-6. Plaintiffs are not entitled to the relief requested or to any other relief. 

DEFENDANT FEDERAL ELECTION COMMISSION’S 

AFFIRMATIVE DEFENSE 

1. The Complaint fails to state a claim upon which relief can be granted. 

 Respectfully submitted, 

Lisa J. Stevenson (D.C. Bar No. 457628) 

Deputy General Counsel — Law 

lstevenson@fec.gov 

 

Kevin Deeley 

Acting Associate General Counsel 

kdeeley@fec.gov 

Harry J. Summers 

Assistant General Counsel 

hsummers@fec.gov 

/s/ Seth Nesin 

Seth Nesin 

Greg J. Mueller (D.C. Bar No. 462840) 

Charles Kitcher (D.C. Bar No. 986226) 

 Attorneys 

 snesin@fec.gov 

gmueller@fec.gov 

 ckitcher@fec.gov 

 

COUNSEL FOR DEFENDANT 

FEDERAL ELECTION COMMISSION 

999 E Street NW 

 Washington, DC 20463 

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July 28, 2014 (202) 694-1650 

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