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UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Alexandria Division 

_______________________________________ 

 ) 

STOP RECKLESS ECONOMIC ) No. 1:14-CV-00397-AJT-IDD 

INSTABILITY CAUSED BY DEMOCRATS, ) 

TEA PARTY LEADERSHIP FUND, and ) 

ALEXANDRIA REPUBLICAN CITY ) 

COMMITTEE, ) 

 ) 

Plaintiffs, ) 

 ) 

 v. ) 

 ) 

FEDERAL ELECTION COMMISSION, ) 

 ) 

 Defendant. ) 

_______________________________________) 

 

AMENDED COMPLAINT

 The Federal Election Campaign Act (“FECA”), as amended by the Bipartisan Campaign 

Reform Act (“BCRA”), allows certain political committees that have existed for more than six 

months to contribute up to $5,000 per election to a candidate for federal office, for a total of up to 

$10,000 per candidate each election cycle (including a primary election and general election). The 

statute places materially indistinguishable political committees that have existed for less than six 

months at a disadvantage, permitting them to contribute only $2,600 per election to each candidate, 

for a total of $5,200 per candidate each election cycle. These discriminatory restrictions 

impermissibly allow entrenched institutions and interests to engage in protected First Amendment 

activities to a greater extent than newly formed grassroots organizations that have spontaneously 

mobilized in response to emergent political issues and developments. They unconstitutionally 

allow some speakers to exercise their speech and associational rights in the political arena to a 

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greater extent than others, particularly penalizing the emergence of spontaneous, grassroots 

political expression when it is most vital—in the days leading up to an election. 

 Further underscoring the arbitrary and indefensible structure of the current system is that 

the ability of certain political committees to engage in other forms of political expression and 

association becomes limited after they have existed for more than six months. A newly formed 

political committee may, within the first six months of its existence, contribute an annual total of 

$10,000 to a state political party committee and its affiliated local political party committees, as 

well as $32,400 annually to a national political party committee. Once many such committees 

have existed for more than six months, however, those limits are decreased to a total of $5,000 

each year to a state party committee and its local affiliates, as well as $15,000 annually to national 

political party committees. This impermissibly abrogates the associational rights of both those 

committees and their individual members. 

 This bizarre amalgamation of increasing and decreasing contribution limits based on the 

duration of an entity’s existence cannot survive constitutional scrutiny. 

Jurisdiction and Venue

1. This Court has subject-matter jurisdiction over this case pursuant to 28 U.S.C. 

§ 1331, as it arises under the First Amendment to the U.S. Constitution and concerns the 

constitutionality of various provisions of federal law. 

2. Venue is proper in this Court under 28 U.S.C. § 1391(e)(1)(B)-(C), because the 

defendant is an agency of the United States, a substantial part of the events and omissions giving 

rise to the claim occurred in this district, and Plaintiffs Stop the Reckless Economic Instability 

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

reside here, see id. § 1391(c)(2). 

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Parties 

3. Plaintiff STOP THE RECKLESS ECONOMIC INSTABILITY CAUSED BY 

DEMOCRATS (“STOP PAC”) is a non-connected political committee (“PAC”) that maintains its 

principal place of business in Alexandria, Virginia. It filed its registration with the Federal 

Election Commission (“FEC”) on February 24, 2014, and resubmitted its registration form on 

April 4, 2014, after the FEC failed to post the original one on its website. 

4. Plaintiff TEA PARTY LEADERSHIP FUND (“Fund”) is a non-connected

multicandidate political committee (“multicandidate PAC”) that is registered and maintains its 

principal place of business in Alexandria, Virginia. It filed its registration with the FEC on May 

9, 2012. 

5. Plaintiff ALEXANDRIA REPUBLICAN CITY COMMITTEE (“ARCC”) is a 

local political party committee and is affiliated with the Virginia Republican State Committee, a 

state political party committee. It maintains its principal place of business in Alexandria, Virginia. 

6. Defendant FEDERAL ELECTION COMMISSION (“FEC”) is located in 

Washington, D.C. It is the federal agency charged with enforcing the FECA and BCRA. 

The Discriminatory Contribution Limits 

7. The FECA allows individuals to join together to form “political committees” to 

further their political goals, engage in expressive conduct, and support candidates who share their 

goals and values. 2 U.S.C. § 431(4). 

8. In general, the FECA treats a political committee as a “person.” 2 U.S.C. § 431(11). 

9. The FEC announced the inflation-adjusted limits for contributions by political 

committees and other entities on February 6, 2013. See FEC, Price Index Adjustments for 

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Contribution and Expenditure Limitations and Lobbyist Bundling Disclosure Threshold, 78 FED.

REG. 8,530, 8,532 (Feb. 6, 2013). 

10. Taking into account the FEC’s adjustments for inflation, a “person”—including a 

political committee—generally may contribute the following amounts in the current (2013-2014) 

election cycle: 

a. $2,600 per election to any candidate for federal office, for a maximum of 

$5,200 per election cycle (including the primary and general elections), see 2 U.S.C. 

§ 441a(a)(1)(A); 

b. a total of $10,000 per year to a state political party committee and its 

affiliated local political party committees, see 2 U.S.C. § 441a(a)(1)(D); and 

c. $32,400 per year to any national political party committee, see 2 U.S.C. 

§ 441a(a)(1)(B), such as the Democratic National Committee, Republican National 

Committee, Democratic Senatorial Campaign Committee, National Republican Senatorial 

Committee, Democratic Congressional Campaign Committee, and National Republican 

Congressional Committee. 

11. A political committee qualifies as a “multicandidate political committee,” and 

becomes subject to different contribution limits, if it has: 

a. been registered with the FEC for six or more months; 

b. received contributions from more than 50 persons; and 

c. contributed to five or more candidates for federal office. 2 U.S.C. 

§ 441a(a)(4). 

12. Taking into account the FEC’s adjustments for inflation, a “multicandidate political 

committee” generally may contribute: 

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a. $5,000 per election to any candidate for federal office, for a maximum of 

$10,000 per election cycle (including the primary and general elections), see 2 U.S.C. 

§ 441a(a)(2)(A); 

b. $5,000 per year to any other political committee, including a total of $5,000 

to a state political party committee and its affiliated local political party committees, see 2 

U.S.C. § 441a(a)(2)(C); and 

c. $15,000 per year to any national political party committee, see 2 U.S.C. 

§ 441a(a)(2)(B).

13. The following table summarizes the contribution limits that apply to political 

committees that have more than 50 contributors and have contributed to five or more candidates: 

Recipient of Contribution: 

Political Committee Making 

Contribution Has Existed for 

Less Than Six (6) Months 

Political Committee Making 

Contribution Has Existed for 

Six (6) or More Months 

Candidate $2,600 $5,000 

State political party 

committee and local party 

committee affiliates 

$10,000 $5,000 

National political 

party committee 

$32,400 $15,000 

14. Even if a political committee has received contributions from more than 50 persons, 

and has contributed to five or more candidates for federal offices, it cannot be recognized as a 

“multicandidate political committee”—and become subject to the contribution limits that apply to 

multicandidate political committees—unless it has existed and been registered with the FEC for at 

least six months. 2 U.S.C. § 441a(a)(4). 

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15. Conversely, once a political committee has received contributions from more than 

50 persons, contributed to five or more candidates for federal office, and existed and been 

registered with the FEC for at least six months, it must be designated a “multicandidate political 

committee” and cannot avoid being subject to the contribution limits that apply to such entities. 

See 11 C.F.R. § 110.2(a)(1). 

16. Due to the discriminatory contribution limits that apply to political committees and 

“multicandidate political committees,” a political committee that has received more than 50 

contributions and contributed to at least five candidates, but has been registered with the FEC for 

less than six months, may contribute only $2,600 per election to each candidate (for a maximum 

of $5,200 per election cycle). 2 U.S.C. § 441a(a)(1)(A). An identically situated political 

committee that has received more than 50 contributions and contributed to at least five candidates, 

but has existed and been registered with the FEC for more than six months, however, qualifies as 

a multicandidate political committee, id. § 441a(a)(4), and may contribute $5,000 per election to 

each candidate (for a maximum of $10,000 per election cycle), id. § 441a(a)(2)(A). 

17. A political committee that has received more than 50 contributions and contributed 

to at least five candidates, but has been registered with the FEC for less than six months, may 

contribute a total of $10,000 each year to a state political party committee and its affiliated local 

political party committees, as well as $32,400 each year to a national political party committee. 2 

U.S.C. § 441a(a)(1)(B), (D). An identically situated political committee that has received more 

than 50 contributions and contributed to at least five candidates, but has existed and been registered 

with the FEC for more than six months, however, is designated a multicandidate political 

committee, 2 U.S.C. § 441a(a)(4), and may contribute a total of only $5,000 each year to a state 

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political party committee and its affiliated local political party committees, as well as $15,000 each 

year to a national political party committee per year, 2 U.S.C. § 441a(a)(2)(B), (C). 

Federal Law Imposes Unconstitutional Discriminatory 

Limits on STOP PAC’s Ability to Associate With and 

Demonstrate Its Support for the Candidates It Supports 

18. Plaintiff STOP PAC filed with the FEC the paperwork necessary to register as a 

political committee on February 24, 2014. STOP PAC has over 1,400 contributors and has made 

contributions to at least five candidates for federal office. 

19. STOP PAC meets all of the statutory qualifications for being recognized as a 

“multicandidate political committee,” except it has existed and been registered with the FEC for 

less than six months. Because STOP PAC is unable to qualify as a “multicandidate political 

committee,” it may contribute only $2,600 per election to each candidate, rather than $5,000. 

20. On or about April 4, 2014, STOP PAC contributed the statutory maximum of 

$2,600 to Niger Innis. Innis was a candidate for the Republican nomination for Congress from 

Nevada’s fourth congressional district in Nevada’s June 10, 2014 primary election. 

21. STOP PAC wished to contribute an additional $2,400 to Innis in connection with 

the primary election, which would bring its total contribution to Innis in connection with the 

primary to $5,000. From April 4, 2014 (the date of STOP PAC’s contribution to Innis) through 

the primary, STOP PAC consistently had sufficient funds in its account to make this contribution. 

22. The FEC maintains that, due to the FECA’s six-month waiting period, STOP PAC 

will not qualify as a multicandidate political committee until September 11, 2014—after the 

primary election is over—and therefore could not contribute more than a total of $2,600 to Innis 

in connection with the primary. If STOP PAC had existed and been registered with the FEC for 

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more than six months, however, it would have been able to contribute a total of $5,000 to Innis in 

connection with the primary. 

23. STOP PAC wished to contribute additional funds to Innis in the primary election 

as a way of further associating itself with him; expressing and demonstrating its strong approval 

of his political views and proposals concerning limited government, lower taxes, and personal 

freedom; subsidizing his political speech, with which it deeply agrees; and assisting his campaign. 

24. On or about June 16, 2014, STOP PAC contributed the statutory maximum of 

$2,600 to Dan Sullivan. Sullivan is a candidate for the Republican nomination for Senate from 

Alaska in Alaska’s August 19, 2014 primary election. 

25. STOP PAC wished to contribute an additional $2,400 to Sullivan in connection 

with the primary election, which would bring its total contribution to Sullivan in connection with 

the primary to $5,000. From June 16, 2014 (the date of STOP PAC’s contribution to Sullivan) 

through the present, STOP PAC consistently has had sufficient funds in its account to make this 

additional $2,400 contribution. It will retain such funds until the date of the primary. 

26. The FEC maintains that, due to the FECA’s six-month waiting period, STOP PAC 

will not qualify as a multicandidate political committee until September 11, 2014—after the 

primary election is over—and therefore may not contribute funds totaling more than $2,600 to a 

candidate such as Sullivan in connection with that primary election. If STOP PAC had existed 

and been registered with the FEC for more than six months, however, it would have been able to 

contribute a total of $5,000 to Sullivan in connection with the primary. 

27. STOP PAC wishes to contribute additional funds to Sullivan in the primary 

election as a way of further associating itself with him; expressing and demonstrating its strong 

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approval of his political views and proposals concerning pro-growth tax reform and health care 

reform; subsidizing his political speech, with which it deeply agrees; and assisting his campaign. 

28. On or about July 7, 2014, STOP PAC contributed $2,600 to Congressman Joe Heck 

in connection with the 2014 general election. Congressman Heck is the Republican nominee for 

Congress from Nevada’s 3rd congressional district. 

29. STOP PAC previously contributed $250 to Heck in connection with Nevada’s 2014 

primary election for the 3rd congressional district 

30. STOP PAC wishes to immediately contribute an additional $1,800 to Heck, for a 

total of $4,400, but federal law prohibits it from contributing funds totaling more than $2,600 to a 

candidate until its six-month waiting period expires on September 11, 2014. Between August 1, 

2014 and September 11, 2014, STOP PAC will retain sufficient funds in its account (in addition 

to other funds alleged in this Amended Complaint) to make such a contribution. 

31. The FEC maintains that, due to the FECA’s six-month waiting period, STOP PAC 

will not qualify as a multicandidate political committee until September 11, 2014, and therefore 

may not contribute a total of more than $2,600 to Heck in connection with the general election 

until that date. If STOP PAC had existed and been registered with the FEC for more than six 

months, however, it would have been able to immediately contribute a total of $5,000 to Sullivan 

in connection with the general election. 

32. STOP PAC wishes to contribute additional funds to Heck in the general election as 

a way of further associating itself with him; expressing and demonstrating its strong approval of 

his political views and proposals concerning health care and rollbacks of excessive federal 

regulations; subsidizing his political speech, with which it deeply agrees; and assisting his 

campaign. 

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33. STOP PAC believes that associating itself with a candidate as early as possible in 

a general election race, and to the greatest extent legally possible, can have the greatest impact on 

the race by helping to define a candidate early in the voters’ minds, engendering further support 

from like-minded individuals and groups that can increase exponentially as time progresses, and 

assisting the candidate in propagating his views more broadly, potentially defining the issues that 

will determine the course of the race. 

34. Because STOP PAC’s contributors live throughout the country, making a 

contribution through STOP PAC is the most practical and realistic way in which they collectively 

can associate as STOP PAC supporters with the candidates the committee supports. 

35. If STOP PAC contributes more than $2,600 to a candidate in connection with a 

single election, it will face a credible threat of civil enforcement proceedings or criminal 

prosecution. 

Federal Law Imposes Unconstitutional Discriminatory 

Limits on the Fund’s Ability to Associate With and 

Demonstrate Its Support for Political Party Committees 

 

36. Plaintiff Fund registered as a political committee with the FEC on May 9, 2012, 

and has over 100,000 contributors. It has made, and continues to make, contributions to dozens 

of federal candidates. 

37. The Fund, which has been registered with the FEC for six or more months, is 

registered and treated as a “multicandidate political committee.” It therefore may contribute a total 

of only $5,000 per year to a state political party committee and its affiliated local political party 

committees, as well as $15,000 per year to a national political party committee. 

38. On April 4, 2014, the Fund contributed the statutory maximum of $5,000 to the 

ARCC. 

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39. The Fund has more than $37,400 in available funds. It wishes to immediately 

contribute an additional $5,000 to the ARCC, which would bring its total contributions to the 

ARCC for the year 2014 to $10,000. The Fund further wishes to immediately contribute $32,400 

to the National Republican Senatorial Committee (“NRSC”). 

40. Due to the discriminatory limits on contributions from multicandidate political 

committees to political party committees, the Fund may not contribute as much to the ARCC and 

the NRSC as a political committee that is identical to it in all material respects, but has existed and 

been registered with the FEC for less than six months. 

41. The Fund wishes to contribute additional funds to the ARCC and NRSC as a way 

of further associating itself with those entities; expressing and demonstrating its strong approval 

of their political platforms; subsidizing their political speech, with which it deeply agrees; and 

assisting the campaigns in which those entities are involved. 

42. Because the Fund’s contributors live throughout the country, making a contribution 

through the Fund is the most practical and realistic way in which they can collectively associate 

the Fund with the ARCC and NRSC and further their efforts as a group. 

CAUSES OF ACTION

COUNT I 

Plaintiffs STOP PAC’s Fifth Amendment Equal Protection Challenge to 2 U.S.C. 

§ 441a(a)(1)(A) As Applied to Certain New Political Committees 

43. Plaintiff STOP PAC hereby re-alleges and incorporates by reference the allegations 

contained in Paragraphs 1-38. 

44. Limits on contributions from political committees to candidates burden the 

fundamental First Amendment rights of freedom of association and speech of such committees 

and their members. 

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45. The FEC is subject to the Due Process Clause of the Fifth Amendment, which 

contains equal protection restrictions identical to those that the Fourteenth Amendment’s Equal 

Protection Clause imposes on states. See Bolling v. Sharpe, 347 U.S. 497 (1954). 

46. Under federal law, materially identical groups that have received contributions 

from more than 50 people and contributed to at least 5 federal candidates are unconstitutionally 

treated differently, depending on whether or not they have been registered with the FEC for at least 

6 months. 

47. A group that has received contributions from more than 50 people and contributed 

to at least 5 federal candidates, but has not been registered with the FEC for at least 6 months, is 

considered to be only a “political committee,” is treated as a “person” for purposes of contribution 

limits, and may contribute no more than $2,600 per election to each candidate. 2 U.S.C. 

§ 441a(a)(1)(A). 

48. A materially identical group that has received contributions from more than 50 

people, contributed to at least 5 federal candidates, and has existed and been registered with the 

FEC for at least 6 months is considered to be a “multicandidate political committee” and may 

contribute up to $5,000 per election to each candidate. 2 U.S.C. § 441a(a)(2)(A). 

49. The differing limits on materially identical committees’ contributions to candidates, 

depending on whether the committee has existed and been registered with the FEC for more than 

6 months, is not closely tailored to furthering an important government interest, and fails any level 

of heightened constitutional scrutiny. Imposing the lower $2,600 restriction on all new political 

committees is an impermissibly overbroad means of furthering any interest the Government may 

assert. 

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50. Section 441a(a)(1)(A)’s contribution limit of $2,600 to each candidate per election 

is unconstitutional under the equal protection component of the Fifth Amendment’s Due Process 

Clause, as applied to political committees that have received contributions from more than 50 

people and contributed to at least 5 federal candidates, but have not existed and been registered 

with the FEC for at least 6 months. 

COUNT II 

Plaintiff STOP PAC’s First Amendment Challenge to 2 U.S.C. § 441a(a)(4)’s Six-Month 

Waiting Period As Applied to Certain New Political Committees 

51. Plaintiff STOP PAC hereby re-alleges and incorporates by reference the allegations 

contained in Paragraphs 1-46. 

52. Political committees that have received contributions from more than 50 people and 

made contributions to at least 5 federal candidates, but that have existed and been registered with 

the FEC for less than six months, may contribute only $2,600 per election to each candidate. 

2 U.S.C. § 441a(a)(1)(A). 

53. 2 U.S.C. § 441a(a)(4) imposes a six-month waiting period on such committees 

before they may qualify as “multicandidate political committees,” and be permitted to contribute 

$5,000 per election to each candidate under 2 U.S.C. § 441a(a)(2)(A). 

54. This six-month waiting period is a substantial delay that interferes with new 

political committees’ attempts to associate with and demonstrate their support for candidates in a 

timely manner. Such delay constitutes a substantial burden on First Amendment rights. 

55. 2 U.S.C. § 441a(a)(4)’s six-month waiting period for being designated a 

“multicandidate political committee” and being permitted to contribute $5,000 rather than $2,600 

per election to each candidate is comparable to a prior restraint and substantially burdens First 

Amendment rights of freedom of association and expression. 2 U.S.C. § 441a(a)(4) therefore is 

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unconstitutional as applied to political committees that have received contributions from more than 

50 people and contributed to at least 5 federal candidates, but have not existed and been registered 

with the FEC for at least 6 months. 

COUNT III 

ARCC’s and the Fund’s Fifth Amendment Equal 

Protection Challenge to 2 U.S.C. § 441a(a)(2)(B), (C) 

56. Plaintiffs ARCC and the Fund hereby re-allege and incorporate by reference the 

allegations contained in Paragraphs 1-51. 

57. Limits on contributions from multicandidate political committees to candidates 

burden the fundamental First Amendment rights of freedom of association and expression of such 

committees and their members. 

58. The FEC is subject to the Due Process Clause of the Fifth Amendment, which 

contains equal protection restrictions identical to those that the Fourteenth Amendment’s Equal 

Protection Clause imposes on states. See Bolling v. Sharpe, 347 U.S. 497 (1954). 

59. Under federal law, materially identical groups that have received contributions 

from more than 50 people and contributed to at least 5 federal candidates are unconstitutionally 

treated differently, depending on whether they have been registered with the FEC for at least 6 

months. 

60. A group that has received contributions from more than 50 people and contributed 

to at least 5 federal candidates, but has not been registered with the FEC for at least 6 months, is 

considered to be only a “political committee,” is treated as a “person” for purposes of contribution 

limits, and may contribute up to a total of $10,000 annually to a state political party committee and 

its affiliated local political party committees, as well as $32,400 annually to a national political 

party committee. 2 U.S.C. § 441a(a)(1)(B), (D). 

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61. A materially identical group that has received contributions from more than 50 

people, contributed to at least 5 federal candidates, and has been registered with the FEC for at 

least 6 months is considered to be a “multicandidate political committee” and may contribute a 

total of only $5,000 annually to a state political party committee and its affiliated local political 

party committees, as well as $15,000 annually to a national political party committee. 2 U.S.C. § 

441a(a)(2)(B), (C). 

62. The different limits on committees’ contributions to candidates, depending on 

whether the committee has existed and been registered with the FEC for more than 6 months, is 

not closely tailored to furthering an important government interest, and fails any form of 

heightened scrutiny. 

63. Section 441a(a)(2)(B), (C)’s annual contribution limits of $5,000 to state political 

party committees and their affiliated local political party committees, and $15,000 to national 

political party committees, is unconstitutional under the equal protection component of the Fifth 

Amendment’s Due Process Clause. 

PRAYER FOR RELIEF

 WHEREFORE, Plaintiffs pray for the following relief: 

1. A declaratory judgment pursuant to 28 U.S.C. § 2201 that: 

a. 2 U.S.C. § 441a(a)(1)(A)’s $2,600 limit on contributions to candidates 

violates the equal protection component of the Fifth Amendment as applied to STOP PAC 

and similarly situated groups; 

b. 2 U.S.C. § 441a(a)(4)’s six-month waiting period on being designated a 

“multicandidate political committee” and the resulting restrictions on speech and 

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association violate the First Amendment as applied to STOP PAC and similarly situated 

groups; and 

c. 2 U.S.C. § 441a(a)(2)(C)’s $5,000 limit on contributions from 

multicandidate political committees to state political party committees and affiliated local 

political party committees, as well as 2 U.S.C. § 441a(a)(2)(B)’s $15,000 limit on 

contributions from multicandidate political committees to national political party 

committees, violate the equal protection component of the Fifth Amendment; 

2. An injunction: 

a. prohibiting the FEC from enforcing 2 U.S.C. § 441a(a)(1)(A)’s $2,600 limit 

on contributions from political committees to candidates against political committees such 

as STOP PAC that have received contributions from more than 50 people and made 

contributions to at least 5 federal candidates (and requiring the FEC to instead apply 2 

U.S.C. § 441a(a)(2)(A)’s $5,000 limit to such entities); 

b. prohibiting the FEC from enforcing 2 U.S.C. § 441a(a)(2)(C)’s $5,000 limit 

on contributions from multicandidate political committees such as the Fund to state 

political party committees and their affiliated local political party committees such as the 

ARCC (and requiring the FEC to instead apply 2 U.S.C. § 441(a)(1)(D)’s $10,000 limit to 

such contributions); and 

c. prohibiting the FEC from enforcing 2 U.S.C. § 441a(a)(2)(B)’s $15,000 

limit on contributions from multicandidate political committees such as the Fund to 

national political party committees (and requiring the FEC to instead apply 2 U.S.C. 

§ 441(a)(1)(B)’s $32,400 limit to such contributions); 

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3. Costs and attorneys’ fees pursuant to any applicable statute or authority, including 

but not limited to the Equal Access to Justice Act, 28 U.S.C. § 2412; and 

4. Such other relief as this Court deems just and appropriate. 

Dated this 7th day of July 2014. 

 

 Respectfully submitted, 

 

 /s/ Michael T. Morley 

 Michael 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 

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