Coolidge Reagan Foundation V FEC

Case 1:19-cv-01493-ESH Document 1 Filed 05/22/19 Page 1 of 12
U.S. DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
)
COOLIDGE REAGAN FOUNDATION )
1629 K Street, NW, Suite 300 )
Washington, D.C. 20006, )
)
)
Plaintiff, )
)
v. )
)
FEDERAL ELECTION COMMISSION, )
1050 First Street, NE )
Washington, DC 20463, )
)
Defendant, )
_______________________________________)
VERIFIED COMPLAINT
Plaintiff COOLIDGE REAGAN FOUNDATION brings this action for injunctive and
declaratory relief and alleges as follows:
INTRODUCTION
1. The Coolidge Reagan Foundation (“CRF”) asks this Court to compel the Federal Election
Commission (“FEC”) to take action on an administrative complaint it filed with the FEC
nine months ago providing reason to believe Hillary for America (“HFA”) and the
Democratic National Committee (“DNC”) violated campaign finance law by conspiring
with foreign nationals, including current and former members of the Russian government,
to manipulate the results of the 2016 election.
2. The administrative complaint alleges HFA and the DNC worked with British national
Christopher Steele to generate the so-called “Steele Dossier”—a thoroughly debunked
collection of lies and spurious allegations intended to discredit then-candidate Donald
Trump. HFA and the DNC used their shared law firm agent, Perkins Coie, LLP, as a straw-
1
man intermediary and conduit to avoid publicly reporting the tens of thousands of dollars
they funneled abroad to pay for the fraudulent document.
3. HFA and the DNC’s scheme of compensating a third party through a straw-man
intermediate and conduit to prevent the public from learning of their role in the transaction
was the conduct of which the defendants in United States v. Benton, 890 F.3d 697 (8th Cir.
2018), cert. denied, No. 18-442, 2019 U.S. LEXIS 1966 (Mar. 18, 2019), were convicted.
The U.S. Supreme Court recently upheld those convictions.
4. Many of the allegations in the Steele dossier, funded by HFA and the DNC, originated with
current and former Russian officials. Ironically, the dossier played a primary role in
triggering Independent Counsel Robert Mueller’s investigation into alleged collusion
between the Trump campaign and the Russian government—collusion which the
Independent Counsel concluded did not occur. It was also the Obama Administration’s
primary basis for obtaining a warrant under the Foreign Intelligence Surveillance Act
(“FISA”) to engage in unprecedented surveillance against a presidential candidate and,
later, President-elect of the opposing political party.
5. Federal law does not permit the FEC to investigate alleged violations of campaign finance
law unless the Commission determines there is “reason to believe” a violation occurred
based on an administrative complaint, any response, and publicly available campaign
finance reports. 52 U.S.C. § 30109(a)(2). This standard is far lower than either “probable
cause,” cf. id. § 30109(a)(3), or the preponderance standard a district court would apply,
cf. id. § 30109(a)(6).
6. This Court should ensure the FEC takes appropriate enforcement action in a timely manner
pursuant to 52 U.S.C. § 30109(a)(8). FEC Chairwoman Ellen Weintraub has publicly
2
announced she intends to vote against any effort to defend against lawsuits such as this
seeking to compel the FEC to engage in meritorious enforcement efforts. See Nihal
Krishan, Elections Commission Chief Uses the “Nuclear Option” to Rescue the Agency
from Gridlock, MOTHER JONES (Feb. 20, 2019), at
https://www.motherjones.com/politics/2019/02/elections-commission-chief-uses-the-
nuclear-option-to-rescue-the-agency-from-gridlock/. She has also announced she might
willfully go into contempt of court by deliberately ignoring an order this Court may issue
to compel the agency to enforce federal law. Id. (“Weintraub says she might pursue a
second nuclear option: refuse to comply with the court order.”).
7. The FEC’s apparent failure to find “reason to believe” federal campaign finance law has
been violated, despite the evidence set forth in CRF’s administrative complaint, is arbitrary,
capricious, and contrary to law.
JURISDICTION AND VENUE
8. This Court has jurisdiction over this case pursuant to 28 U.S.C. § 1331 because it arises
under a federal statute.
9. Venue is proper in this Court under 28 U.S.C. § 1391(e) because Defendant is an entity of
the U.S. Government.
PARTIES
10. Plaintiff COOLIDGE-REAGAN FOUNDATION (“CRF”) is a § 501(c)(3) non-profit
organization organized under the laws of, and headquartered in, Virginia.
11. Defendant FEDERAL ELECTION COMMISSION (“FEC”) is the federal agency charged
with enforcing the Federal Election Campaign Act (“FECA”) and is located in Washington,
D.C.
3
THE FEC’S FAILURE TO TAKE ACTION

ON CRF’S ADMINISTRATIVE COMPLAINT
12. On August 1, 2018, CRF filed an administrative complaint with the FEC against
Christopher Steele, a British national; Hillary for America, Hillary Clinton’s principal
authorized presidential candidate committee; the DNC, a national political party
committee; and Perkins Coie, the law firm for HFA and the DNC. 1
13. The administrative complaint was written, signed, notarized, and verified under penalty of
perjury as required by 52 U.S.C. § 30109(a)(1).
14. A true and complete copy of the administrative complaint is appended to this Complaint
as Exhibit 1.
15. On or about August 8, 2018, the FEC’s Office of General Counsel (“OGC”) acknowledged
receipt of the administrative complaint and designated it Matter Under Review (“MUR”)
number 7449.
16. On information and belief, the FEC notified the respondents of the administrative
complaint within five days of its receipt, pursuant to 11 C.F.R. § 111.5(a), and provided
them with an opportunity to submit a response within fifteen days, pursuant to 11 C.F.R.
§ 111.6(a).
17. On information and belief, OGC has not yet prepared a report for the Commission pursuant
to 11 C.F.R. § 111.7 containing a preliminary legal and factual analysis of the
administrative complaint and any responses received.
18. Although the administrative complaint has been pending for well over nine months and the
2020 presidential campaign cycle is already underway, it appears the Commission has not
1
A few counts of the administrative complaint refer to Marc Elias, a partner at Perkins Coie and general
counsel of HFA. The administrative complaint did not separately name him as a respondent, however. His
actions contribute to the liability of Perkins Coie and/or HFA.
4
yet voted on whether there exists “reason to believe” any “possible violation[s]” of federal
campaign finance law occurred. Such a vote is necessary for Commission staff to begin
investigating the administrative complaint’s allegations.
THE ALLEGATIONS IN CRF’S ADMINISTRATIVE COMPLAINT
19. CRF’s administrative complaint alleges HFA and the DNC paid Christopher Steele, a
foreign national, to generate the Steele dossier, based primarily on lies and fabrications
from current and former Russian government officials and other foreign nationals. To mask
their key role in funding the dossier, HFA and the DNC funneled their payments through
their law firm, Perkins Coie, and failed to properly report the purposes of those payments
to the FEC as required by federal law. Their scheme closely resembled that for which the
defendants in United States v. Benton, 890 F.3d 697 (8th Cir. 2018), cert. denied, No. 18-
442, 2019 U.S. LEXIS 1966 (Mar. 18, 2019), were convicted.
20. The administrative complaint alleges Perkins Coie hired and paid over $1 million to Fusion
GPS, a “strategic intelligence” firm, to perform opposition research on then-candidate
Trump for HFA and the DNC. This opposition research was for purely political purposes,
and completely unrelated to the provision of legal advice or any ongoing or impending
litigation. See Ex. 1, ¶¶ 6-13.
21. HFA publicly reported all its payments to Perkins Coie from January 2016 through
December 2017 as being for “LEGAL SERVICES.” The DNC specified a variety of
different purposes for its payments to the firm. Neither HFA nor the DNC accurately
specified any of their payments were for opposition research or investigations into then-
candidate Trump. See Ex. 1, ¶¶ 14-15.
5
22. The administrative complaint alleges that, by using Perkins Coie as a straw-man
intermediary and conduit, and falsely reporting the purposes of their payments to the firm,
HFA and the DNC were able to mask their role in subsidizing the Steele dossier from public
view and distance themselves from Fusion GPS—undermining the very transparency
campaign finance law was established to promote. Cf. Benton, 890 F.3d at 708-10.
23. The administrative complaint alleges Fusion GPS paid at least $168,000 to Christopher
Steele, a foreign national and director of London-based firm Orbis (also known as Orbis
Business Intelligence Ltd.) to gather information about alleged connections between
Trump and Russia. Steele—acting as a paid sub-agent of HFA and/or the DNC—solicited
foreign nationals, including Russian citizens and current and former members of the
Russian government and Russian intelligence, to provide valuable information, evidence,
files, documents, records, electronic storage media, or other things relating to Trump.
24. Steele compiled the dubious and largely unverifiable information he received from foreign
sources of questionable credibility into a “dossier” concerning Trump. Steele provided the
dossier, through Orbis, Fusion GPS, and Perkins Coie, to HFA and the DNC.
THE COUNTS IN CRF’S ADMINISTRATIVE COMPLAINT
25. The administrative complaint alleges the respondents violated campaign finance law in
several ways.
26. Count I alleges HFA and the DNC filed false campaign finance reports in violation of 52
U.S.C. § 30104(b) by improperly reporting the purposes of some of their payments to
Perkins Coie. Neither HFA nor the DNC reported any of nearly $13 million they
collectively paid Perkins Coie was for opposition research; investigations into Donald
6
Trump; the Steele Dossier; payments to Fusion GPS, Orbis, or Christopher Steele; or any
other purpose that would accurately reveal the true nature of the payments.
27. Count II alleges HFA and the DNC filed false campaign finance reports in violation of 52
U.S.C. § 30104(b) by using Perkins Coie as a straw-man intermediary and conduit to mask
their payments to Fusion GPS, Orbis, and Christopher Steele for the Steele Dossier. HFA
and the DNC retained Fusion GPS to perform a background investigation of, and
opposition research into, Donald Trump solely for political purposes. That investigation
was unrelated to any legal work or advice Perkins Coie was providing and was not
performed in connection with any pending or potential litigation. HFA and the DNC
retained and paid Fusion GPS through Perkins Coie, rather than doing so directly, solely
for the purpose of obscuring their payments to Fusion GPS and avoiding publicly reporting
them.
28. Count III alleges Perkins Coie aided and abetted HFA’s and the DNC’s false campaign
finance reports alleged in Count II, by allowing itself to be used as a straw-man
intermediary and conduit. Perkins Coie retained Fusion GPS to perform a background
investigation of, and opposition research into, Donald Trump solely for political purposes.
As noted above, that investigation was unrelated to any legal work or advice Perkins Coie
was providing and was not performed in connection with any pending or potential
litigation. Perkins Coie funneled funds from HFA and the DNC to Fusion GPS solely for
the purpose of allowing HFA and the DNC to obscure their payments to Fusion GPS and
avoiding publicly reporting them.
29. Count IV alleges Christopher Steele violated 52 U.S.C. § 30121(a)(2) and 11 C.F.R.
§ 110.20(g) by soliciting other foreign nationals, including but not limited to Russian
7
citizens and current and former members of the Russian government and Russian
intelligence services, for things of value—including but not limited to files, records,
information, recordings, videos, and other evidence concerning Donald Trump—in
connection with the 2016 presidential election. At the time, he was acting as a sub-agent
of HFA and/or the DNC.
30. Count V alleges HFA violated 11 C.F.R. § 110.20(b)(1) by substantially assisting Steele in
his solicitation of foreign nationals. Marc Elias, HFA’s general counsel, directed the
payment to Fusion GPS to hire Orbis and/or Steele to solicit foreign nationals for things of
value in connection with the 2016 presidential election.
31. Count VI alleges Steele, a foreign national, violated 52 U.S.C. § 30121(a)(1) by providing
the Steele Dossier, funded by HFA and the DNC, to David Korn of the Washington Bureau
of Mother Jones with the intent of influencing the 2016 election by securing Trump’s
defeat. By releasing the dossier to Mother Jones, he ensured its baseless claims would be
widely distributed before the campaign, alleviating the need for HFA or the DNC to pay
for advertising to disseminate its contents themselves and preserving the secrecy shrouding
its funders.
32. Count VII alleges the DNC, HFA, and Steele violated 11 C.F.R. § 110.20(i) by allowing a
foreign national, Steele, to participate in the election-related activities and decision-making
of the DNC and HFA. By providing the false, derogatory, and defamatory allegations in
the Steele Dossier to the DNC and HFA (through Fusion GPS and Perkins Coie), Steele
indirectly participated in their decision-making processes concerning their expenditures
relating to the 2016 presidential election.
8
THE ADMINISTRATIVE COMPLAINT PROCEDURE
33. 52 U.S.C. § 30109(a)(1) authorizes any person to file a written, signed, sworn, and
notarized complaint with the FEC alleging a violation of federal campaign finance law.
34. Within five days of receiving the administrative complaint, the FEC must notify “any
person alleged in the complaint to have committed such a violation.” 52 U.S.C.
§ 30109(a)(1). Any such person “shall have the opportunity to demonstrate, in writing, to
the Commission within 15 days after notification that no action should be taken” pursuant
to the Complaint. Id.
35. After the respondents have been given an opportunity to submit a responsive filing, the
Commission must vote on whether “it has reason to believe” a person violated federal
campaign finance law. It takes the votes of four Commissioners to approve such a “reason
to believe” (“RTB”) finding. The RTB vote is based solely on the administrative complaint,
any responsive filings, and potentially public FEC records; the Commission is not
permitted to undertake any investigation of the complaint or its allegations prior to an RTB
finding. Id. § 30109(a)(2).
36. Upon making an RTB finding, the Commission must notify the person alleged to have
violated the law and “make an investigation of such alleged violation, which may include
a field investigation or audit.” Id.
37. At the conclusion of the Commission’s investigation, OGC must prepare a report setting
forth “the legal and factual issues of the case.” A copy of the report is provided to each
respondent, and they have an opportunity to submit a responsive filing. Id. § 30109(a)(3).
38. In most cases, upon receiving OGC’s report of the investigation, the Commission must
vote whether “probable cause” exists to believe federal campaign finance law was violated.
9
It takes the votes of four Commissioners to make such a probable cause determination. Id.
§ 30109(a)(3), (a)(4)(A)(i).
39. After the Commission makes a probable cause determination, it must attempt to enter into
a conciliation agreement with the respondents for a period of 30-90 days. It takes the votes
of four Commissioners to approve any such conciliation agreement. Id.
§ 30109(a)(4)(A)(i).
40. If the Commission is unable to reach a conciliation agreement with the respondent, then
upon a vote of four Commissioners it may seek monetary or injunctive relief in U.S.
District Court. Id. § 30109(a)(6)(A).
41. In cases involving violations of certain disclosure requirements, including 52 U.S.C.
§ 30104(a), (c), (e)-(g), (i); id. § 30105, in contrast, the Commission does not make
“probable cause” determinations, but instead simply determines the disclosure requirement
was violated and imposes a civil monetary penalty. Id. §§ 30109(a)(4)(C)(i)(I)-(II),
(a)(4)(C)(iv)(I)-(II). Such penalties are subject to judicial review. Id. § 30109(a)(4)(C)(iii).
COUNT I – FAILURE TO ACT UNDER 52 U.S.C. § 30109(8)(A)
42. CRF hereby realleges and incorporates by reference the allegations set forth in Paragraphs
1 to 41 as if fully set forth herein.
43. CRF filed its administrative complaint alleging violations of federal campaign finance law
with the FEC on August 1, 2018.
44. Over 120 days—specifically, 294 days—have elapsed since CRF filed its administrative
complaint, and the FEC has failed to act. In particular, on information and belief, the FEC
has not even made a “Reason to Believe” finding pursuant to 52 U.S.C. § 30108(a)(2) based
on the administrative complaint and any responses received thereto.
10
45. Without a Reason to Believe finding, the FEC cannot even initiate an investigation into the
administrative complaint’s allegations. See 52 U.S.C. § 30108(a)(2).
46. CRF is aggrieved by the Commission’s failure to act on its administrative complaint. 52
U.S.C. § 30109(a)(8)(A) provides, “Any party aggrieved . . . by a failure of the Commission
to act” on an administrative complaint “during the 120-day period beginning on the date
the complaint is filed, may file a petition with the United States District Court for the
District of Columbia.” The Court may rule the Commission’s “failure to act is contrary to
law, and may direct the Commission to conform with such declaration within 30 days.” Id.
§ 30109(a)(8)(C).
47. The Commission’s failure to act on CRF’s administrative complaint is arbitrary, capricious,
contrary to law, and an abuse of discretion.
WHEREFORE, Plaintiff CRF is entitled to relief under 52 U.S.C. § 30109(a)(8).
PRAYER FOR RELIEF
WHEREFORE, Plaintiff CRF prays for the following relief:
1. A declaratory judgment CRF is entitled to relief under 52 U.S.C. § 30109(a)(8)(A), (C)
and the FEC’s failure to act on the administrative complaint is arbitrary, capricious,
contrary to law, or an abuse of discretion.
2. An injunction compelling the Commission, pursuant to 52 U.S.C. § 30109(a)(8)(C):
a. to vote pursuant to 52 U.S.C. § 30109(a)(2), no more than thirty (30) days from the
date of this Court’s order, on whether there exists reason to believe each of the
Respondents in the administrative complaint has violated the cited provisions of
federal campaign finance law based on the administrative complaint’s allegations
and any responsive filings; and
11
b. in the event the Commission makes one or more “reason to believe” findings in
connection with the administrative complaint, to conduct its investigation, vote on
whether probable cause exists to believe campaign finance laws have been violated
pursuant to 52 U.S.C. § 30109(a)(3), and take any other subsequent steps necessary
to enforce the legal provisions at issue, without unreasonable delay.
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 22nd day of May, 2019.
Respectfully submitted,
/s/ Dan Backer

DC Bar # 996641
POLITICAL.LAW
441 North Lee Street, Suite 300
Alexandria, VA 22314
(202) 210-5431
dan@political.law
Counsel for Coolidge
Reagan Foundation
VERIFICATION
I, Dan Backer, declare under penalty of perjury that the foregoing is true and correct to
the best of my personal knowledge. Executed on May 22, 2019.
/s/ Dan Backer

Counsel for Coolidge
Reagan Foundation
12
Case 1:19-cv-01493-ESH Document 1-1 Filed 05/22/19 Page 1 of 2
CIVIL COVER SHEET
JS-44 (Rev. 6/17 DC)
I. (a) PLAINTIFFS DEFENDANTS
(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF _____________________ COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT _____________________
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED
(c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER) ATTORNEYS (IF KNOWN)
II. BASIS OF JURISDICTION III. CITIZENSHIP OF PRINCIPAL PARTIES (PLACE AN x IN ONE BOX FOR
(PLACE AN x IN ONE BOX ONLY) PLAINTIFF AND ONE BOX FOR DEFENDANT) FOR DIVERSITY CASES ONLY!
o 1 U.S. Government o 3 Federal Question

PTF DFT
o1 o1
PTF
o4 o4
DFT
Plaintiff (U.S. Government Not a Party) Citizen of this State Incorporated or Principal Place
of Business in This State
o 2 U.S. Government o 4 Diversity Citizen of Another State o2 o2 Incorporated and Principal Place o5 o5
Defendant (Indicate Citizenship of
of Business in Another State
Parties in item III) Citizen or Subject of a
Foreign Country
o3 o3 Foreign Nation o6 o6
IV. CASE ASSIGNMENT AND NATURE OF SUIT
(Place an X in one category, A-N, that best represents your Cause of Action and one in a corresponding Nature of Suit)
o A. Antitrust o B. Personal Injury/ o C. Administrative Agency o D. Temporary Restraining
Malpractice Review Order/Preliminary
410 Antitrust Injunction
310 Airplane 151 Medicare Act
315 Airplane Product Liability Any nature of suit from any category
320 Assault, Libel & Slander Social Security
may be selected for this category of
861 HIA (1395ff)
330 Federal Employers Liability case assignment.
862 Black Lung (923)
340 Marine
863 DIWC/DIWW (405(g)) *(If Antitrust, then A governs)*
345 Marine Product Liability
864 SSID Title XVI
350 Motor Vehicle
865 RSI (405(g))
355 Motor Vehicle Product Liability
Other Statutes
360 Other Personal Injury
891 Agricultural Acts
362 Medical Malpractice
893 Environmental Matters
365 Product Liability
890 Other Statutory Actions (If
367 Health Care/Pharmaceutical
Administrative Agency is
Personal Injury Product Liability
Involved)
368 Asbestos Product Liability
o E. General Civil (Other) OR o F. Pro Se General Civil

Real Property Bankruptcy Federal Tax Suits 462 Naturalization
210 Land Condemnation 422 Appeal 27 USC 158 870 Taxes (US plaintiff or Application
220 Foreclosure 423 Withdrawal 28 USC 157 defendant) 465 Other Immigration
230 Rent, Lease & Ejectment 871 IRS-Third Party 26 USC Actions
240 Torts to Land Prisoner Petitions 7609 470 Racketeer Influenced
245 Tort Product Liability 535 Death Penalty
& Corrupt Organization
540 Mandamus & Other Forfeiture/Penalty
290 All Other Real Property 480 Consumer Credit
550 Civil Rights 625 Drug Related Seizure of
Property 21 USC 881 490 Cable/Satellite TV
Personal Property 555 Prison Conditions
690 Other 850 Securities/Commodities/
370 Other Fraud 560 Civil Detainee – Conditions
Exchange
371 Truth in Lending of Confinement
Other Statutes 896 Arbitration
380 Other Personal Property
375 False Claims Act 899 Administrative Procedure
Damage Property Rights
820 Copyrights 376 Qui Tam (31 USC Act/Review or Appeal of
385 Property Damage
830 Patent 3729(a)) Agency Decision
Product Liability
835 Patent – Abbreviated New 400 State Reapportionment 950 Constitutionality of State
Drug Application 430 Banks & Banking Statutes
840 Trademark 450 Commerce/ICC 890 Other Statutory Actions
Rates/etc. (if not administrative agency
460 Deportation review or Privacy Act)
o G. Habeas Corpus/ o H. Employment o I. FOIA/Privacy Act o J. Student Loan
2255 Discrimination
530 Habeas Corpus – General 442 Civil Rights – Employment 895 Freedom of Information Act 152 Recovery of Defaulted
510 Motion/Vacate Sentence (criteria: race, gender/sex, 890 Other Statutory Actions Student Loan
463 Habeas Corpus – Alien national origin, (if Privacy Act) (excluding veterans)
Detainee discrimination, disability, age,
religion, retaliation)
*(If pro se, select this deck)* *(If pro se, select this deck)*
o K. Labor/ERISA o L. Other Civil Rights o M. Contract o N. Three-Judge

(non-employment) (non-employment) Court
110 Insurance
710 Fair Labor Standards Act 441 Voting (if not Voting Rights 120 Marine 441 Civil Rights – Voting
720 Labor/Mgmt. Relations Act) 130 Miller Act (if Voting Rights Act)
740 Labor Railway Act 443 Housing/Accommodations 140 Negotiable Instrument
751 Family and Medical 440 Other Civil Rights 150 Recovery of Overpayment
Leave Act 445 Americans w/Disabilities – & Enforcement of
790 Other Labor Litigation Employment Judgment
791 Empl. Ret. Inc. Security Act 446 Americans w/Disabilities – 153 Recovery of Overpayment
Other of Veteran’s Benefits
448 Education 160 Stockholder’s Suits
190 Other Contracts
195 Contract Product Liability
196 Franchise
V. ORIGIN
o 1 Original o 2 Removed o 3 Remanded o 4 Reinstated o 5 Transferred o 6 Multi-district o 7 Appeal to o 8 Multi-district
Proceeding from State from Appellate or Reopened from another Litigation District Judge Litigation –
Court Court district (specify) from Mag. Direct File
Judge
VI. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE.)
VII. REQUESTED IN CHECK IF THIS IS A CLASS DEMAND $ Check YES only if demanded in complaint
ACTION UNDER F.R.C.P. 23 YES NO
COMPLAINT JURY DEMAND:
VIII. RELATED CASE(S) (See instruction) If yes, please complete related case form
YES NO
IF ANY
DATE: _________________________ SIGNATURE OF ATTORNEY OF RECORD _________________________________________________________
INSTRUCTIONS FOR COMPLETING CIVIL COVER SHEET JS-44

Authority for Civil Cover Sheet
The JS-44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and services of pleadings or other papers as required
by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the
Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of Court for each civil complaint filed.
Listed below are tips for completing the civil cover sheet. These tips coincide with the Roman Numerals on the cover sheet.
I. COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF/DEFENDANT (b) County of residence: Use 11001 to indicate plaintiff if resident
of Washington, DC, 88888 if plaintiff is resident of United States but not Washington, DC, and 99999 if plaintiff is outside the United States.
III. CITIZENSHIP OF PRINCIPAL PARTIES: This section is completed only if diversity of citizenship was selected as the Basis of Jurisdiction
under Section II.
IV. CASE ASSIGNMENT AND NATURE OF SUIT: The assignment of a judge to your case will depend on the category you select that best
represents the primary cause of action found in your complaint. You may select only one category. You must also select one corresponding
nature of suit found under the category of the case.
VI. CAUSE OF ACTION: Cite the U.S. Civil Statute under which you are filing and write a brief statement of the primary cause.
VIII. RELATED CASE(S), IF ANY: If you indicated that there is a related case, you must complete a related case form, which may be obtained from
the Clerk’s Office.
Because of the need for accurate and complete information, you should ensure the accuracy of the information provided prior to signing the form.
AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURT

for the
District
__________ of Columbia
District of __________
)
)
)
)
Plaintiff(s) )
)
v. Civil Action No.
)
)
)
)
)
Defendant(s) )
SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)

was received by me on (date) .
I personally served the summons on the individual at (place)

on (date) ; or
I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or
I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of (name of organization)
on (date) ; or
I returned the summons unexecuted because ; or
Other (specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:


for the
District
)
)
)
)
Plaintiff(s) )
)
v. Civil Action No.
)
)
)
)
)
Defendant(s) )
CLERK OF COURT
Date:
Civil Action No.
PROOF OF SERVICE


on (date) ; or

on (date) ; or
Other (specify):
.
Date:
Server’s address


for the
District
)
)
)
)
Plaintiff(s) )
)
v. Civil Action No.
)
)
)
)
)
Defendant(s) )
CLERK OF COURT
Date:
Civil Action No.
PROOF OF SERVICE


on (date) ; or

on (date) ; or
Other (specify):
.
Date:
Server’s address

Coolidge Reagan Foundation V FEC

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Coolidge Reagan Foundation V FEC

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Case 1:19-cv-01493-ESH Document 1 Filed 05/22/19 Page 1 of 12

U.S. DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

declaratory relief and alleges as follows:

Democratic National Committee (“DNC”) violated campaign finance law by conspiring

to manipulate the results of the 2016 election.

Christopher Steele to generate the so-called “Steele Dossier”—a thoroughly debunked

collection of lies and spurious allegations intended to discredit then-candidate Donald

they funneled abroad to pay for the fraudulent document.

The U.S. Supreme Court recently upheld those convictions.

triggering Independent Counsel Robert Mueller’s investigation into alleged collusion

(“FISA”) to engage in unprecedented surveillance against a presidential candidate and,

later, President-elect of the opposing political party.

based on an administrative complaint, any response, and publicly available campaign

cf. id. § 30109(a)(6).

pursuant to 52 U.S.C. § 30109(a)(8). FEC Chairwoman Ellen Weintraub has publicly

from Gridlock, MOTHER JONES (Feb. 20, 2019), at

nuclear-option-to-rescue-the-agency-from-gridlock/. She has also announced she might

second nuclear option: refuse to comply with the court order.”).

capricious, and contrary to law.

JURISDICTION AND VENUE

under a federal statute.

the U.S. Government.

10. Plaintiff COOLIDGE-REAGAN FOUNDATION (“CRF”) is a § 501(c)(3) non-profit

THE FEC’S FAILURE TO TAKE ACTION

authorized presidential candidate committee; the DNC, a national political party

perjury as required by 52 U.S.C. § 30109(a)(1).

to 11 C.F.R. § 111.7 containing a preliminary legal and factual analysis of the

administrative complaint and any responses received.

investigating the administrative complaint’s allegations.

THE ALLEGATIONS IN CRF’S ADMINISTRATIVE COMPLAINT

GPS, a “strategic intelligence” firm, to perform opposition research on then-candidate

litigation. See Ex. 1, ¶¶ 6-13.

candidate Trump. See Ex. 1, ¶¶ 14-15.

Business Intelligence Ltd.) to gather information about alleged connections between

Russian government and Russian intelligence, to provide valuable information, evidence,

THE COUNTS IN CRF’S ADMINISTRATIVE COMPLAINT

U.S.C. § 30104(b) by improperly reporting the purposes of some of their payments to

finance reports alleged in Count II, by allowing itself to be used as a straw-man

avoiding publicly reporting them.

information, recordings, videos, and other evidence concerning Donald Trump—in

of HFA and/or the DNC.

value in connection with the 2016 presidential election.

foreign national, Steele, to participate in the election-related activities and decision-making

indirectly participated in their decision-making processes concerning their expenditures

relating to the 2016 presidential election.

THE ADMINISTRATIVE COMPLAINT PROCEDURE

person alleged in the complaint to have committed such a violation.” 52 U.S.C.

to the Complaint. Id.

finding. Id. § 30109(a)(2).

a field investigation or audit.” Id.

of four Commissioners to approve any such conciliation agreement. Id.

District Court. Id. § 30109(a)(6)(A).

41. In cases involving violations of certain disclosure requirements, including 52 U.S.C.

was violated and imposes a civil monetary penalty. Id. §§ 30109(a)(4)(C)(i)(I)-(II),

(a)(4)(C)(iv)(I)-(II). Such penalties are subject to judicial review. Id. § 30109(a)(4)(C)(iii).

COUNT I – FAILURE TO ACT UNDER 52 U.S.C. § 30109(8)(A)

1 to 41 as if fully set forth herein.

with the FEC on August 1, 2018.

on the administrative complaint and any responses received thereto.

administrative complaint’s allegations. See 52 U.S.C. § 30108(a)(2).

U.S.C. § 30109(a)(8)(A) provides, “Any party aggrieved . . . by a failure of the Commission

contrary to law, and an abuse of discretion.

WHEREFORE, Plaintiff CRF is entitled to relief under 52 U.S.C. § 30109(a)(8).

DATE: _ SIGNATURE OF ATTORNEY OF RECORD _________________________________