Case 1:19-cv-00908-APM-TJK-NJR Document 65 Filed 07/14/20 Page 1 of 106 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) TED CRUZ FOR SENATE, et al., ) ) Plaintiffs, ) Civ. No. 19-908 (NJR, APM, TJK) ) v. ) ) FEDERAL ELECTION COMMISSION, et al., ) SUMMARY JUDGMENT ) MOTION Defendants. ) ) DEFENDANT FEDERAL ELECTION COMMISSION’S MOTION FOR SUMMARY JUDGMENT Defendant Federal Election Commission (“Commission”) respectfully cross-moves this Court for an order (1) granting summary judgment to the Commission pursuant to Rule 56 of the Federal Rules of Civil Procedure and Local Civil Rule 7(h), and (2) denying plaintiffs’ summary judgment motion (Docket No. 61). In support of this motion, the Commission is filing a Memorandum in Support of Its Motion for Summary Judgment and in Opposition to Plaintiffs’ Motion for Summary Judgment; a Statement of Undisputed Material Facts and accompanying exhibits; a Statement of Genuine Issues in response to Plaintiff’s Statement of Undisputed Material Facts; and a Proposed Order. Lisa J. Stevenson (D.C. Bar No. 457628) Seth Nesin Acting General Counsel Attorney
[email protected] [email protected] Kevin Deeley Tanya Senanayake (D.C. Bar No. 1006218) Associate General Counsel Attorney
[email protected] [email protected] 1 Case 1:19-cv-00908-APM-TJK-NJR Document 65 Filed 07/14/20 Page 2 of 106 Harry J. Summers COUNSEL FOR DEFENDANT Assistant General Counsel FEDERAL ELECTION COMMISSION
[email protected] 1050 First Street NE Washington, DC 20463 (202) 694-1650 July 14, 2020 2 Case 1:19-cv-00908-APM-TJK-NJR Document 65 Filed 07/14/20 Page 3 of 106 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) TED CRUZ FOR SENATE, et al., ) ) Plaintiffs, ) Civ.