Case 1:15-cv-01397-TSC Document 90 Filed 10/13/17 Page 1 of 56 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) LEVEL THE PLAYING FIELD, et al., ) ) Plaintiffs, ) Civ. No. 15-1397 (TSC) ) v. ) ) FEDERAL ELECTION COMMISSION, ) MOTION FOR SUMMARY ) JUDGMENT Defendant. ) ) FEDERAL ELECTION COMMISSION’S MOTION FOR SUMMARY JUDGMENT In accordance with the Court’s Minute Order of August 17, 2017, 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’ motion for summary judgment (Docket No. 83). 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 and a Proposed Order. Respectfully submitted, Lisa J. Stevenson (D.C. Bar No. 457628) /s/ Robert W. Bonham III Acting General Counsel Robert W. Bonham III (D.C. Bar No. 397859)
[email protected] Senior Attorney
[email protected] Kevin Deeley Associate General Counsel Haven G. Ward (D.C. Bar No. 976090)
[email protected] Attorney
[email protected] Charles Kitcher (D.C. Bar No. 986226) Acting Assistant General Counsel COUNSEL FOR DEFENDANT
[email protected] FEDERAL ELECTION COMMISSION 999 E Street, N.W. Case 1:15-cv-01397-TSC Document 90 Filed 10/13/17 Page 2 of 56 Washington, DC 20463 October 13, 2017 (202) 694-1650 2 Case 1:15-cv-01397-TSC Document 90 Filed 10/13/17 Page 3 of 56 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) LEVEL THE PLAYING FIELD, et al., ) ) Plaintiffs, ) Civ.