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Cases: Kean for Congress v. FEC: Plaintiff Filings

Legal Center Files on Behalf of Kean for Congress Committee

To view the Plantiff's Notice of Filing, click here.


Campaign Legal Center Files Joint Motion with FEC

The Campaign Legal Center filed today, along with the Federal Election Commission, a joint motion for a protective order in Kean for Congress Committee v. FEC. On February, 15th, 2005 , Federal judge John Bates issued an order to the Federal Election Commission to reconsider its decision in a key case involving a "stealth PAC" 527 group called Council for Responsible Government (CRG) in light of the Supreme Court's decision in McConnell v. FEC . The CLC is providing legal representation to the Kean for Congress Committee in this matter.

The joint motion for a protective order would guarantee confidentiality of materials filed by the FEC in the event the agency does not dismiss the Kean committee's administrative complaint that has been pending since 2000. The FEC has until April, 15th to notify the court about what action it will take on the Kean committee's complaint, and a hearing is scheduled in Federal court on that date.

Click here to view a copy of the motion for a protective order.

Click here to view the proposed order.


Plaintiff Files Notice of Recent FEC AO

On October 20, 2004, the plaintiff filed a notice in regard to a recent Advisory Opinion issued by the FEC.

Click here to view the notice.

Click here to view exhibit A - FEC's AO 2004-33.


Plaintiffs File Notice of Court Decision

On September 29, 2004, the plaintiffs filed a notice of court decision with the court referencing the recent District Court decision issued by Judge Kollar-Kotelly in Shays et al. v. FEC.

Click here to view the filing.


Kean Motion for Summary Judgement

On May 19, 2004, Kean for Congress filed a Motion for Summary Judgment backed by the Campaign Legal Center, alleging the FEC had misapplied precedent and acted arbitrarily and capriciously in dismissing the original complaint involving the Council for Responsible Government a year earlier.

Click here to view the Memorandum of Points and Authorities in Support of Summary Judgement.

Click here to view Motion Exhibit List.

Click here to view Exhibit 1

Click here to view Exhibit 2.

Click here to view Exhibit 3.

Click here to view Exhibit 4.

Click here to view Exhibit 5.

Click here to view Exhibit 6.

Click here to view Exhibit 7.

Click here to view the Statement of Undisputed Facts.


Kean Memo in Opposition to FEC's Motion to Dismiss

Kean for Congress submitted on April 22, 2004 its memorandum in opposition to the FEC's Motion to Dismiss - rejecting the defense's challenge to the plaintiff's standing - and alternative Motion for Summary Judgment.

Click here to read the memorandum in its entirety.


Kean for Congress Amended Complaint

On March 4, 2004, Kean for Congress filed its first amended complaint.

Click here to read the amended complaint.


Kean for Congress Opening Brief

On January 5, 2004, the plaintiff in Kean for Congress v. FEC filed its opening brief, which seeks review of the commission's dismissal last year of a complaint alleging that the Council for Responsible Government violated federal law by secretly funded mailings for Kean's opponent, a New Jersey Republican. The complaint, filed in the U.S. District Court for the District of Columbia , contends that the FEC's dismissal of the first complaint was "arbitrary, capricious, an abuse of discretion, and otherwise contrary to law."

Click here to read the Kean for Congress complaint in its entirety.