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FEDERAL ELECTION COMMISSION In the matter of Newton L. Gingrich Calista Gingrich ‘Newt 2012, Ine. and Lisa Lisker, in her MUR No. __ capacity as Treasurer of Newt 2012, Inc Gingrich Productions, Ine. COMPLAINT |. Citizens for Responsibility and Ethies in Washington ("CREW") and Melanie Sloan bring this complaint before the Federal Eletion Commission (“FEC”) seeking an immediste investigation and enforcement action against Newton L. Gingrich, Callista Gingrich, ‘Newt 2012, In., and Gingrich Productions, Inc. for direct and serious violations ofthe Federal Election Campaign Act (“FECA”). ‘Complainants 2 Complainant CREW is non-profit corporation, organized under section '501(c)3) ofthe Internal Revenue Code, CREW is committed to protecting the righ of citizens to be informed about the activities of government officials and to ensuring the integrity of government officials. CREW is dedicated to empowering citizens to have an influential voice in {government decisions and in the govemmental decision making process. CREW uses a sion of research, tigation, and advocacy to advance its mission 2. In furtherance ofits mision, CREW seeks to expose unethical and iegal conduct ofthoseinvolved in government. One way CREW does this is by educating citizens ‘garding the integrity ofthe electoral process and our system of government, Toward this end CREW ‘monitors the campaign finance activities of those who run for federal office and publiczes those ‘who vilate federal campaign finance laws, Through its website, press leases and other rethods of dstibution, CREW also files complaints with he FEC whee it discovers violations ofthe FECA, Publicizing campaign finance violators and fling compla nts with the FEC serves (CREW misionofkepin the public informed about individuals and ents tat wolate campsign finance laws and detering future violations of campaign finarce la 4. Inonderto assess whether an individual, candidate, poltal committee or other regulated entity is complying with federal campaign finance law, CREW needs the information contained in receipts end disbursements report hat political committees must file pursuant to the FECA, 2 USC. §434(a)2); 11 CER. § 104.1. CREW is hindered in its programmatic activity when an individual, candidate, political committee or other regulated entity fil to éisclose campaign finance information in reports of receipts and disbursements roquired by the FECA. 5. CREW relies onthe FEC’s proper administration of the FECA’s reporting requirements because the FECA-mandated reports of receipts and disbursements are the only source of information CREW can use to determine ia candidat, poitel committee or other regulate entity is complying with the FECA, The proper administration ofthe FECA’s ‘poring requirements ineludes mandating that ll rpors of receipts an dlsbursements required by the FECA are properly and timely filed withthe FEC. CREW is hindered in ts programmatic activity when the FEC fails to propery administer the FECA’ reporting requirements 6. Complainant Melanie Sloan isthe executive director of Citizens for Resporsibility and Ethics in Washington, a citizen ofthe United States anda registered voter and resent ofthe District of Columbia. As a registered voter, Ms, Sloen is entitled to receive information contained in reports of receipts and disbursements required by the FECA, 2 US.C. § 434(a)(2j 11 CER. § 104.1. Ms, Sloan is harmed when a candidate, political committee or other regulated entity fils wo report campaign finance activity as required by the FECA. See FEC v. Akins, 924 US. 11, 19 (1998), quoting Buckley v. Valeo, 424 U.S. 1, 6667 (1976) (political committees must disclose contributors and disbursements to help voters understand ‘who provides which candidates with financial support), Ms, Sloan is Further harmed when the FEC failsto properly administer the FECA's reporting requirement, limiting ther ability to review campaign finance information 7. Newton L. Gingrich (hereinafe Republican nomination tobe President ofthe United States andthe former Chief Executive Officer 0° Gingrich Productions, Ine 8. Callie Gingrich isthe wife of Newt Gingrich and the current Chief Executive Officer Gingrich Productions, ine. 9. Newt 2012, Inc. is « Georgia non-profit corporation andthe principal campaign ‘committer of Newt Gingrich 10, Lisa Liskr is the Treasurer of Newt 2012, ne 11. Gingrich Produetions, Ine. sa Georgia for-profit corpration that sells books authored by Newt and Calista Gingrich Factual Allegations 12, uring the frst week of March 2011, News Gingrich began accepting

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