In a briefing filed with its motion to supplement the complaint, the CDP stresses that “in determining whether the FEC’s delay in addressing the Administrative Complaint is ‘unlawful,’ one of the most important factors this Court must consider is the length of time it has been pending before the agency.” Thus, the CDP argues, “in determining whether the FEC’s ‘failure to act is contrary to law,’ the pertinent time period should now be over one year, rather than four months,” and the court should allow it to update the complaint accordingly.
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