(CNN) - A day before the DNC's Rules and Bylaws Committee is set to determine how to seat the delegations of Florida and Michigan, the Clinton campaign's chief lawyer said the committee is compelled to seat both delegations fully and not award Barack Obama any delegates from Michigan.
In a letter addressed to the co-chairs of the RBC, Clinton lawyer Lyn Utrecht said both states have already been sufficiently punished because of lack of campaign activity.
"It is a bedrock principle of our Party that every vote must be counted, and thereby every elected delegate should be seated," Utrecht wrote. "The States have already been punished because no campaign activity was conducted in Florida or Michigan. There is no requirement or need to punish their duly elected delegates who represent the 2.3 million voters in Michigan and Florida who participated in the nominating process."
Utrecht also made clear the campaign will not accept a resolution in Michigan that awards Obama any delegates, since the Illinois senator took his name off the ballot there.
"Neither the DNC Rules nor the Michigan Delegate Selection Plan allow arbitrary reallocation of Uncommitted delegates to a candidate or arbitrary reallocation of delegates from one candidate to another," he wrote.
The Clinton campaign also said Friday that former Michigan Gov. Jim Blanchard and Florida State Senator Arthenia Joyner will make the case for the campaign at the hearing Saturday.