BH Group / fund

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STACK PACK FED SOC LEO

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SLUDGE

Former law professor Neomi Rao is facing headwinds in her judicial nomination, so Charles Koch’s Americans for Prosperity is stepping in.

:{:{Billionaire manufacturing magnate Charles Koch has for decades used his enormous wealth and political power to install elected officials (https://readsludge.com/2018/10/19/koch-and-adelson-come-to-the-rescue-of-trump-devotee-ron-desantis-in-florida/),}:

government administrators (https://www.salon.com/2016/06/19/big_men_on_campus_the_koch_brothers_university_donations_are_a_veiled_political_weapon/), and regulators (https://readsludge.com/2018/10/04/koch-backed-sec-commissioner-claims-corporate-law-is-in-the-public-interest/) who will keep the business interests of Koch Industries and other giant, heavily polluting companies in mind.}:

But Koch is also dipping into the judicial arena. One of his protegés has been nominated by President Trump and is poised to join the second-most powerful court in the United States, and Koch’s premier political spending group wants to make sure it happens.

In 2016, the Charles Koch Foundation (CKF) and a mystery donor combined to give $30 million to the George Mason University (GMU) law school, renaming it after the late, conservative Supreme Court Justice Antonin Scalia. Koch’s foundation put in $10 million, and the remaining $20 million, it was later discovered, was administered by Federalist Society officials through a 501(c)(4) nonprofit, BH Fund.

:{:{The grant established 12 new law professorships—nearly all the hires had ties to the conservative Federalist Society (https://legacy.tyt.com/2018/05/18/after-donation-administered-by-federalist-society-leaders-gmu-hired-professors-tied-to-the-federalist-society/)—}:

and founded two ideological law school centers (https://ia601201.us.archive.org/24/items/GMUASSLawMOU2016/GMU%20ASSLaw%20MOU%202016.pdf#page=6),

the Center for Liberty and Law and the Center for the Study of the Administrative State. The founder and director of the latter center was Neomi Rao (https://www.law.gmu.edu/assets/files/faculty/cv/rao.pdf), who had been a law professor at GMU since 2012. She previously clerked for the most conservative Supreme Court justice, Clarence Thomas, and was associate counsel and special advisor to President George W. Bush. She has never been a judge.}:

Rao took a leave of absence from George Mason in 2017 when President Donald Trump appointed her as director of the White House Office of Information and Regulatory Affairs (OIRA), Trump’s “regulation czar.”

:{:{The dean of the GMU law school told another donor to her center, corporate lobbyist and longtime Koch ally C. Boyden Gray (https://www.desmogblog.com/c-boyden-gray), that he hoped to lure her back to GMU with a $1.5-million professorship, funded by Gray, according to an email unearthed by GMU alumna Allison Pienta (}:

:{:{http://www.unkochmycampus.org/dec-20-2018-donor-control-at-gmu-update?rq=boyden%20gray).}:

“This chair would help me to entice Neomi to return home to Scalia Law after she dismantles the administrative state (https://www.documentcloud.org/documents/5750669-Antonin-Scalia-Law-School-Grant-Agreement.html#document/p2/a484188)

while serving at OIRA,” he wrote in a May 2017 letter to Gray. Gray gave another $3 million to the center, and it was renamed in his honor.}:}:

Dismantling the administrative state (p. 2) (https://www.documentcloud.org/documents/5750669-Antonin-Scalia-Law-School-Grant-Agreement.html#document/p2/a484234)

IFrame Content (https://www.documentcloud.org/documents/5750669-Antonin-Scalia-Law-School-Grant-Agreement/annotations/484234.html?embed=true&maxheight=750&maxwidth=500)

View entire document on DocumentCloud (https://www.documentcloud.org/documents/5750669-Antonin-Scalia-Law-School-Grant-Agreement.html#document/p2/a484234)

But instead of returning to the law school, Rao may be headed to the powerful D.C. Circuit Court of Appeals to fill the seat vacated by the newest Trump-appointed Supreme Court justice, Brett Kavanaugh. Rao’s GMU center hosted a conference (https://administrativestate.gmu.edu/rethinking-judicial-deference/) in 2016 that featured Kavanaugh, a fellow Federalist Society member, as keynote speaker.

Rao’s judgeship nomination is perhaps the crowning achievement of the Antonin Scalia Law School’s initiative to reshape the federal judiciary. In 2017, the law school’s Law and Economics Center, which CKF had been funding for years, drew up a funding proposal (https://www.documentcloud.org/documents/5751080-GMU-Law-and-Economics-Center-Federal-Judges-and.html) for the center’s “Federal Judges and Attorneys General Initiatives.”

‘Reshaping’ the Federal Bench

“The election of Donald Trump presents a historic opportunity for a new president to reshape the federal judiciary, reform the regulatory state, promote economic growth, and restore constitutional federalism,” reads the proposal.

The program educates newly appointed judges on economics and other issues so they will “be more likely to make sound decisions that support the rule of law and the free enterprise system.” The new Federal Judges Initiative will “cover topics expected to be highly relevant to the current presidential administration’s policy agenda, such as the economics of health care and health financing, financial services regulation, environmental and energy regulation, health and safety regulation, privacy, labor and employment law, and telecommunications regulation.”

As of 2017, over 5,000 judges and 700 state attorneys general had participated in at least one Law and Economics Center program. In the 2018 fiscal year, the Law and Economic Center requested over $1.7 million for its Judicial Education Budget.

“Rao’s transition from the Koch-funded Antonin Scalia School of Law to her nomination to the second-highest court in the country is exemplary of Koch’s successful strategy of leveraging George Mason University to exert influence on the judicial branch for decades to come,” Samantha Parsons, a GMU graduate and director of campaigns at the activist group UnKoch My Campus, told Sludge. “Her nomination should serve as a warning of the anti-democratic agenda we can expect throughout our nation’s judicial system should George Mason University succeed in its goals to facilitate the education and placement of hundreds of new federal judges under Trump’s presidency.”

:{:{In December, when Trump nominated Rao, Koch’s most prominent political advocacy organization, Americans for Prosperity, endorsed (https://americansforprosperity.org/afp-endorses-slate-of-highly-qualified-judicial-nominees/) her for the judgeship.}:

But Rao has since encountered some bumps in the road. Republican Missouri Sen. Josh Hawley said he has “deep concerns (https://www.axios.com/neomi-rao-dc-circuit-nominee-josh-hawley-concerns-228fe428-7944-430a-bc5c-71a50278ec38.html?utm_source=twitter&utm_medium=twsocialshare&utm_campaign=organic),” telling Axios that she may not be sufficiently anti-abortion.}:

At a recent Senate committee hearing, Iowa Republican Sen. Joni Ernst expressed concerns over Rao’s 1994 essay on date rape (https://www.washingtonpost.com/local/legal-issues/neomi-rao-pressed-on-past-writings-on-date-rape-at-hearing-on-her-judicial-nomination/2019/02/05/156b4784-28b4-11e9-b2fc-721718903bfc_story.html?utm_term=.e68dab1a1db9), which alleged that women who are raped while drunk are partially to blame for being raped. Rao’s OIRA has stalled issuing an employer guidance on sexual harassment for 15 months (https://theintercept.com/2019/02/04/neomi-rao-hearing-oira-brett-kavanaugh/), a process that normally takes no longer than 90 days, as David Dayen reported for The Intercept.

:{:{Americans for Prosperity will fund digital advertising and grassroots efforts (https://www.axios.com/neomi-rao-dc-circuit-nominee-josh-hawley-concerns-228fe428-7944-430a-bc5c-71a50278ec38.html?utm_source=twitter&utm_medium=twsocialshare&utm_campaign=organic)}:

in an attempt to sway public opinion in favor of Rao this week, according to Axios. On Tuesday morning, the Facebook ad archive (https://www.facebook.com/ads/archive/?active_status=all&ad_type=political_and_issue_ads&country=US&q=americans%20for%20prosperity) listed six AFP ads in favor of Rao, which began running on Monday. Each ad targets one Republican senator, including Ernst and Hawley, urgin Facebook users to tell their senator to vote for Rao’s D.C. Circuit Court nomination. Additional targeted senators are Ted Cruz (Texas), Marsha Blackburn (Tenn.), James Lankford (Okla.), and Ben Sasse (Neb.). The Google ad archive did not list any recent AFP purchases.}:

One of Americans for Prosperity’s Facebook ads supporting Neomi RaoFacebook Ad Archive

Americans for Prosperity did not reply to Sludge’s request for comment.

‘Regulatory Obstruction’

The American Constitution Society says OIRA, which is part of the Office of Management and Budget, “has embraced politicized regulatory obstruction (https://www.acslaw.org/acsblog/a-lesson-in-failure-oira-neomi-rao-and-deregulation-at-any-cost/) as its raison dêtre” under Rao. In OIRA’s 2018 report (https://www.whitehouse.gov/wp-content/uploads/2018/10/2018-Unified-Agenda-Cutting-the-Red-Tape.pdf), entitled “Cutting the Red Tape,” Rao writes, “we are working to push back the expansion of the administrative state, which has placed undue burdens on the public and impeded economic growth.”

Under Rao’s leadership, OIRA, has approved sweeping environmental deregulation by the EPA. Koch Industries, which Charles Koch runs, is a giant manufacturing conglomerate with subsidiaries that refine and transport oil, create paper products, and produce chemicals. The company is among the country’s biggest air and water polluters and has paid hundreds of millions of dollars for environmental violations. Koch and his brother David are lifelong libertarians who have fought taxes and regulations for decades.

“Rao has never seen a regulation she didn’t hate, and as a judge would dismantle 40 years of environmental and social progress,” Brett Hartl, government affairs director at the Center for Biological Diversity, said (https://www.buzzfeednews.com/article/zoetillman/trump-nominates-neomi-rao-brett-kavanaugh-seat) in a statement to Buzzfeed News. “Her confirmation would be the most damaging and regressive yet by Trump after Kavanaugh and Gorsuch.”

GMU is by far the biggest recipient of grants from the Charles Koch Foundation (CKF), which gives tens of millions of dollars each year to free-market higher education programs. Since 2005, CKF and the Charles Koch Institute have donated nearly $129 million to GMU, including over $34 million for the free-market Mercatus Center, according to Sludge’s analysis. Another free-market-focused GMU center, the Institute for Human Studies, has received $8.7 million.

The university has come under fire for allowing the CKF to impact hiring decisions (https://www.insidehighered.com/news/2018/05/01/koch-agreements-george-mason-gave-foundation-role-faculty-hiring-and-oversight). In the case of Florida State University, CKF was even allowed to control economics curricula (https://publicintegrity.org/federal-politics/koch-foundation-proposal-to-college-teach-our-curriculum-get-millions/).

AFP isn’t the only Koch-linked group to spend money to influence the judiciary. The Center for Media and Democracy reports that Donors Trust, a donor-advised fund that wealthy conservatives including Koch use to score tax deductions and potentially anonymize their donations to nonprofits, has bankrolled right-wing groups (https://www.prwatch.org/news/2019/02/13449/donorstrust-bankrolled-right-wing-judicial-appointments-trumps-acting-ag-and) such as the Judicial Crisis Network and its sister organization, the Judicial Education Project, which spent millions of dollars on ads supporting the Supreme Court confirmation of Neil Gorsuch. Donors Trust also funds the Federalist Society and, as Sludge recently reported, several Southern Poverty Law Center-designated hate groups (https://readsludge.com/2019/02/19/americas-biggest-charities-are-funneling-millions-to-hate-groups-from-anonymous-donors/).

Charles Koch Is Funding Rightwing, Pro-Trump Media, New Disclosure Reveals (https://readsludge.com/2018/11/21/charles-koch-is-funding-rightwing-pro-trump-media-new-disclosure-reveals/)

Koch Brothers Continue to Influence Tax Policy After Huge Cuts Last Year (https://readsludge.com/2018/06/18/koch-brothers-continue-to-influence-tax-policy-after-huge-cuts-last-year/)

Koch-Backed SEC Commissioner Claims Corporate Law is in the Public Interest (https://readsludge.com/2018/10/04/koch-backed-sec-commissioner-claims-corporate-law-is-in-the-public-interest/)

Author profile](https://readsludge.com/author/alex/)

Alex Kotch (https://readsludge.com/author/alex/)

Alex is a reporter at Sludge and a contributor to The Young Turks. He was previously part of the award-winning investigative team at International Business Times, and his other work has appeared in T

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Trump's unofficial Supreme Court advisor who was actively involved in all three of his justice nominations has been revealed as the sole trustee of a perplexing group that generated more than $80 million in dark money in 2018.

A unfiled tax return for Rule of Law Trust (RLT) shows the name of Federalist Society co-chairman Leonard Leo, according to CREW. The mysterious tax return also includes a number of questionable details that raise alarms about the origin of the money.

In its first year of operation, there were no employees or volunteers working the firm's main address which appears to be a virtual office located in Virginia. The only people associated with RLT have statuses similar to Leo being Federalist Society officials who now work as "consultants" or have a long history of ties to companies circulating dark money.

The company's mission statement also notes that it strives "to advance conservative principles and causes through communications, research, strategy and assistance to other organizations."

In addition to the mysterious cash circulating and the business' hallow history, it also appears to have funneled nearly $2.7 million in company expenditures through another business known as the BH Group.

*"The filing vastly expands the amount of money known to be flowing into the growing constellation of dark money groups tied to Federalist Society co-chairman Leonard Leo."

Leo is also listed as the partial owner of that firm. While there has been speculation of Leo's affiliation with the company, his true status within the company had not been confirmed until recently. The BH Group garnered attention back in 2016 after it donated a cool $1 million to Trump's first presidential election campaign. The firm also has a history of funneling funds for the purpose of campaign contributions.

Wellspring Committee and Judicial Crisis Network (JCN), both 501(c)(4) social welfare groups relatively similar to RLT, also funneled money through the BH Group to sway elections and Supreme Court nominations.

Here is a quick timeline of how dark money has influenced politics over the last four years:

In 2016, JCN shelled out millions of dollars to dissuade senators from considering President Barack Obama's last Supreme Court nominee, Judge Merrick Garland.

In 2017, JCN dumped millions into having Trump's first Supreme Court nominee Justice Neil Gorsuch fill the seat Obama's nominee was denied.

In 2018, the group repeated the same process to back Trump's second nomination of Justice Brett Kavanaugh.

Now, in 2020, JNC has poured millions into the confirmation of Trump's nomination, Amy Coney Barrett to quickly fill the seat of the late Ruth Bader Ginsburg before the upcoming election.

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The company's mission statement also notes that it strives "to advance conservative principles and causes through communications, research, strategy and assistance to other organizations."

*"The filing vastly expands the amount of money known to be flowing into the growing constellation of dark money groups tied to Federalist Society co-chairman Leonard Leo."

Here is a quick timeline of how dark money has influenced politics over the last four years:

In 2016, JCN shelled out millions of dollars to dissuade senators from considering President Barack Obama's last Supreme Court nominee, Judge Merrick Garland.

In 2017, JCN dumped millions into having Trump's first Supreme Court nominee Justice Neil Gorsuch fill the seat Obama's nominee was denied.

In 2018, the group repeated the same process to back Trump's second nomination of Justice Brett Kavanaugh.

Now, in 2020, JNC has poured millions into the confirmation of Trump's nomination, Amy Coney Barrett to quickly fill the seat of the late Ruth Bader Ginsburg before the upcoming election.

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:{ former United States Department of Justice trial attorney under ex-President Bill Clinton is probing Republican billionaire and ex-President Donald Trump donor Leonard Leo along with "his network of nonprofit groups," POLITICO exclusively reports.

Washington, D.C. Attorney General Brian Schwalb's investigation comes after the GOP billionaire and Federalist Society leader's trust fund, Marble Freedom Trust's latest Internal Revenue Service (IRS) filing revealed in June Leo's mission to control right-wing politics, according to a Truthout report.

Truthout notes the IRS filing obtained by progressive watchdog Accountable.US "shows the Federalist Society leader 'has dumped at least $411 million into fueling right-wing infrastructure in the U.S. since mid-2020.'"

POLL: Should Trump be allowed to hold office again?"

According to POLITICO, the probe also "comes after POLITICO reported in March that one of Leo's nonprofits — registered as a charity — paid his for-profit company tens of millions of dollars in the two years since he joined the company.'

The news outlet notes that "a few weeks later, a progressive watchdog group filed a complaint with the D.C. attorney general and the IRS requesting a probe into what services were provided and whether Leo was in violation of laws against using charities for personal enrichment."

POLITICO reports:

Best known as Donald Trump's White House 'court whisperer,' Leo played a behind-the-scenes role in the nominations of all three of the former president's Supreme Court justices and promoted them through his multi-billion-dollar network of nonprofits. Trump chose his three Supreme Court picks, Neil Gorsuch, Brett Kavanaugh and Amy Coney Barrett, from a list drawn up by Leo. More recently, Leo was the beneficiary of a $1.6 billion contribution, believed to be the biggest political donation in U.S. history.

"There are questions as to whether Leo-affiliated nonprofits have diverted substantial portions of their income and assets, directly or indirectly, to the personal benefit of Leonard Leo," the Campaign for Accountability's complaint said. "Such payments were generally listed as made in exchange for alleged consulting, research, public relations, or similar services. However CFA has reasonable questions about whether those alleged services were actually rendered at all or, if services were rendered, whether the payments made were substantially in excess of fair market value."

Per the report, "The news of the investigation comes as the nonprofit that was a subject of the complaint quietly relocated in recent weeks from the capital area to Texas, according to paperwork filed in Virginia and Texas," after "for nearly 20 years the nonprofit, now known as The 85 Fund, had been incorporated in Virginia."

The news outlet notes:

The Leo-aligned nonprofit The 85 Fund — which is registered as a tax-exempt charity — paid tens of millions of dollars to a public relations firm in Virginia which he co-chairs in the two years since he joined the firm, known as CRC Advisors. The watchdog complaintalleges the total amount of money that flowed from Leo-aligned nonprofits to his for-profit firms was $73 million over six years beginning in 2016.

According to POLITICO, attorney David B. Rivkin Jr., who represents the parties in the probe, "said in a statement that the complaint 'is sloppy, deceptive and legally flawed and we are addressing this fully with the DC Attorney General's office.'"

Politico's full report is available at this link.

HEIDI PRZYBYLA

08/22/2023

Washington

D.C. Attorney General Brian Schwalb is investigating judicial activist Leonard Leo and his network of nonprofit groups, according to a person with direct knowledge of the probe.

The scope of the investigation is unclear. But it comes after POLITICO reported in March that one of Leo’s nonprofits — registered as a charity — paid his for-profit company tens of millions of dollars in the two years since he joined the company. A few weeks later, a progressive watchdog group filed a complaint with the D.C. attorney general and the IRS requesting a probe into what services were provided and whether Leo was in violation of laws against using charities for personal enrichment.

David B. Rivkin Jr., an attorney for the parties in the investigation, said in a statement that the complaint “is sloppy, deceptive and legally flawed and we are addressing this fully with the DC Attorney General’s office.”

The news of the investigation comes as the nonprofit that was a subject of the complaint quietly relocated in recent weeks from the capital area to Texas, according to paperwork filed in Virginia and Texas. For nearly 20 years the nonprofit, now known as The 85 Fund, had been incorporated in Virginia.

Gabe Shoglow-Rubenstein, Schwalb’s communications director, declined to confirm or deny the existence of the probe, including whether the attorney general took any action in response to the complaint.

Schwalb, who took office in January, has a background in tax law and served as a trial attorney in the tax division of the Department of Justice under President Bill Clinton.

Best known as Donald Trump’s White House “court whisperer,” Leo played a behind-the-scenes role in the nominations of all three of the former president’s Supreme Court justices and promoted them through his multi-billion-dollar network of nonprofits. Trump chose his three Supreme Court picks, Neil Gorsuch, Brett Kavanaugh and Amy Coney Barrett, from a list drawn up by Leo. More recently, Leo was the beneficiary of a $1.6 billion contribution, believed to be the biggest political donation in U.S. history.

He is also the co-chair of the Federalist Society, the academic arm of the conservative legal movement, for which he worked in various capacities for decades while building his donor base.

While Leo grants few interviews, in mid-July he was featured in a two-part podcast with the Maine Wire, a conservative news organization. Asked why he’s become a “lightening rod for criticism,” Leo cited his commitment to “defend the Constitution” and spoke about the “long history” of dark money in U.S. politics.

“It’s not to hide in the shadows,” he said. “It’s because we want ideas judged by their own moral and intellectual force.”

He did not address any allegations of potential misuse of nonprofit tax law.

Real estate and other public records illustrate that the lifestyle of Leo and a handful of his allies took a lavish turn in the course of the making of the current ultraconservative court, beginning in 2016, the year he was tapped as an unpaid adviser to Trump. Citing the report, a progressive watchdog group called on the IRSand D.C. Attorney General a few weeks later to investigate whether the groups may be violating their tax-exempt status by “siphoning” assets or income for personal use.

Anthony Burke, a public affairs specialist with the IRS, declined to comment. “Under the federal tax law, federal employees cannot disclose tax return information,” he said.

The Leo-aligned nonprofit The 85 Fund— which is registered as a tax-exempt charity — paid tens of millions of dollars to a public relations firm in Virginia which he co-chairs in the two years since he joined the firm, known as CRC Advisors.

The watchdog complaintalleges the total amount of money that flowed from Leo-aligned nonprofits to his for-profit firms was $73 million over six years beginning in 2016.

“There are questions as to whether Leo-affiliated nonprofits have diverted substantial portions of their income and assets, directly or indirectly, to the personal benefit of Leonard Leo,” read the Campaign for Accountability’s complaint.

“Such payments were generally listed as made in exchange for alleged consulting, research, public relations, or similar services. However CFA has reasonable questions about whether those alleged services were actually rendered at all or, if services were rendered, whether the payments made were substantially in excess of fair market value,” said the complaint, which covers the period between 2016 and 2020.

POLITICO reported that a total of $43 million flowed to Leo’s company over two years and that the bulk of it came from The 85 Fund, a nonprofit run by his allies which has spent tens of millions of dollars over the past decade to promote Trump’s Supreme Court picks, file briefs before the court and, more recently, used an alias to push for voting restrictions and of cheating in the 2020 election.

It is now run by Carrie Severino, an attorney and former clerk for Justice Clarence Thomas listed as director in the group’s most recent IRS paperwork and is collecting massive amounts of anonymous funds: $117 million in 2021.

In discontinuing the group in the state of Virginia, the new address Severino listed is a virtual office suite in Fort Worth, Texas, shared by a “Two Men and a Truck”franchise. The office building advertises virtual and coworking spaces.

Further complicating the picture: in Texas, a new registration for “The 85 Fund” was filed on June 27 under yet a different address in a different city than the one listed on the Virginia paperwork. It is also registered in Texas as a for-profit entity.

This location is a UPS store in a strip mall next door to a restaurant called the “Snooty Pig Cafe.” As POLITICO previously reported, The 85 Fund had been using a UPS drop box in DC’s Georgetown neighborhood as its principal office address.

Beginning in 2016, Leo formed or helped reorganize two for-profit businesses — CRC Advisors and BH Group— to perform millions of dollars in services for his aligned nonprofits.

In those five years, BH Group brought in $15 million from the nonprofits. Yet unlike CRC, BH Group doesn’t appear to have advertised itself as a consulting or public relations firm, or even have had a website. During some of that time, Leo was employed full-time as a vice president at the nonprofit Federalist Society, raising questions about how he could have reasonably generated millions of dollars in consulting fees at the same time, the complaint says.

The 85 Fund’s switch to the Fort Worth office building came days after POLITICO inquired, on June 30, about certain Leo allies who may have personally benefited from millions in anonymous donations that moved through the 85 Fund over the past decade.

A number of the groups that receive contributions from Leo’s “dark money” network, in turn, hold sizable contracts with his firm, CRC Advisors. This includes the Federalist Society, the nation’s preeminent conservative debating society where Leo was executive vice president and still serves as co-chairman. Among payments the complaint flagged to the IRS and DC attorney general is $3.1 million which the Federalist Society paid to CRC between 2020 and 2021 for “media training.”

On July 7, a Leo spokesperson offered an initial response to inquiries POLITICO had made about The 85 Fund, previously known as the Judicial Education Project.That was the day paperwork with Severino’s signature was filed “surrendering” The 85 Fund’s charter in Virginia.

In the paperwork, Severino stated the plan to move to Texas was adopted by a majority of the board of directors on Dec. 8, 2022. It has three board members. In addition to Severino, they include treasurerGary Marx and chair Todd Graves,according to the latest IRS paperwork available.

It’s not the only major conservative nonprofit to have moved to Texas in recent years. The National Rifle Association, contesting multiple lawsuits from attorneys general in New York state and Washington, D.C., alleging violations of nonprofit law, announced in early 2021 that it would relocate to Texas.

Yael Fuchs, who was a senior lawyer on the New York case against the NRA, said Texas has limited regulation over charities, making it a more attractive legal environment for nonprofits.

“This gambit isn’t going to deprive the regulator [DC] of jurisdiction over past wrongdoing but it could create some hurdles,” she said. They include complications in gaining injunctive relief or obtaining evidence, “but there are ways of getting over those,” said Fuchs, former head of charities enforcement in the New York attorney general’s office.

It’s also not the first time a Leo-aligned group has shifted operations after media scrutiny.

A separate Leo-aligned group that appears to have been involved in the 2017 sale of GOP pollster Kellyanne Conway’s company was dissolved last fall,three days after POLITICO inquired about whether it helped to facilitate the multi-million-dollar deal while she was advising Trump on judicial candidates.

In his statement, Rivkin, the lawyer for the groups targeted in the CFA complaint, said CFA was connected to Arabella Advisors, a firm that was founded by former Bill Clinton appointee Eric Kessler. Leo has long compared his business practices to those of Arabella.

Both Michelle Kuppersmith, CFA executive director, and Steve Sampson, Arabella spokesperson, said their groups have no financial relationship. However, CFA was originally part of the Hopewell Fund, a nonprofit for which Arabella provides administrative support. CFA spun off from Hopewell in 2017, both groups confirmed.

Arabella is a for-profit company that provides administrative, HR and accounting services to largely philanthropic nonprofits which are largely independently run.

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The Religious Right movement, which gained considerable momentum during President Ronald Reagan's 1980 campaign, has had a complex relationship with Catholicism over the years. The Religious Right is dominated by far-right white evangelical Protestant fundamentalists, who are vehemently critical of Catholic practices (the confessional, physical images of Jesus). Yet Republican evangelicals will work with the Catholic right when it comes to fighting abortion or same-sex marriage.

The Catholic right is by no means universally loved by American Catholics. President Joe Biden and former House Speaker Nancy Pelosi (D-California), for example, are both known for being devout Catholics, but they are also major critics of the Religious Right and its influence on the U.S. Supreme Court — which the Catholic right now dominates. Justice Clarence Thomas, Justice Samuel Alito, Justice Brett Kavanaugh and Justice Amy Coney Barrett are all hard-right Catholics and GOP appointees who voted to overturn Roe v. Wade in the Dobbs v. Jackson Women’s Health Organization ruling of 2022.

In contrast, Justice Sonia Sotomayor, a Democratic Barack Obama appointee, is a Catholic who was a dissenter in Dobbs and has been a scathing critic of the High Court's current direction. She even used the word "stench" to express her disdain. Sotomayor is to the left of the Vatican, while Thomas, Alito and Barrett are to the right of the Vatican.

One of the Catholic right's most influential figures is judicial activist Leonard Leo, former executive vice president of the Federalist Society. Leo has spent decades lobbying to push the federal courts to the far right. And according to Politico's Heidi Przybyla, he has made a fortune in the process.

In an article published by Politico on March 1, Przybyla reports, "A network of political nonprofits formed by judicial activist Leonard Leo moved at least $43 million to a new firm he is leading, raising questions about how his conservative legal movement is funded. Leo's own personal wealth appeared to have ballooned as his fundraising prowess accelerated since his efforts to cement the Supreme Court's conservative majority helped to bring about its decision to overturn abortion rights. Most recently, Leo reaped a $1.6 billion windfall from a single donor in what is likely the biggest single political gift in U.S. history."

According to Przybyla, Politico's analysis of "dozens of financial, property and public records dating from 2000 to 2021" shows that Leo's "lifestyle took a lavish turn beginning in 2016." And his fortunes grew considerably during the Trump years, Przybyla reports.

The Politico journalist explains, "The spending by Leo-aligned nonprofits on his for-profit businesses coincided with changes in his personal lifestyle and finances. IRS and other public records between 2016 and 2020 show a major expansion of Leo's personal wealth that coincided with the start of his work for Trump and the creation of his own for-profit entity called BH Group. Both happened in 2016."

The former Federalist Society VP forcefully lobbied for many of the severe social conservatives who are now on the U.S. Supreme Court, including Barrett. In 2016, he encouraged then-Senate Majority Leader Mitch McConnell (R-Kentucky) to do everything he could to derail then-President Barack Obama's nomination of Merrick Garland following the death of Justice Antonin Scalia (a far-right Catholic social conservative). It worked; that seat stayed open until 2017, when then-President Donald Trump appointed Justice Neil Gorsuch — another justice who voted to overturn Roe in 2022. Gorsuch was raised Catholic but has more recently attended an Episcopal church.

Trump was very specific about the type of justices he wanted: hardcore social conservatives. Former Justice Anthony Kennedy was a right-wing fiscally conservative 1987 Reagan appointee, but he was much more of a libertarian than Scalia, Alito or Thomas and often voted with Democratic justices when it came to abortion or gay rights. And that wasn't the type of justice that Trump and Leo wanted.

Przybyla notes, "The Court’s 2022 decision overturning half a century of the federal right to abortion was widely seen as a victory for the conservative legal movement led by Leo. Trump picked his Court nominees from a list drawn up by Leo, who then served as his unofficial adviser in the White House. A constellation of outside groups affiliated with Leo poured tens of millions of dollars in anonymous donor funds into promoting those nominees — Neil Gorsuch, Brett Kavanaugh and Amy Coney Barrett — thereby cementing a new conservative majority for the next generation."

Read Politico's full report at this link.

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Leonard Leo, the right-wing leader of the judicial activist network the Federalist Society, is coming under scrutiny for his "lavish" use of the organization's funds to live the high life, POLITICO reported on Wednesday.

"A network of political non-profits formed by judicial activist Leonard Leo moved at least $43 million to a new firm he is leading, raising questions about how his conservative legal movement is funded," reported Heidi Przybyla. "Leo’s own personal wealth appeared to have ballooned as his fundraising prowess accelerated since his efforts to cement the Supreme Court’s conservative majority helped to bring about its decision to overturn abortion rights. Most recently, Leo reaped a $1.6 billion windfall from a single donor in what is likely the biggest single political gift in U.S. history."

Leo has been a massively influential figure, often called Trump's "judge whisperer" for the outsized role he played in getting right-wing jurists seated who have been involved in everything from dismantling abortion rights, to rolling back voting and redistricting protections, to undermining the regulatory process.

According to POLITICO, which has obtained records of Leo's finances over the last two decades, Leo's personal wealth skyrocketed under President Donald Trump, with whom he worked closely to appoint a steady stream of right-wing judges to the federal bench including three at the Supreme Court — "the same period during which he erected a for-profit ecosystem around his longtime nonprofit empire that is shielded from taxes."

CRC Advisers, the consulting firm he created in 2020, did not respond to questions about what the $43 million is being used for. However, Leo, who led a "middle class lifestyle" prior for most of his time at the Federalist Society, began making extravagant purchases after the former president's election in 2016, including "two new mansions in Maine, four new cars, private school tuition for his children, hundreds of thousands of dollars in donations to Catholic causes and a wine buyer and locker at Morton’s Steakhouse."

Stetson University law professor Ciara Torres-Spelliscy, an expert on campaign finance, told POLITICO, “If millions of dollars in dark money are sloshing around, it makes it really easy for people on the inside to take a cut ... That behavior is, unfortunately, now showing in the judicial nominating process."

This is not the first time questions have been raised about Leo's financial activities. In 2019,The Washington Post flagged that Leo has helped right-wing nonprofits raise $250 million to promote his approved judges, with no transparency in the donors' identity. And another dark-money group, BH Ventures, which contributed $24 million to CRC Advisors and up to $5 million to former Trump adviser Kellyanne Conway's polling firm, shut down shortly after reporters began investigating it.

Alarmed Democrats have responded in force to the Federalist Society's efforts to remake federal courts. Since taking office, President Joe Biden has been confirming judges at an even faster pace than Trump did, with 97 seated in his first two years alone — often from a diverse array of racial and professional backgrounds.

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On December 20, 2022, Politico’s Heidi Przybyla reported that right-wing judicial activist and Federalist Society Vice President Leonard Leo appeared to “have helped facilitate” the sale of GOP strategist Kellyanne Conway’s business, The Polling Company, to the firm Creative Response Concepts (CRC) in 2017. Now, a month later, Przybyla is reporting that a “dark money group tied to” Leo was “dissolved” only “three days after Politico inquired about whether it helped to facilitate” that sale.

When Americans complain about the overturning of Roe v. Wade and the radical-right direction of the U.S. Supreme Court, Leo is one of the people they have to thank. Leo, the Federalist Society’s former vice president, played an important role in the appointment of far-right socially conservative justices like Amy Coney Barrett. Leo was a strong Barrett supporter when former President Donald Trump nominated her in 2020, and four years earlier, in 2016, he encouraged Sen. Mitch McConnell to do everything he could to derail then-President Barack Obama’s nomination of Merrick Garland (who is now U.S. attorney general under President Joe Biden).

One-third of the U.S. Supreme Court is now comprised of Donald Trump appointees, all of whom voted to overturn Roe v. Wadein the caseDobbs v. Jackson Women’s Health Organization. And Leo did everything he could to help Trump move the High Court to far right. That is in addition to all of the far-right judges Leo helped bring to the lower federal courts.

Przybyla, in an article published by Politico on January 20, explains, “The BH Fund, which was formed in 2016 with an anonymous $24 million donation, has been a nerve center for distributing millions of dollars around Leo’s network of dark-money groups bolstering former President Donald Trump’s Supreme Court picks. On the day of the 2017 sale of Conway’s polling business to the firm Creative Response Concepts Inc., a lawyer filed similar liens with Virginia regulators for both CRC and BH Fund, which financial experts say suggested the dark money group played a role in financing the transaction, Politico reported in late December.”

The 2017 sale, according to Przybyla, was “valued at between $1 million and $5 million” in Conway’s “federal filings” — and it “raised potential ethical concerns because Conway” was “simultaneously advocating with Trump for some of Leo’s favored judicial candidates.”

“But just three days after Politico’s inquiries,” Przybyla reports, “the BH Fund closed down, according to documents filed with the Virginia State Corporation Commission. Adam Kennedy, a spokesperson for the firm now known as CRC Advisors — which had performed extensive consulting work for Leo in 2017 and is now led by him— said the BH Fund has been dormant since the end of 2021. He confirmed it was dissolved in October ‘as other organizations made it obsolete.’”

Przybyla adds, “Indeed, Leo now controls more than $1.6 billion in conservative donor funds, and he is erecting a new architecture of dark-money groups to administer it. Critics have long maintained that understanding how Leo has distributed his trove of anonymous funds is critical to understanding how the conservative legal movement claimed a majority of the U.S. Supreme Court…. Under the current tax code, nonprofits like BH Fund can spend unlimited amounts of money on political activities without disclosing their donors — as long as they are deemed ‘social welfare’ activities that do not primarily promote a political candidate.”

One outspoken critic of dark money in politics is Saurav Ghosh, who serves as director of federal campaign finance reform for the Campaign Legal Center.

Ghost, discussing Leo’s role in the sale of Conway’s company, told Politico, “Nothing screams ‘efforts to conceal’ quite like folding up an organization just as you start getting questions about it…. (The) influence of dark money is doubly problematic once someone is in office because they’re (potentially) able to influence outcomes.”

After Politico published Przybyla’s December 20, 2022 article, Democratic Sen. Dick Durbin described her reporting on Conway and Leo as “further evidence of the troubling role that Leonard Leo and the Federalist Society played in driving Donald Trump’s judicial selection process.”

“Leo’s network of outside groups built successful advocacy campaigns around the nominations of Chief Justice John Roberts, Samuel Alito, Neil Gorsuch, Brett Kavanaugh and Amy Coney Barrett and blocked President Barack Obama’s nomination of Merrick Garland,” Przybyla notes. “BH Fund operated alongside two other Leo-linked entities to promote Trump’s nominees.”

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One outspoken critic of dark money in politics is Saurav Ghosh, who serves as director of federal campaign finance reform for the Campaign Legal Center.

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https://www.opensecrets.org/news/2018/03/secret-contributions-to-trump-inauguration/

rob mcg

the committee that ran President Trump’s inaugural celebrations and surrounding events in January 2017 recently filed its annual tax return with the IRS, giving the public its first glimpse at how it spent the record $107 million it raised in the months after the 2016 election.

But rather than clearing up the questions that swirl around the committee — about charitable contributions, secret donors and massive vendors paydays — the filing only adds to the mystery. So OpenSecrets teamed up with the “Trump Inc” podcast, a partnership between WNYC and ProPublica, to explore some of these questions.

We looked into suspiciously high vendor costs, which included a more than $50 million payday for two firms, and we trekked out to a small Virginia town to try to get to the bottom of what appears to be an anonymous shell corporation that gave $1 million to the inaugural committee.

The Dark Money Inauguration

Trump’s inauguration was not only a bonanza for special interests and high-dollar event planners, it was also a chance for wealthy donors and government contractors to show support for the new administration — and to do so in secret, if they choose.

Since inaugural committees were first required to report their donors to the Federal Election Commission in 2002, no inauguration has reported any significant contributions from secretive dark money groups or shell corporations.

That is, until Trump’s inauguration, which took $2 million from two entities whose sources of funding are mostly or entirely untraceable.

The first came on December 20, 2016, in the form of a $1 million check from a 501(c)(4) social welfare organization closely tied to Paul Ryan and the Republican establishment in the House. The group, called American Action Network, spent more than $5.5 million in 2016 to help House Republicans keep their majority.

Groups like American Action Network (AAN) can spend heavily in elections without disclosing their donors, which is why they are often referred to as “dark money” groups.

Such groups aren’t just conduits for wealthy individual donors to spend on elections without any fingerprints, they are also attractive to corporations that don’t want their name publicly tied to political attack ads. The beauty is that while the public may not know who provided the money, politicians and party officials almost certainly know who’s bankrolling the groups.

As OpenSecrets has previously reported, tax documents from other organizations show that AAN has received significant funding from trade associations like PhRMA and theAmerican Petroleum Institute that represent major corporations. In one instance, the health insurer Aetna accidentally disclosed a contribution to the group.

But AAN is downright transparent compared to a limited liability company called BH Group that, two days later, on December 22, gave another $1 million to the inaugural committee. Whereas AAN is an organization with a website, an agenda and employees, BH Group is largely a black hole.

BH Group appears to be little more than an anonymous shell corporation used to shield the original donor (or donors) who provided $1 million to President Trump’s inauguration

Very little is known about the company. Virginia incorporation records show that it was formed four months to the day before it handed its seven-figure check to the inaugural committee. And tax filings obtained by OpenSecrets last year show that sometime between its formation and the end of the year, the BH Group received $750,000 from another dark money group, the Wellspring Committee, as OpenSecrets first reported last November. The Wellspring Committee payment was for “Public Relations,” which is interesting given that the Wellspring Committee appears to have no public-facing operation.

BH Group was paid $750,000 for “Public Relations” by the Wellspring Committee, a dark money group that appears to have no public operations

We went to the address listed on BH Group’s incorporation records only to find that it’s a “virtual office” run by a company called Regus, which rents temporary and virtual office space and provides clients with “call answering services and mail handling.”

A Regus representative would not provide any names or contact information for BH Group, so we left empty-handed.

From there we headed out to Warrenton, Virginia, home to one of the most prominent conservative law firms in the country, Holtzman Vogel Josefiak Torchinsky (HVJT) — which is connected to both the inaugural committee and, potentially, BH Group.

The primary address the inaugural committee listed on its tax return was HVJT’s office. And BH Group’s incorporation records were signed by someone named Donna Smith, which happens to be the name of a longtime paralegal at the firm.

When we arrived at their offices on a Tuesday afternoon, we were not met with the bustle one might expect from one of the most prestigious law firms in the Washington area, but with silence. Many of the offices were dark, and no one was sitting at the reception desk. We rang the bell twice and, finally, someone strolled out to meet us.

We presented BH Group’s incorporation papers and asked if we could speak with Donna Smith about the company. The receptionist called Smith on the phone and proceeded to repeat the words “BH Group” over and over to an apparently stupefied Smith.

Moments later we were met, not by Donna Smith, but by HVJT partner Michael Bayes, who greeted us, but only provided a very lawyerly “we don’t have any comment on client matters” in response to our questions about Smith and BH Group.

We left their offices with little more than a first hand illustration of why wealthy donors and high-powered political operatives pay top dollar to retain the services of a firm like HVJT: discretion and protection.

It’s an axiom of political dark money that if you have enough money to spend millions on politics, you have enough money to hire the best lawyers in the country to cover your tracks. But one thing to keep in mind is that while the public doesn’t know who’s funding these groups, the people the groups support — in this case, Trump and his administration — almost certainly know, including the source of BH Group’s $1 million.

In other words, they know whose interests to keep in mind when deciding on a matter of policy, and they know whose call to answer when the phone rings.

Vendor Bonanza

On the spending side, the Trump inaugural simply doesn’t make sense. It’s just basic math.

President Obama’s first inauguration in 2009 spent a little under $51 million on five packed days of events and celebrations. Eight years later, the committee responsible for Trump’s inaugural festivities spent nearly double that, more than $97 million, on hardly 48 hours of events, with the rest going to charity.

Roughly speaking, that works out to about $8,600 per minute for Obama’s inauguration — from the morning of January 17, 2009, when he began his whistle-stop tour in Philadelphia, to the end of the National Prayer Service in Washington, D.C. on January 21.

Meanwhile, Trump’s inaugural committee spent about $37,000 per minute from the moment he laid a wreath at the Tomb of the Unknowns on the afternoon of January 19, to the end of the National Prayer Service on January 21.

Not only was Trump’s inauguration schedule shorter than President Obama’s, the inauguration’s less-than-historic turnout should have helped contain the costs that come with managing crowds at events and festivities outside of the swearing-in itself.

So the question is, how could an inauguration that Trump officials were selling as a “workmanlike” affair, and “not a coronation,” manage to spend nearly twice as much as an historic inauguration that was both longer, busier and better attended?

The new tax documents show that one way is to pay vendors an unprecedented amount of money for their services.

For example, the 2009 and 2017 inaugural committees made payments to a Maryland company called Hargrove Inc. for “event production services.” However, the 2009 inauguration paid just over $5 million, whereas the 2017 inaugural paid five times that.

(Bush 2005 numbers do not include contractor payments because such information was not required to be reported before 2008)

Hargrove did not respond to repeated calls and emails from OpenSecrets seeking explanation for what the Trump inauguration got for five times the cost.

But Hargrove was only one of two contractors who received an eight-figure payout from the inaugural committee. The other, first reported by The New York Times last month, was a more than $25.8 million payment to a firm formed just weeks before the inauguration.

California incorporation records show that WIS Media Partners was formed December 6, 2016, just weeks before the inauguration

The firm, Wis Media Partners, was founded by Stephanie Winston Wolkoff, a longtime friend of Melania Trump.

The payouts seem outrageous, and they are unprecedented, at least in recent memory. Organizers of Trump’s inaugural have blamed everything from inexperience to broadcasting costs for the explosion in spending.

“I couldn’t tell you how we possibly could have spent $25 million on a concert,” Steve Kerrigan, head of Obama’s 2013 inaugural committee, told the Associated Press about the cost of Trump’s “Make America Great Again! Welcome Celebration” the night before the inauguration.

OpenSecrets contacted a number of event planning firms that have put on large events, including past inaugurations, to get a sense of just how extraordinary the costs were. None wanted to speak on the record.

Absent expert input, we looked for information on major music festivals. There’s surprisingly little info here, too, so we turned to our IRS data.

We looked at nearly a decade’s worth of IRS data for similarly large payments to firms that do event planning. That review, of more than 70,000 vendor payments reported to the IRS on annual tax returns filed by thousands of nonprofits, showed not a single event payment of $25 million or more.

Only three payments were in the eight-figure range, with the closest being the Mobile World Congress in 2015, which was put on by a trade association called GSMA Limited.

The four-day conference is the world’s largest exhibition for the mobile industry, bringing over 90,000 visitors from 200 countries, with exhibits from 2,000 tech companies — and in 2015,, according to GSMA’s website. A company called Fira Barcelona was paid $22.2 million — less than half of what Trump’s inaugural committee paid its top two contractors — to plan the four-day international conference.

One reason these payments matter is that they could be a way to repay friends and allies by letting vendors charge above-market rates and keep the difference. For example, there is no information in the filing about what subcontractors were paid by Hargrove and Wis Media Partners.

The New York Times reported, for example, that Stephanie Winston Wolkoff, Melania Trump’s friend, only kept about $1.6 million of the $25.8 million her firm was paid. The rest, The Times reports, was spent to “help pay other inaugural workers who reported to” Winston Wolkoff. We will likely never know precisely where the remaining $24 million went, or whether it involved payments to friends or family of the President.

Tom Barrack, a close friend of Trump who served as chairman of the inaugural committee, told the Associated Press last September that “a full and clean external audit has been conducted and completed.”

OpenSecrets sought a copy of the audit from Barrack’s representatives, but none was provided.

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https://www.opensecrets.org/news/:{2018/11/:(style="background-color:#ffff66;"):}:trump-inauguration-money-links-secretive-dark-money/

Notorious “dark money” conduit Wellspring Committeegave $14.8 million to the primary spender on Supreme Court Justice Brett Kavanaugh’s confirmation and paid $919,900 to the mysterious LLC that made a $1 million donation to President Donald Trump’s inaugural committee, according to a new tax return obtained Nov. 27 by the Center for Responsive Politics.

Wellspring has acted as a conduit for large contributions from secretive donors since it was set up, effectively laundering multi-million dollar donations with no substantive disclosure or accountability.

Despite operating behind the scenes with a name unknown to most of the American public, Wellspring is at the crux of Ann and Neil Corkery’s network of politically active dark money groups, funneling millions from anonymous financiers to political causes they don’t want their names attached to — and doing ostensibly little else.

Wellspring has continued to be the chief financier of the Judicial Crisis Network (JCN), with a $14,814,998 contribution last year.

JCN is another nondisclosing politically active nonprofit linked to the Corkerys’ network of conservative dark money groups. It has become the predominant dark money spender in Supreme Court confirmation fights as a vehicle for deep-pocketed donors to funnel millions of dollars behind or against judicial nominees.

Since 2010, Wellspring has funneled more than $54.2 million to JCN, according to tax returns obtained by CRP.

The bulk of Wellspring’s funds that came from three multi-million dollar secret donors in 2017, a shift from prior years in which the biggest amount the group received from a single mystery donor increased with each passing year. The largest donor accounted for $8.9 million, another gave $5.5 million and a third secret donor provided $2 million — but all of their identities remain hidden from the public.

The biggest anonymous contribution to Wellspring in 2016 was nearly $28.5 million, a jump from $8.5 million in 2015 and $6.96 million in 2014. That one secret donor accounted for around 90 percent of Wellspring’s funding in 2016, a year it gave $23 million to JCN.

As a 501(c)(4) social welfare organization, JCN is not required to report its donors to the IRS — and chooses not to disclose its funders’ identities to the public — so its only discoverable donors are other entities like Wellspring that act as conduits for the anonymous money directed at JCN.

JCN was back in the limelight this year as the biggest spender in support of Trump’s second Supreme Court nominee, Brett Kavanaugh. Following its tried and true playbook, JCN launched its first ad about Kavanaugh before Trump even finished announcing his nomination and soon after announced plans to spend $10 million on his confirmation. JCN pledged $10 million to support the successful confirmation of Trump’s first Supreme Court nominee, Neil Gorsuch, the prior year and reported spending $7 million to block the confirmation of Merrick Garland before President Barack Obama left office.

JCN has also spent substantial sums on lobbyists, including Jon Kyl, who lobbied to help JCN marshall in Gorsuch’s nomination before becoming the official White House “sherpa” guiding Kavanaugh through that same process. He was later appointed to fill the late Sen. John McCain’s seat — ultimately enabling him to vote for the confirmation he was once tasked with helping Kavanaugh secure.

JCN spent $483,246 in total on Facebook ads and just $1,900 on Google platforms around the fight to confirm Kavanaugh with an estimated reach of potentially millions of Facebook users.

TV advertising made up the bulk of JCN’s reported spending on Kavanaugh with around $3.9 million going TV ads, according to Kantar Media/CMAG estimates — leaving millions of dollars JCN had pledged to spend unaccounted for.

The puzzle of Trump’s mysterious inaugural gift

The only contractor paid by Wellspring last year was BH Group, the mysterious LLC created four months to the day before it made a $1 million donation to the Trump inaugural committee on Dec. 22, 2016.

The newly discovered payment for “public relations” follows a $750,000 payment to the newly minted BH Group the prior year as well as $947,000 from JCN to the BH Group around when the LLC made its inaugural donation.

While it initially appeared that BH Group was merely a shell company created solely for the purpose of laundering money into the Trump inaugural committee, more information about the LLC has only added to its mystery.

New tax returns reviewed by CRP reveal that Judicial Education Project, JCN’s sister 501(c)(3) nonprofit organization, also paid an additional $1.3 million to BH Group LLC last year. Judicial Education Fund keeps its donors anonymous but CRP tracked the bulk of the group’s recent funding to DonorsTrust, which accounted for more than 99 percent of its money last year. Like JCN, Judicial Education Fund has also been funded by Wellspring in prior years.

One name that CRP has tied to the mysterious LLC is Leonard Leo, the executive vice president at the Federalist Society, an influential conservative and libertarian legal organization, who listed “BH Group” as his employer in a campaign finance filing reported to the Federal Election Commission.

Leo’s more widely known affiliation with the Federalist Society has gained attention after reports that it played a substantial role guiding the hand of Trump’s White House in its judicial nomination process, including in the selection of Supreme Court justices.

Ann Corkery, the Wellspring Committee’s former president and wife of current president Neil Corkery, has reportedly worked closely with him in this process and Leo has been “directly involved” in raising much of the anonymous money the Wellspring Committee brings in every year.

A public records request revealed that Leo and another Federalist Society vice president have also been involved in a nonprofit called the BH Fund,which was set up to enforce a donor agreement between an anonymous $20 million donor and theAntonin Scalia Law School at George Mason University, whose president came under fire for allowing donors to dictate conditions in return for financial gifts.

Incorporation records list BH Group’s address as avirtual office in Arlington, Va. and the only identified point of contact is Donna Smith, whose name matches that of a longtime paralegal at Holtzman Vogel Josefiak Torchinsky, the law firm that shared a Warrenton, Va. office with the address the Trump inaugural committee on its tax return.:{

Continuing the money churn

Staying the course from prior years, Wellspring also gave $400,000 to the Catholic Association, $48,000 to the Annual Fund and $350,000 to the Foundation for Government Accountability’s 501(c)(4) arm, FGA Action.

Another appendage of the Corkerys’ dark money web is theFoundation for Accountability and Civic Trust (FACT), a nonprofit run by acting Attorney General Matthew Whitaker before he became Jeff Sessions’ chief of staff, as CRP first reported in 2016. Like Wellspring, JCN and the Judicial Education Project, Neil Corkery is also the treasurer of FACT. Nearly 100 percent of FACT’s funding came from a single anonymous donor each year since the group was created in 2014, which CRP discovered came entirely from a donor-advised fund called DonorsTrust.

In addition to longstanding dark money stalwarts that have realigned their priorities for the Trump era, new groups spending heavily in support of Trump’s agenda also weighed in on Kavanaugh’s Supreme Court confirmation battle but are not entirely isolated from the Washington swamp Trump pledged to drain.

Wellspring was one of the early donors of 45Committee, another 501(c)(4) social welfare nonprofit that primarily exists to support Trump’s agenda which spent on ads supporting Supreme Court Justice Brett Kavanaugh’s confirmation this year.:{

Another spender was America First Policies, the 501(c)(4) nonprofit organization staffed by former Trump campaign and White House personnel that has become the main dark money group supporting Trump’s agenda.

Although America First Policies itself does not reveal donors’ identities, CRP traced over a quarter of its funding to major corporate players, including Reynolds American and Pharmaceutical Research and Manufacturers of America (PhRMA), a trade group representing the drug company industry’s lobbying interests.

New tax documents filed by another pro-Trump nonprofit, Great America Alliance, show it raised and spent around $3.4 million during that period. Unlike America First Policies, which reported millions more in previously undisclosed political spending it its new tax return, Great America Alliance claimed that it “educated voters through direct and indirect political advocacy messaging nationwide within the scope of applicable laws and regulations.”

This highlights one of the many legal grey areas emerging in the wake of Trump’s unprecedented move to register as a candidate for the 2020 presidential election on his first day in office — leaving the vast majority of financiers behind the growing network of dark money groups spending on his agenda a mystery.

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https://www.alternet.org/2020/10/trump-supreme-court-advisor-leonard-leo-tied-to-more-than-80-mllion-in-dark-money

m ellis

President Donald Trump's unofficial Supreme Court advisor who was actively involved in all three of his justice nominations has been revealed as the sole trustee of a perplexing group that generated more than $80 million in dark money in 2018.

In its first year of operation, there were no employees or volunteers working the firm's main address which appears to be a virtual office located in Virginia. The only people associated with RLT have statuses similar to Leo being Federalist Society officials who now work as "consultants" or have a long history of ties to companies circulating dark money.

The company's mission statement also notes that it strives "to advance conservative principles and causes through communications, research, strategy and assistance to other organizations."

In addition to the mysterious cash circulating and the business' hallow history, it also appears to have funneled nearly $2.7 million in company expenditures through another business known as the BH Group.

"The filing vastly expands the amount of money known to be flowing into the growing constellation of dark money groups tied to Federalist Society co-chairman Leonard Leo."

Here is a quick timeline of how dark money has influenced politics over the last four years:

In 2016, JCN shelled out millions of dollars to dissuade senators from considering President Barack Obama's last Supreme Court nominee, Judge Merrick Garland.
In 2017, JCN dumped millions into having Trump's first Supreme Court nominee Justice NeilGorsuchfill the seat Obama's nominee was denied.
In 2018, the group repeated the same process to back Trump's second nomination of Justice Brett Kavanaugh.
Now, in 2020, JNC has poured millions into the confirmation of Trump's nomination, Amy Coney Barrett to quickly fill the seat of the late Ruth Bader Ginsburg before the upcoming election.

FROM YOUR SITE ARTICLES

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https://www.opensecrets.org/news/2019/05/dark-money-group-funded-by-17million-mystery-donor-before-kavanaugh/

The conservative “dark money” organization that spearheaded controversial Supreme Court Justice Brett Kavanaugh’s contentious confirmation received $22 million in anonymous donations in the year before the 2018 court fight, newly released tax records show.

The Judicial Crisis Network (JCN), a Washington, D.C.-based nonprofit, pledged to spend as much as $10 million to ensure Kavanaugh’s confirmation — the same amount that it spent to help confirm Justice Neil Gorsuch in 2017. JCN has close ties to Trump’s judicial adviser Leonard Leo, a longtime executive at the Federalist Society, the influential conservative and libertarian lawyers network based in Washington, D.C.

More than three-quarters of the funds JCN raised between July 2017 and June 2018 came in the form of a $17 million contribution from a single anonymous donor, according to its latest tax return, which was obtained by MapLight and OpenSecrets. Former Supreme Court Justice Anthony Kennedy announced his retirement in June 2018, paving the way for Kavanaugh’s nomination.

JCN’s filing lists nine other anonymous contributions, none smaller than six figures.

The bulk of JCN’s funding has typically come from the Wellspring Committee, another secretive nonprofit run by operatives who wear multiple hats in a larger network of opaque groups. Neil Corkery, Wellspring’s current president, previously served as JCN’s treasurer; his wife, Ann, was leading Wellspring at the time.

Wellspring has continued to send massive annual endowments to JCN since the group launched in 2005. JCN, in turn, has continued to pour tens of millions of dollars into every subsequent Supreme Court nomination fight and working to reshape the judiciary. Wellspring reported donating almost $15 million to JCN in 2017, on top of $23.5 million in 2016. Neither organization discloses the sources of its funds.

The 2017-18 tax return also reveals JCN paid $241,000 to BH Group — a Virginia limited-liability company tied to Leo, the Trump judicial adviser — after paying the company $947,000 the previous year. BH Group was responsible for a mysterious $1 million donation to Trump’s inaugural committee in 2017. BH Group received at least $919,000 from Wellspring and $1.4 million from the Judicial Education Project, a nonprofit affiliated with JCN, through the end of 2017.

JCN contributed $250,000 to the National Rifle Association (NRA), after giving the gun rights group $1 million from 2016-17. America Engaged, another nonprofit tied to Leo, also gave $950,000 to the NRA in 2017. The NRA ran ads boosting both Gorsuch and Kavanaugh.

JCN gave almost $3.6 million to the Republican Attorneys General Association (RAGA) and $450,000 to the Rule of Law Defense Fund. RAGA launched the dark money policy fund while then-Oklahoma Attorney General Scott Pruitt was on the association’s board of directors. Pruitt later chaired the fund before Trump hired him to lead the Environmental Protection Agency.

One of the many controversies Pruitt dealt with during his 17-month EPA tenure involved the revelation his wife had secured a position with JCN as a temporary contractor. JCN reportedly received her resume from Leo, who has helped raise much of the Wellspring Committee’s cash, according to McClatchy.

From 2017-18, JCN continued quietly bankrolling a small but expanding circle of conservative groups aimed at attracting women, with $75,000 to the Susan B. Anthony List; $35,000 to the American Women’s Alliance; and $250,000 to Winning for Women, which was launched in 2017 as a conservative counterweight to EMILY’s List.

The Susan B. Anthony List boosted Kavanaugh’s nomination and continued to support him after he was accused of sexual assault by Christine Blasey Ford, a Stanford University professor who knew the justice when he was in prep school. Winning for Women also threw their support behind Kavanaugh, spending on hundreds of videos and Facebook ad buys targeting women.

JCN also donated $500,000 to A New Missouri, a dark money organization established to support the state’s former Republican governor, Eric Greitens. He resigned last year amid an investigation into the organization.

This story was produced in partnership between OpenSecrets and MapLight.

Feel free to distribute or cite this material, but please credit the Center for Responsive Politics.

For permission to reprint for commercial uses, such as textbooks, contact the Center: info@crp.org

RELATED TOPICS

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conservative “dark money” organization that spearheaded controversial Supreme Court Justice Brett Kavanaugh’s contentious confirmation received $22 million in anonymous donations in the year before the 2018 court fight, newly released tax records show.

JCN’s filing lists nine other anonymous contributions, none smaller than six figures.

The 2017-18 tax return also reveals JCN paid $241,000 to BH Group — a Virginia limited-liability company tied to Leo, the Trump judicial adviser — after paying the company $947,000 the previous year. BH Group was responsible for a mysterious $1 million donation to Trump’s inaugural committee in 2017. BH Group received at least $919,000 from Wellspring and $1.4 million from the Judicial Education Project,a nonprofit affiliated with JCN, through the end of 2017.

https://truthout.org/articles/one-six-figure-donor-funds-whitaker-nonprofit-with-dark-money/

A single six-figure donor accounted for 100 percent of funding raised by a nonprofit run by acting Attorney General Matthew Whitakerbefore he became Jeff Sessions’ chief of staff last year, new tax documents obtained by the Center for Responsive Politics reveal.

President Trump tapped Whitaker to become acting Attorney General earlier in November after Jeff Sessions was asked to resign.

The Foundation for Accountability and Civic Trust (FACT) is a self-proclaimed 501(c)(3) “watchdog” nonprofit.

This is not the first year a single big donor has accounted for the entirety of FACT’s funding, according to an exclusive new analysis by CRP. Nearly 100 percent of FACT’s funding — all but a few dollars in interest accrued on money left-over from prior years — came from a single anonymous donor again in 2015, 2016 and again last year.

CRP discovered FACT’s first tax return back in 2016, revealing its funding — $600,000 for 2014, its first year of operation — came entirely from a donor-advised fund called DonorsTrust, which acts as a pass-through vessel managing the money flow from wealthy individuals and foundations to nonprofit organizations while allowing the donors to remain anonymous. Beneficiaries of DonorsTrust include a breadth of conservative and libertarian initiatives. Due to DonorsTrust’s design, although CRP is able to reveal the direct funder of FACT by piecing together grants from different tax returns, the ultimate donor remains hidden.

New tax returns obtained by CRP show that wasn’t the only time DonorsTrust was FACT’s main funder. In fact, DonorsTrust accounted for 100 percent of FACT’s income from donations again in 2015, in 2016 and its most recent tax return — meaning Whitaker’s organization that claimed to be “dedicated to promoting accountability, ethics, and transparency” has gotten all of its funds from a group that exists mainly as a vehicle for donors to elude transparency every year since its inception.

deep Ties to Dark Money Networks

In their application for tax-exempt status, FACT — then called the Free Market America Educational Foundation — told the Internal Revenue Service (IRS) that its purpose was to “conduct research and provide informational studies on free market concepts in relation to environmental regulations and policy.” The IRS approved the group’s application for tax-exempt charity status on July 21, 2014, according to its determination letter.

Tax-exempt status in hand, the nonprofit changed its address to a UPS store and its name just weeks later, according to Virginia incorporation records. The nonprofit changed its name again that October, first to the Working for Rights to Express & Communication before finally landing on its current name — ultimately changing its name three times in the months following IRS approval for tax-exempt status, twice in just one day. That month, Whitaker, took control of the organization after losing his bid for a U.S. Senate seat in Iowa. :{

As the Free Market America Educational Foundation, the group was started by Ray Wotring, an operative who had long ago been tied to another shadowy network of politically active nonprofits. Wotring also served on another conservative nonprofit, Americans for Limited Government, which has close financial ties to the network and shared the same UPS story mailing address as FACT’s first iteration as the Free Market America Educational Foundation as well as Free Market America’s 501(c)(4) nonprofit arm.

Free Market America’s nonprofit arm has remained active and began to spend on lobbying in 2018, reporting six-figure spending.

FACT’s dark money ties don’t end there.

The treasurer and a member of the board of directors at FACT is Neil Corkery. Corkery, along with his wife Ann, sit at the helm of a network of conservative “dark money” groups organized to influence public policy and has become a key player promoting Trump’s agenda.

The network has become well-known for the Judicial Crisis Network(JCN), a nondisclosing group that emerged as the predominant dark money spender in Supreme Court confirmation fights since its launch in 2005, allowing deep-pocketed donors to funnel millions of dollars opposing or supporting judicial nominees, including a pledge to spent $10 million on the confirmation of Supreme Court Justice Brett Kavanaugh. JCN’s primary benefactor over the years has been the Wellspring Committee, an even more opaque nonprofit run by the Corkerys that accounted for over 80 percent of its total revenue in 2016.

Many of the groups tied to the network list the same address as their office, with different “suite” numbers. In reality, the address is also a UPS store and the suite numbers are PO boxes.

Links to Trump’s Mysterious Inaugural Donor

In addition to its ostensible political spending fueled by secret donors, disclosures by groups in the Corkery’s network have also raised question about other vehicles of influence behind the scenes, most notably in ties to a $1 million gift to President Donald Trump’s inaugural committee from a mysterious Northern Virginia company called BH Group, LLC.

Little is known about the LLC other than the seven-figure check on Dec. 22, 2016, almost a month before President Trump was sworn in, and a trail of clues pieced together from tax documents and other disclosures.

These clues have also led to Leonard Leo, the executive vice president at the Federalist Society, who listed “BH Group” as his employer in a filingwith the Federal Election Commission.

Tax documents previously obtained by CRP show that the Wellspring Committee made a $750,000 payment to BH Group for “public relations” and that JCN made an additional cash infusion of $947,000to the BH Group around when the LLC made its inaugural donation.

New tax documents first obtained by Maplight and reviewed by CRP reveal that Judicial Education Project, JCN’s sister 501(c)(3) nonprofit organization, paid an additional $1.3 million to BH Group LLC last year.

As a 501(c)(3) organization, Judicial Education Fund is not required to reveal its donors and chooses to keep them secret. However, CRP has been able to trace the source of the bulk of the group’s 2017 funding. Like FACT, Judicial Education Fund received millions of dollars coming from DonorsTrust accounting for more than 99 percent of the group’s funding.

That newly revealed payment from Judicial Education Fund brings the total known income for the BH Group to more than $3 million, according to CRP’s analysis — over three times the $1 million it gave to President Trump’s inaugural committee and raising more questions about its other activities that have yet to be reported.

Whitaker’s Watchdog

FACT’s own activities since 2014 have largely revolved around legal and ethics complaints, mostly targeting Democrats and with a particularly aggressive focus on Hillary Clinton during the 2016 presidential election.

FACT has paid more than half-a-million dollars to Republican opposition research firm America Rising LLC,according to its most recent three tax returns.

FACT raised just over $3.4 million since it was conceived in 2014, according to tax filings obtained by CRP. Whitaker’s salary accounts for more than a third of FACT’s entire revenue since its exception, making him its single largest expense.

Whitaker received more than $1.2 million from FACT over the three years he led the organization, according to CRP’s analysis of the group’s tax returns, with the salary he drew from FACT rising precipitously — in some cases increasing by more than six-figures with each passing year.

Whitaker made $502,000 in 2017 — around half of FACT’s spending — despite having left the organization to take a position at the Justice Department as then-Attorney General Jeff Sessions’ chief of staff in September of that year.

[graph]

FACT provided the vast majority of Whitaker’s income for the entire span of time covered by his financial disclosures on file with the Office of Government Ethics and released by the Justice Department the Tuesday before Thanksgiving, following weeks of scrutiny and multiple requests.

Whitaker’s selection as acting Attorney General has been contested on multiple fronts, and the release of his financial disclosures has only fueled the dumpster fire.

Disclosures revealed that Whitaker’s unsuccessful 2014 campaign received four donations totaling $8,800 this year — years after he lost the election and just months after he joined the Justice Department. The donations were the only money the campaign has received in over two years, raising questions about the potential implications of the donations under the Hatch Act, a federal law that generally prohibits federal officials from knowingly soliciting or accepting campaign donations and a separate Justice Department memo further restricting political activity by its personnel in the hopes of keeping the agency as apolitical as possible.

A provision of the Hatch Act allows officials to raise money to retire campaign debt, but the campaign’s only reported spending was 2018 were $228 to reimburse “data services” and $500 to Whitaker’s old law firm for renting office space, according to the New York Times.

Whitaker’s law partner of eight years, William Gustoff,who was treasurer for Whitaker’s unsuccessful 2014 Senate campaign and also serves on the board of FACT, signed off on the FEC filings.

“The checks came in. I, as the treasurer, deposited the checks, and I retired the debt that I knew I could without talking to Matt,” Gustoff told the New York Times, “I don’t talk to Matt about the campaign.”

Gustoff did say that FACT had been “well received” by Republican donors.

2017 Form 990 tax returns for DonorsTrust and Judicial Education Project were first obtained by Maplight’s Andrew Perez and reviewed by the Center for Responsive Politics.

===

...

During the Obama era, the dark money ramped up. The Wellspring Committee, a nonprofit formed in 2008 where both Corkerys have served as president, became the chief funder of JCN, bankrolling its campaigns to block Merrick Garland’s confirmation, and, under Trump, to support the nomination of Neil Gorsuch and other nominees to federal courts. According to an investigation last year by the Center for Responsive Politics, “most of Wellspring’s funds, in turn, came from a single mysterious donor who gave the organization almost $28.5 million—nearly 90 percent of its $32.2 million in revenues” in 2016. According to this report, Wellspring gave more than $23 million to JCN in 2016, quadrupling its 2015 donation to the group of $5.8 million.

Wellspring also donated money to the Catholic Association, another nonprofit the Corkerys helped found, this one to advocate on behalf of “religious liberty,” and to the Federalist Society. In yet another sign of the intimacy of this network, the association paid Leo, known as Trump’s Supreme Court whisperer, $120,000 for “management consulting.” (Leo also earned $435,000 from the Federalist Society that year, according to its tax return.) Neither Leo nor the Corkerys responded to requests for comment.

Another mysterious Corkery-linked company, BH Group LLC, created in 2016, donated $1 million to Trump’s inaugural committee. Not much is known about what BH Group does, or who its principals are, but in 2016, the Corkerys’ Wellspring Committee paid BH Group $750,000 for “public relations,” according to its tax return, and JCN paid the firm $947,000 for “consulting services.” And Leo later identified BH Group as his employer in an FEC filing.

In early May 2017, about a month after Gorsuch was confirmed to the Supreme Court, Leo was awarded the prestigious Canterbury Medal from the Becket Fund for Religious Liberty, billed by the organization as “religious liberty’s highest honor.” A major Christian-right legal firm, the Becket Fund is best known for its victory in 2014’s landmark Hobby Lobby case, in which the Supreme Court ruled that the Affordable Care Act’s requirement of contraceptive coverage violated the company’s religious freedom. In his acceptance speech at a gala held at The Pierre, a New York luxury hotel overlooking Central Park, Leo, in white tie, could barely conceal his elation that Trump had beaten the odds to win the White House. Looking back on the campaign, Leo recalled the “fear that permeated every day in that countdown to November 8” and rejoiced at the “amazing turn of events, thanks to our 45th president.”

...

86 253 ORG BH GROUP. LLC $1,000,000 12/22/2016

1655 N FORT MYER DRIVE, Suite 700

ARLINGTON VA 22209

Located in shared office space run by Regus PLC in a large building near several companies that have obtained large defense department contracts. Address was actually N Fort Myer Dr (N was omitted), and suite number was omitted from data reported to FEC. Incorporated 22 August 2016.

This one appears on Bloomberg as having no executives listed, no recent transactions. Go to website and it is a concrete business, but not in Va.

===

253

ORG

BH GROUP. LLC

$1,000,000

12/22/2016

https://www.google.com/maps/place/1655+N+FORT+MYER+DRIVE,+Suite+700,ARLINGTON,VA,22209,

1655 N FORT MYER DRIVE, Suite 700

ARLINGTON

22209

===

big data?

https://www.qedgroupllc.com/about-us/#our-history

https://riskdynamic.com/connect/

Janet Jozwik

Quantitative Modeling

Janet Jozwik a lead econometric modeler for RiskSpan directing a range of model builds and model validation efforts for clients. Janet has a background in mortgage credit modeling, loss forecasting, and data analysis.

Prior to joining RiskSpan, Janet was a financial economist at Fannie Mae where she specialized in single family credit pricing. Her work directly impacted the national guarantee fee pricing scheme and government programs to support the housing market during and after the financial crisis. Janet has extensive experience in analyzing massive datasets, a deep understanding of the drivers of credit risk, and an expertise in modeling mortgage cash flows.

Janet holds an MBA from the University Of Chicago Booth School Of Business and a BA in Economics from Johns Hopkins University.

RisKontroller Global LLC

1655 North Fort Myer Drive, Suite 700

Arlington, Virginia 22209 USA

Also, Washington DC, Zürich, and Mumbai.

muckrock

Subject: Virginia Freedom of Information Act Request: Virginia BH Group

Email

To Whom It May Concern:

Pursuant to the Virginia Freedom of Information Act, I hereby request the following records:

All available documents and communications relating to the following business:

BH GROUP, LLC

1655 N Fort Myer Drive, Suite 700

Arlington VA 22209

SCC ID: S6344156

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter.

I look forward to receiving your response to this request within 5 business days, as the statute requires.

Sincerely,

Andrew Perez

From: Virginia State Corporation Commission

05/14/2018

Subject: RE: Virginia Freedom of Information Act Request: Virginia BH Group

Email

For future reference, the public availability of Commission records and those of its operating divisions, including the Office of the Clerk, is generally governed by Title 12.1 of the Code of Virginia, particularly subsection C of §12.1-19.

And, under Virginia corporate law, filings made by entities formed or registered under that law are public records.

Images of those documents are available for viewing or printing at:

http://www.scc.virginia.gov/clk/viewimg.aspx**

For convenience, I have attached that document.

S6344156

BH Group, LLC

NEW LLC 08/22/2016

The only submission on record is the original articles of organization.

By law, the entity must pay an annual renewal fee of $50 by August 31 of each year.

The 2017 payment was received electronically on 8/15/2017.

Business Entity Name: BH Group, LLC

SCC ID: S6344156

Annual Assessment Payment 8/15/2017 8:57:42 AM

Kenneth (Ken) J. Schrad

Director

Division of Information Resources

State Corporation Commission

PO Box 1197

Richmond VA 23218

e-mail: ken.schrad@scc.virginia.gov

office: 804-371-9858

cell: 804-334-6454

1608540834

SCC eFile
ARTICLES OF ORGANIZATION
OF
BH GROUP, LLC

The undersigned, pursuant to Chapter 12 of Title 13.1 of the Code of Virginia, states as follows:

1.

The name of the limited liability company is BH Group, LLC.

2.

The purpose for which the limited liability company is formed is to engage in any lawful business,
purpose or activity for which a limited liability company may be formed under the Virginia Limited
Liability Company Act.

3.

The name of the limited liability company's initial registered agent is National Corporate Research,
Ltd. The initial registered agent is a foreign stock corporation authorized to transact business in
Virginia.

4.

The address of the limited liability company's initial registered office, which is identical to the
business office of the initial registered agent, is 250 Browns Hill Court, Midlothian, VA 23114. The
initial registered office is located in Chesterfield County, Virginia.

5.

The address of the limited liability company's principal office where the records of the limited
liability company are to be kept is 1655 N Fort Myer Drive, Suite 700, Arlington, VA 22209.

ORGANIZER:
Isl

Donna Smith Date: August 22, 2016
Donna Smith

actually 1/2 dozen

Donna Marie Smith, 58

MURPHY, NC

Lived InCarrollton GA, Tallahassee FL, Fayetteville TN, Midlothian VA

Related ToGeorge Smith, Sylvester Smith, Travis Smith, Joan Smith, Trenetra Smith

Donna B Smith, 56 BOSTON, VA Lived In Lewisburg WV, Culpeper VA, Davison MI, Midlothian VA Related To Douglas Smith, Steven Smith, Sarah Smith, Rodney Smith, Timothy Smith Also known as Dawn D Smith, Deann B Smith

Aliases: Donna G Smith, Dawn D Smith, Deann B Smith

Female, Age 56

Relatives: Douglas Smith • Steven Smith • Sarah Smith • Rodney Smith • Timothy Smith

Locations: Boston, VA • Lewisburg, WV • Culpeper, VA • Davison, MI • Hartwell, GA

https://sccefile.scc.virginia.gov/Documents/1504026083.pdf?documentName=1504026083

404?

---

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We also provide statutory representation services in a wide range of international jurisdictions. For more information about representation outside of the United States, please contact INTERNATIONAL@COGENCYGLOBAL.COM. 8/15/2018 Listing the correct name and address of your Registered Agent on filings is critically important. To make sure you have the most current address for COGENCY GLOBAL INC. in a given state, always check the Registered Agent Address List posted on our web site: COGENCYGLOBAL.COM. Or, better yet, save yourself time and avoid typos by using our corporate forms, which have our name and address already inserted. You can access the corporate forms library from our website, but you will need a password. To apply for a password, provide your name, firm name, phone number and e-mail address in a request to: INFO@COGENCYGLOBAL.COM ALBANY, NEW YORK 194 WASHINGTON AVE, STE. 310 ALBANY, NY 12210 800.828.0938 Fax 866.621.3526 CHICAGO, ILLINOIS 111 W WASHINGTON ST, STE. 1447 CHICAGO, IL 60602 866.775.0112 Fax 866.775.0113 DOVER, DELAWARE 850 NEW BURTON RD, STE. 201 DOVER, DE 19904 800.483.1140 Fax 800.253.5177 SACRAMENTO, CALIFORNIA 1325 J STREET, STE. 1550 SACRAMENTO, CA 95814 866.369.1640 Fax 866.621.3522 TALLAHASSEE, FLORIDA 115 N CALHOUN ST, STE. 4 TALLAHASSEE, FL 32301 866.625.0838 Fax 866.625.0839 Corporate Headquarters: NEW YORK, NEW YORK 10 E 40TH STREET, 10TH FL • NY, NY 10016 800.221.0102 Fax 800.944.6607 International: Tel: +1 212.947.7200 CHARLOTTE, NORTH CAROLINA 212 S TRYON STREET, STE. 1000 CHARLOTTE, NC 28281 866.775.0114 Fax 866.775.0115 DALLAS, TEXAS 1601 ELM STREET, STE. 4360 DALLAS, TX 75201 844.818.2384 Fax 866.342.7307 LOS ANGELES, CALIFORNIA 600 WILSHIRE BLVD, STE. 980 LOS ANGELES, CA 90017 888.600.9540 Fax 866.621.3527 SPRINGFIELD, ILLINOIS 600 S SECOND ST, STE. 404 SPRINGFIELD, IL 62704 888.883.6300 Fax 866.621.3523 WASHINGTON, DC 1025 VERMONT AVE, NW, STE. 1130 WASHINGTON, DC 20005 800.494.5225 Fax 800.494.7512 OUR U.S. FULL SERVICE OFFICES: HOW TO NAME US AS YOUR REGISTERED AGENT LIST OUR NAME ON FILINGS AS “COGENCY GLOBAL INC.” Page 2 of 7 When an email address or phone number is requested, use SOP@COGENCYGLOBAL.COM and 866.621.3524. Make sure to complete and send a Registered Agent Contact Information Form any time you name us as agent. JURISDICTION STATUTORY REPRESENTATION ADDRESS Alabama 2 North Jackson Street Suite 605 Montgomery, AL 36104 Alaska 3085 Mountainwood Circle Juneau, AK 99801 Mailing address: P.O. Box 33735 Juneau, AK 99803 Arizona 300 W. Clarendon Ave., Ste. 240 Phoenix, AZ 85013 Arkansas 1215 Twin Lakes Drive Little Rock, AR 72205 California 1325 J Street -Ste. 1550 Sacramento, CA 95814 Colorado 12649 West Warren Avenue Lakewood, CO 80228 Connecticut 53 Pamela Drive Milford, CT 06460 Delaware 850 New Burton Road, Suite 201 Dover, DE 19904 (Kent County) LIST OUR NAME ON FILINGS AS “COGENCY GLOBAL INC.” Page 3 of 7 When an email address or phone number is requested, use SOP@COGENCYGLOBAL.COM and 866.621.3524. Make sure to complete and send a Registered Agent Contact Information Form any time you name us as agent. District of Columbia 1025 Vermont Avenue, N.W., Suite 1130 Washington, DC 20005 Florida 115 North Calhoun Street, Suite 4 Tallahassee, FL 32301 (Leon County) Georgia 900 Old Roswell Lakes Parkway, Suite 310 Roswell, GA 30076 (Fulton County) Hawaii 1188 Bishop Street, Suite 2212 Honolulu, HI 96813 Idaho 921 S. Orchard Street - Suite G Boise, ID 83705 Illinois 600 South Second Street, Suite 404 Springfield, IL 62704 (Sangamon County) Indiana 155 East Market, Suite 800 Indianapolis, IN 46204 Iowa 400 Locust Street, Suite 400 Des Moines, IA 50309 (Polk County) Kansas 2101 S.W. 21st Street Topeka, KS 66604 LIST OUR NAME ON FILINGS AS “COGENCY GLOBAL INC.” Page 4 of 7 When an email address or phone number is requested, use SOP@COGENCYGLOBAL.COM and 866.621.3524. Make sure to complete and send a Registered Agent Contact Information Form any time you name us as agent. Kentucky 828 Lane Allen Road, Suite 219 Lexington, KY 40504 (Fayette County) Louisiana 3867 Plaza Tower Drive, First Floor Baton Rouge, LA 70816 Maine (For domestic corporations ONLY, must name individual Kenneth Keene at this address) 128 State Street, 3rd Floor Augusta, ME 04330 (Kennebec County) Maryland 1519 York Road Lutherville, MD 21093 (Baltimore County) Massachusetts 44 School Street, Suite 325 Boston, MA 02108 Michigan 229 Brookwood Drive, Suite 14 South Lyon, MI 48178 Minnesota 6040 Earle Brown Drive, Suite 480 Brooklyn Center, MN 55430 Mississippi 248 East Capitol Street –Ste. 840 Jackson, MS 39201 LIST OUR NAME ON FILINGS AS “COGENCY GLOBAL INC.” Page 5 of 7 When an email address or phone number is requested, use SOP@COGENCYGLOBAL.COM and 866.621.3524.

Make sure to complete and send a Registered Agent Contact Information Form any time you name us as agent.

Missouri 9666 Olive Blvd., Suite 690 St. Louis, MO 63132 Montana 302 N. Last Chance Gulch, Suite 403 Helena, MT 59601 Nebraska 5601 S. 59th Street, Suite C Lincoln, NE 68516 Nevada 321 W. Winnie Lane #104 Carson City, NV 89703 New Hampshire 63 Pleasant Street Concord, NH 03301 New Jersey 14 Scenic Drive Dayton, NJ 08810 N.J. Registered Agent # (for online annual report filings): 759130 New Mexico 1012 Marquez Place, Suite 106B Santa Fe, NM 87505 New York 10 East 40th Street, 10th Floor New York, NY 10016 North Carolina 212 South Tryon Street, Suite 1000 Charlotte, NC 28281 (Mecklenburg County) LIST OUR NAME ON FILINGS AS “COGENCY GLOBAL INC.” Page 6 of 7 When an email address or phone number is requested, use SOP@COGENCYGLOBAL.COM and 866.621.3524. Make sure to complete and send a Registered Agent Contact Information Form any time you name us as agent. North Dakota 120 West Sweet Avenue, Suite 9 Bismarck, ND 58504 Ohio 3958-D Brown Park Dr. Hilliard, OH 43026 Oklahoma 15205 Traditions Lake Parkway Edmond, OK 73013 Oregon 325 13th Street NE, Suite 404 Salem, OR 97301 Pennsylvania 600 North 2nd Street Harrisburg, PA 17101 (Commercial Registered Office Provider) (Dauphin County) Puerto Rico Agustin Stahl, Carr. 174 A-10 Bayamon, PR, 00956 Rhode Island 222 Jefferson Boulevard Warwick, RI 02888 South Carolina 2 Office Park Court, Suite 103 Columbia, SC 29223 South Dakota 326 N. Madison Ave Pierre, SD 57501

LIST OUR NAME ON FILINGS AS “COGENCY GLOBAL INC.” Page 7 of 7 When an email address or phone number is requested, use SOP@COGENCYGLOBAL.COM and 866.621.3524. Make sure to complete and send a Registered Agent Contact Information Form any time you name us as agent. Tennessee 992 Davidson Drive, Suite B Nashville, TN 37205 (Davidson County) Texas 1601 Elm Street, Suite 4360 Dallas, TX 75201 Utah 2005 East 2700 South, Suite 200 Salt Lake City, UT 84109 Vermont 1154 Route 30 Townshend, VT 05353 Virginia 250 Browns Hill Court Midlothian, VA 23114 (Chesterfield County) Washington 1780 Barnes Blvd. SW Tumwater, WA 98512-0410 West Virginia 1627 Quarrier Street East Charleston, WV 25311 (Kanawha County) Wisconsin 901 South Whitney Way Madison, WI 53711 Wyoming 1920 Thomes Avenue Suite 610 Cheyenne, WY 82001