MUR808200001
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Broken Promises, Stand Up for Justice, Sean Jason Anderson, Concerned Conservatives, Inc., 

Nancy H. Watkins, South Florida Residents First, Paul Kilgore, and Unknown Respondents for 

direct and serious violations of the Federal Election Campaign Act (“FECA”). 

2. The FECA prohibits making and knowingly accepting a contribution in the name 

of another person, as well as knowingly permitting one’s name to be used to effect a contribution 

in the name of another person. Nevertheless, political consultants who appear to have controlled 

a network of nonprofit organizations pitched one or more clients on their ability to funnel money 

through nonprofits as part of a funding structure that could be used, among other things, to make 

federal campaign contributions while evading public reporting, in violation of these prohibitions 

on straw donations. Seemingly fulfilling that unlawful scheme, five nonprofits tied to the 

consultants made contributions totaling $1.27 million to federally registered super PACs in 2020. 

3. According to records obtained by the Orlando Sentinel, in November 2019, Jeff 

Pitts, who was then working for a consulting firm called Matrix, LLC, sent the CEO and 

President of Florida Power & Light, Eric Silagy, two memoranda about money in politics, one of 

which described a proposed “structure for funding 2020 activities” while the other discussed 

legalities related to “federal elections support.” The funding memo, which named minimizing 

public reporting as one of its goals, included a flowchart depicting how the company’s money 

could move through several layers of corporate entities, particularly nonprofit organizations, 

before being used to fund “political activities” on both the state and federal level. The legal 

memo warned that nonprofits that directly made independent expenditures to support a federal 

candidate may be required to disclose their donors and “[t]hus” recommended that “it could be 

strategic for a [nonprofit] who wishes to make Independent Expenditures to do so via a Super 

MUR808200002
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PAC.” The effect of this scheme would be to illegally hide the identities of the true source or 

sources of contributions by routing contributions through conduit nonprofits to super PACs, 

which would ultimately fund electioneering activities. 

4. As the Orlando Sentinel noted in its reporting on the memos, nonprofits 

apparently controlled by consultants once employed by Matrix, LLC, including Pitts or those 

who worked with him (the “Conduit Consultants”), subsequently made several donations to 

federal super PACs in 2020 in an apparent effort to carry out the scheme described in the 2019 

memoranda. Matrix later asserted the Conduit Consultants were operating without the firm’s 

knowledge or authorization. 

5. Accordingly, there is reason to believe (1) that an Unknown Respondent or 

Unknown Respondents, which may include corporations like Florida Power & Light, knowingly 

made contributions in the name of another to Wingman PAC, American Valor PAC, Senate 

Leadership Fund, Concerned Conservatives, Inc., and South Florida Residents First, (2) that the 

recipient entities knowingly accepted such contributions while falsely reporting they were made 

by conduit nonprofits apparently controlled by the Conduit Consultants, namely Grow United, 

Inc., the Center for Advancement of Integrity and Justice, Inc., Florida Promise, Inc., Broken 

Promises, and Stand Up for Justice, and (3) that the conduit nonprofits knowingly permitted their 

names to be used to effect a contribution in the name of another by permitting the contributions 

to be falsely attributed to them. These apparent violations of the law deprive the public of 

important information and demand investigation. 

Complainants 

6. Complainant CREW is a non-profit corporation, organized under section 

MUR808200003
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501(c)(3) of the Internal Revenue Code. CREW is committed to protecting the right of citizens to 

be informed about the activities of government officials, to ensuring the integrity of government 

officials, protecting our political system from corruption, and reducing the influence of money in 

politics. CREW is dedicated to empowering voters to have an influential voice in government 

decisions and in the governmental decision-making process. CREW uses a combination of 

research, litigation, and advocacy to advance its mission. 

7. In furtherance of its mission, CREW seeks to expose unethical and illegal conduct 

of those involved in government. One way that CREW does this is by educating citizens 

regarding the integrity of the electoral process and our system of government. Toward this end, 

CREW monitors the campaign finance activities of those who run for federal and state office and 

those who support or oppose such candidates and publicizes those who violate federal campaign 

finance laws through its website, press releases, and other methods of distribution. CREW also 

files complaints with the FEC when it discovers violations of the FECA. Publicizing campaign 

finance violators and filing complaints with the FEC serve CREW’s mission of keeping the 

public informed about individuals and entities that violate campaign finance laws and deterring 

future violations of campaign finance law. 

8. In order to assess whether an individual, candidate, political committee, or other 

regulated entity is complying with federal campaign finance law, CREW needs the information 

contained in receipts and disbursements reports that political committees and others must file 

pursuant to the FECA, 52 U.S.C. § 30104; 11 C.F.R. §§ 104.1–22, 109.10. CREW is hindered in 

its programmatic activity when an individual, candidate, political committee, or other regulated 

entity fails to disclose or provides false information in reports required by the FECA. 

MUR808200004
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9. CREW relies on the FEC’s proper administration of the FECA’s reporting 

requirements because the FECA-mandated disclosure reports are the only source of information 

CREW can use to determine if an individual, candidate, political committee, or other regulated 

entity is complying with the FECA. The proper administration of the FECA’s reporting 

requirements includes mandating that all disclosure reports required by the FECA are properly 

and timely filed with the FEC. CREW is hindered in its programmatic activity when the FEC 

fails to properly administer the FECA’s reporting requirements. 

Respondents 

Conduit Respondents 

10. Grow United, Inc. is a tax-exempt organization formed in Delaware in July 2019. 

Grow United, Inc., Delaware Department of State: Division of Corporations, Entity Details, 

https://bit.ly/3t5moxi. Grow United is at the center of the so-called “ghost” candidate scandal in 

Florida, where the organization funded mailers promoting third party candidates who did little 

campaigning of their own and appear to have been encouraged to run in an effort to siphon votes 

from Democratic candidates in state Senate races. Jason Garcia and Annie Martin, Florida’s dark 

money playbook: How ‘ghost’ candidate scheme revealed secretive political tactics, Orlando 

Sentinel, Dec. 30, 2021, https://bit.ly/32Ugwfu. According to records obtained by the Orlando 

Sentinel, the nonprofit was set up and controlled by the Conduit Consultants. Jason Garcia and 

Annie Martin, Florida Power & Light execs worked closely with consultants behind ‘ghost’ 

candidate scheme, records reveal, Orlando Sentinel, Dec. 2, 2021, https://bit.ly/32V026r. There 

are currently no publicly available tax returns filed by Grow United, but its address and tax 

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6 

identification number are available in the tax return of another organization that provided it a 

grant. Florida Watch Inc., 2020 Form 990, Schedule I, https://bit.ly/3G4LVu6. 

11. The Center for Advancement of Integrity and Justice, Inc. is or was a tax-exempt 

organization formed in Delaware in October 2018. The Center for Advancement of Integrity and 

Justice, Inc., Delaware Department of State: Division of Corporations, Entity Details, 

https://bit.ly/3q0bSnS. There are currently no publicly available tax returns filed by the Center 

for Advancement of Integrity and Justice, Inc., and the Internal Revenue Service automatically 

revoked the organization’s tax-exempt status in May 2021 due to the group’s failure to file a 

Form-990 series return or notice for three consecutive years. Center for Advancement of 

Integrity and Justice, Inc., Auto-Revocation List, Tax Exempt Organization Search, Internal 

Revenue Service, https://bit.ly/3L5mI4F. 

12. Florida Promise, Inc. is a tax-exempt organization formed in Delaware in 

December 2018. Florida Promise, Inc., Delaware Department of State: Division of Corporations, 

Entity Details, https://bit.ly/3JPH3LJ; Florida Promise, Inc., 2018 Form 990-EZ, 

https://bit.ly/32bdv9H. 

13. Richard Alexander is, and at all relevant times was, the chairman of Grow United, 

Inc., Jason Garcia and Annie Martin, Chair of dark-money group in Florida’s ‘ghost’ candidate 

scandal has ties to other secretive groups, Orlando Sentinel, Aug. 26, 2021, 

https://bit.ly/3yweGwR, president of the Center for Advancement of Integrity and Justice, Inc., 

Jason Garcia, Twitter, Oct. 24, 2021, https://bit.ly/3F84Pja, and chairman of Florida Promise, 

Inc., Florida Promise, Inc., 2018 Form 990-EZ. Mr. Alexander’s sister, April Odom, is one of the 

Conduit Consultants who helped set up and control Grow United, and Mr. Alexander also serves 

MUR808200006
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as an officer of additional nonprofits connected to the consultants. Jason Garcia and Annie 

Martin, Dark money behind Florida ‘ghost’ candidates has ties to Alabama political players, 

records suggest, Orlando Sentinel, Aug. 5, 2021, https://bit.ly/3e05w20; Garcia and Martin, 

Chair of dark-money group; Center for Popular Progressive Values and Democracy Inc, 2018 

Form 990, https://bit.ly/3E3gOgv. Prosecutors in Florida have sent Mr. Alexander a “prior to” 

letter related to the investigation of the “ghost” candidate scandal, suggesting that he may be a 

target of an investigation.1

 Annie Martin and Jason Garcia, Operatives tied to ‘ghost’ candidate 

scheme told they’re targets of Miami prosecutors, Orlando Sentinel, Jan. 5, 2022, 

https://bit.ly/3rZQC3F. 

14. Broken Promises was a tax-exempt organization formed in Washington, DC in 

August 2018. Broken Promises, Initial File Number: N00006066042, Washington, DC 

Department of Consumer and Regulatory Affairs, https://bit.ly/3F2LUW6; Broken Promises, 

2018 Form 990, https://bit.ly/3bpNsw7. Broken Promises, which terminated in 2020, appears to 

have shut down soon after CREW filed a complaint with the IRS against the organization 

regarding its high level of political activity in 2018. Broken Promises, 2020 Form 990-N, 

https://bit.ly/3qRTMVl; Broken Promises, Initial File Number: N00006066042, Washington, DC 

Department of Consumer and Regulatory Affairs; Letter from Noah Bookbinder and Matt Corley 

to the Honorable Charles P. Rettig, Dec. 17, 2020, https://bit.ly/3t5PwEr; Mary Ellen Klas, 

Nicholas Nehamas, and Ana Claudia Chacin, ‘Nightmare scenario’: How FPL secretly 

manipulated a Florida state Senate election, Miami Herald, Aug. 29, 2022, 

1

 According to the Orlando Sentinel, H. Scott Fingerhut, a law professor and former prosecutor in the Miami-Dade 

State Attorney’s Office, explained that a “prior to” sent by the State Attorney’s office is an “investigative tool” that 

“typically alerts someone they are the target of an investigation and gives them the chance to sit for an interview 

with prosecutors.” Martin and Garcia, Operatives tied to ‘ghost’ candidate scheme told.

MUR808200007
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https://bit.ly/3VoQRlk (reporting Broken Promises filed for dissolution two weeks after the 

complaint). 

15. Stand Up for Justice was a tax-exempt organization formed in Washington, DC in 

August 2018. Stand Up for Justice, Initial File Number: N00006066111, Washington, DC 

Department of Consumer and Regulatory Affairs, https://bit.ly/3HDQ88o; Stand Up for Justice, 

2018 Form 990, https://bit.ly/3lXURYC. Stand Up for Justice and Broken Promises appear to be 

highly similar organizations that formed on the same day in 2018, shared the same board, and 

used the same accounting firm to prepare its tax returns. Compare Broken Promises, Initial File 

Number: N00006066042, Washington, DC Department of Consumer and Regulatory Affairs; 

Broken Promises, 2018 Form 990 to Stand Up for Justice, Initial File Number: N00006066111, 

Washington, DC Department of Consumer and Regulatory Affairs; Stand Up for Justice, 2018 

Form 990. Stand Up for Justice terminated in 2020 and appears to have shut down soon after 

CREW mentioned the organization in a complaint filed with the IRS against Broken Promises. 

Stand Up for Justice, 2020 Form 990-N, https://bit.ly/32Vikoy; Stand Up for Justice, Initial File 

Number: N00006066111, Washington, DC Department of Consumer and Regulatory Affairs; 

Letter from Noah Bookbinder and Matt Corley to the Honorable Charles P. Rettig, Dec. 17, 

2020. 

16. Sean Jason Anderson was at all relevant times the president and chairman of the 

board of directors of Broken Promises, Broken Promises, 2018 Form 990; Annie Martin and 

Jason Garcia, PAC activity in 2020 ‘ghost’ candidate race mirrored tactics in ’18 Gainesvillearea election, Orlando Sentinel, Aug. 18, 2021, https://bit.ly/3eV6oFI, and board president of 

Stand Up for Justice, Stand Up for Justice, 2018 Form 990. According to the Orlando Sentinel, 

MUR808200008
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“tax, corporate and court records show that Broken Promises is run by Sean Jason Anderson of 

Birmingham, Ala. and Alabama lobbying records from 2011 show there is a Jason Anderson 

who used to work in Matrix LLC’s Birmingham office.” Id.; Alabama Ethics Commission, 

Lobbyist Registration Statement, 2011, Anderson, Jason, https://bit.ly/3t2jqtq; John Archibald, 

Archibald: ‘Bachelor party’ makes for strange bedfellows, AL.com, Nov. 14, 2010, 

https://bit.ly/3qTmZiQ. The Miami Herald reported that Mr. Pitts texted a Florida Power & 

Light executive in 2016 that Mr. Anderson was an old friend of Mr. Pitts, and that Mr. Pitts and 

his associates were “the ones with the check books and in control 100 percent” of nonprofits 

purportedly run by Mr. Anderson and another associate. Nicholas Nehamas and Mary Ellen Klas, 

DeSantis ‘18 campaign got $25,000 from nonprofit secretly funded by FPL cash, records show, 

Miami Herald, Sept. 9, 2022, https://bit.ly/3CSOlgf; Klas, Nehamas, and Chacin, ‘Nightmare 

scenario’: How FPL secretly manipulated a Florida state Senate election. 

Recipient PAC and Treasurer Respondents 

17. Wingman PAC is a federally registered independent expenditure-only committee 

(“super PAC”) formed under FECA in March 2020. Wingman PAC, FEC Form 1, Statement of 

Organization, Mar. 16, 2020, https://bit.ly/3HDxEos. 

18. Abby Dupree is, and at all relevant times was, treasurer of Wingman PAC. 

Wingman PAC, FEC Form 3X, 2020 Post-General Report, Dec. 3, 2020, https://bit.ly/3n22ZcL. 

Ms. Dupree is a managing partner of Carroll and Company and, according to the company’s 

website, has “[e]xtensive experience in campaign finance compliance reporting with the State of 

Florida Division of Elections and the Federal Elections [sic] Commission.” Carroll and 

Company, Abby F. Dupree, CPA, https://bit.ly/3HF3VLV. 

MUR808200009
10 

19. American Valor PAC was a federally registered super PAC formed under FECA 

in September 2020. American Valor PAC, FEC Form 1, Statement of Organization, Sept. 2, 

2020, https://bit.ly/3GeLHRj. American Valor PAC terminated in December 2020. American 

Valor PAC, FEC Form 3X, Termination Report, Dec. 3, 2020, https://bit.ly/3t25pvO. 

20. Lisa Lisker was at all relevant times the treasurer of American Valor PAC. 

American Valor PAC, FEC Form 3X, Termination Report, Dec. 3, 2020. Ms. Lisker is the 

president of Huckaby Davis Lisker, Inc. and has worked with “hundreds of Senate and House 

campaigns, state party, joint fundraising and political action committees, serving as Treasurer for 

most.” AAPC 2020 Annual Pollie Awards & Conference, Lisa Lisker, https://bit.ly/3y7eXYM. 

21. Senate Leadership Fund is a federally registered super PAC formed under FECA 

in January 2015. Senate Leadership Fund, FEC Form 1, Statement of Organization, Jan. 20, 

2015, https://bit.ly/3HGJXjX. 

22. Caleb Crosby is, and at all relevant times was, treasurer of Senate Leadership 

Fund. Senate Leadership Fund, FEC Form 3X, 2020 Year End Report, Amended, Mar. 18, 2021, 

https://bit.ly/337G4FQ. Mr. Crosby has served as the treasurer for dozens of committees 

registered with the FEC. Committees, Most Recent Treasurer, “crosby, caleb,” Federal Election 

Commission, https://bit.ly/3HBfvYm. 

23. Concerned Conservatives, Inc. is a federally registered super PAC formed under 

FECA in November 2019. Concerned Conservatives, Inc., FEC Form 1, Statement of 

Organization, Nov. 22, 2019, https://bit.ly/3eSWJ2e. 

24. Nancy H. Watkins is, and at all relevant times was, the treasurer of Concerned 

Conservatives, Inc. Id.; Concerned Conservatives, Inc., FEC Form 3X, 2020 Pre-Primary Report, 

MUR808200010
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Aug. 6, 2020, https://bit.ly/3n17UdJ. Ms. Watkins is an accountant who is known as “the go-to 

treasurer for hundreds of Republican candidates and political groups around [Florida] and [the] 

country.” Florida 500, Professional Services, Nancy Watkins, https://bit.ly/3JO0dRV. 

25. South Florida Residents First is a federally registered super PAC formed under 

FECA in January 2020. South Florida Residents First, FEC Form 1, Statement of Organization, 

Jan. 6, 2020, https://bit.ly/3n38DuV. 

26. Paul Kilgore is, and at all relevant times was, treasurer of South Florida Residents 

First. South Florida Residents First, FEC Form 3X, 2020 April Quarterly Report, Apr. 15, 2020, 

https://bit.ly/3qWXm0j. Mr. Kilgore has served as the treasurer for hundreds of committees 

registered with the FEC. Committees, Most Recent Treasurer, “kilgore, paul,” Federal Election 

Commission, https://bit.ly/3Gi08Ed. 

True Source or Sources Unknown Respondents 

27. Unknown Respondents are the person or persons, natural or corporate, who are 

the true source or sources of contributions to Wingman PAC, American Valor PAC, Senate 

Leadership Fund, Concerned Conservatives, and South Florida Residents First that were falsely 

attributed to conduit entities Grow United, the Center for Advancement of Integrity and Justice, 

Florida Promise, Broken Promises, and Stand Up for Justice. 

Factual Allegations 

Leaked Documents Reveal Conduit Consultants’ Apparent Control and Use of Nonprofits 

28. In December 2021, the Orlando Sentinel first reported on a “cache” of documents 

detailing a close working relationship between top executives at the utility company Florida 

Power & Light and consultants that previously worked for the Alabama-based political and 

MUR808200011
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communications consulting firm Matrix, LLC. Garcia and Martin, Florida Power & Light execs 

worked closely with consultants. The documents included “checks, bank statements, emails, text 

messages, invoices, internal ledgers and more covering a roughly four-year period between 2016 

and 2020, all of which were apparently unearthed during an internal investigation” by Matrix. Id. 

The records and a summary of the internal Matrix investigation that proclaimed to have 

unearthed “potential unlawful conduct” were also sent to the chairman of Florida Power & 

Light’s parent company, NextEra Energy, Inc., in November 2021. Id. On a January 2022 

earnings call, NextEra Chairman Jim Robo indicated that the company conducted an internal 

investigation after receiving the report and said it “found no evidence of any issues at all, any 

illegality or any wrongdoing on the part of FPL or any of its employees.” Motley Fool 

Transcribing, NextEra Energy (NEE) Q4 2021 Earnings Call Transcript, The Motley Fool, Jan. 

25, 2022, https://bit.ly/3vP6xUn; Nate Monroe, Nate Monroe: NextEra, would-be JEA buyer, 

says internal investigation finds no wrongdoing by company, Florida Times-Union, Jan. 25, 

2022, https://bit.ly/3yhQ10G. 

29. The cache presents a credible record of a scheme to violate the FECA 

orchestrated by the Conduit Consultants. The Orlando Sentinel “independently corroborated 

dozens of details in the records” and a spokesperson for Florida Power & Light “did not dispute” 

details of the documents in response to questions from Orlando Sentinel reporters. Id. Instead, 

the spokesperson, David Reuter, appeared to confirm the authenticity of the documents by only 

contesting the completeness of the picture presented in them and attributing them to a leak by a 

former consultant as part of “a legal dispute.” Id. Mr. Reuter again declined to dispute the 

authenticity of the documents when he defended Florida Power & Light in an op-ed published 

MUR808200012
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shortly after the initial public disclosure of the documents. David P. Reuter, FPL: Spare us the 

outrage over contributions, Orlando Sentinel, Dec. 9, 2021, https://bit.ly/31nfpnL. 

30. Among other things, the Orlando Sentinel reported that the documents showed 

how Florida Power & Light had “donated more than $10 million in recent years to other darkmoney nonprofits controlled by” one or more of the Conduit Consultants, and that Mr. Silagy, 

the CEO and president of Florida Power & Light, had “personally coordinated with those 

consultants on campaign contributions made through their nonprofits.” Garcia and Martin, 

Florida Power & Light execs worked closely with consultants. In addition, according to the 

Florida Times-Union, which was given access to the cache of documents by the Orlando 

Sentinel, “the summary of Matrix’s internal investigation alleges that, beginning in 2016, the 

firm’s former employees created at least 19 different entities to use as vehicles for dark-money 

political contributions.” Nate Monroe, Law firm that advised on botched JEA sale also helped 

former FPL consultants on dark-money projects, Florida Times-Union, Dec. 17, 2021, 

https://bit.ly/3LShcDW. 

A Funding Structure for Corporate Political Contributions that Minimizes Disclosure 

31. The cache of documents included a pair of memos that Mr. Pitts, one of the 

Conduit Consultants who was still then the CEO of Matrix, LLC, sent by email on November 26, 

2019 to a pseudonymous email address that used the name “Theodore Hayes,” but the true 

recipient of the email was Florida Power & Light President and CEO Silagy. Jason Garcia and 

Annie Martin, Operatives pitched secretive political spending plan to FPL exec’s email alias, 

records reveal, Orlando Sentinel, Dec. 17, 2021, https://bit.ly/3nkbMHc; NextEra Energy, Inc. 

Florida Power & Light Company, Form 10-K Annual Report for Year Ending Dec. 31, 2021, 

MUR808200013
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United States Securities and Exchange Commission, Feb. 12, 2022, https://bit.ly/3uooJ5c. 

Florida Power & Light was one of Matrix’s clients at the time and confirmed to the Orlando 

Sentinel that the “Theodore Hayes” email account belonged to Mr. Silagy and was set up for him 

by the consulting firm. Garcia and Martin, Operatives pitched secretive political spending plan. 

32. In the November 2019 email, Mr. Pitts wrote, “Attached is an updated funding 

memo along with a separate legal memo on federal elections support.” Garcia and Martin, 

Operatives pitched secretive political spending plan. According to the Orlando Sentinel, the 

memos “laid out a proposal, written with help from one of Florida’s top law firms, for how 

[Florida Power & Light] money could be filtered through a network of companies and nonprofits 

that would then make campaign contributions to politicians in Florida and around the country. 

One of the chief goals was secrecy.” Id. One of the attached memos, which appears to have been 

written by Mr. Pitts (the “Pitts Memo”), described, in its own words, a plan to “develop a 

structure for funding 2020 activities — advertising, research, consulting, [nonprofit] donations, 

and campaign contributions to groups or individuals where laws allow.” Id. The Pitts Memo 

identified five goals, including funding both state and federal-level campaign contributions as 

well as a desire to “minimize all public reporting of entities and activities.” Id. 

MUR808200014
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33. The Pitts Memo included a flowchart, copied here. 

Garcia and Martin, Operatives pitched secretive political spending plan, (“fig. 1”). 

34. The Pitts Memo flowchart, see fig. 1, laid out how money originating from 

Florida Power & Light could flow through a series of conduit entities before being used to make 

MUR808200015
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political contributions. Id. The memo depicted money first flowing from Florida Power & Light 

to a company called Sun Marketing & Advertising, which is described as “an LLC filed in 

Delaware requiring one individual & no public disclosure of that individual’s name.” Id. The 

Orlando Sentinel noted that on December 13, 2019, about two weeks after the Pitts Memo was 

sent to Mr. Silagy, a company called SUN Marketing & Advertising was incorporated in 

Delaware. Id.; Sun Marketing & Advertising, LLC, Delaware Department of State: Division of 

Corporations, Entity Details, https://bit.ly/3GnSbgC. A spokesperson for Florida Power & Light 

also told the Orlando Sentinel that the power company had made one payment of $250,000 to 

Sun Marketing & Advertising in December 2019, but said the money was used to purchase 

advertising focused on a proposed constitutional amendment. Garcia and Martin, Operatives 

pitched secretive political spending plan. The Florida Power & Light spokesperson said the 

company believed that Sun Marketing & Advertising was owned by Matrix and that Florida 

Power & Light was not involved in the establishment of the Delaware-based LLC. Id. 

35. According to the flowchart in the Pitts Memo, see fig. 1, and the Orlando Sentinel

story describing it, “the memo depicted money flowing from” Sun Marketing & Advertising to 

an “existing ad agency” and an entity identified as “LPAD C4 (Tyson),” which the Orlando 

Sentinel identified as a nonprofit organization called Let’s Preserve the American Dream 

“controlled by a longtime political advisor” to a business lobbying group. Garcia and Martin, 

Operatives pitched secretive political spending plan. The executive director of Let’s Preserve the 

American Dream is named Ryan Tyson. Let’s Preserve the American Dream Inc., 2018 Form 

990, https://bit.ly/31SCMpD. 

MUR808200016
17 

36. According to the Orlando Sentinel, in the flowchart, “[m]oney then flowed from 

that nonprofit to several other nonprofits, which were controlled by Matrix and would then make 

campaign contributions.” Garcia and Martin, Operatives pitched secretive political spending 

plan. The other nonprofits on the flowchart are all seemingly identified as exempt from taxation 

under section 501(c)(4) of the tax code. Id.; see fig. 1. 

37. Directly below Let’s Preserve the American Dream on the flowchart is a group 

labeled “Broken Promises C4 (Matrix/Foley).” See id. Below that are three other groups labeled 

“Florida Promise C4 (Matrix/Foley),” “US Promise C4 (Matrix/Foley),” and “Fed Promise C4 

(Matrix/Foley).” Id. On the flowchart, below the entry for Florida Promise C4, a text box 

suggested that the nonprofit could be used for political contributions in Florida, stating that “C4s 

are allowed to spend 50% of revenues on political activities. Florida PCs are allowed to take 

unlimited funds from C4s.” Id. “PC” is common shorthand in Florida for “political committee” 

and many political action committees registered in the state include “PC” in their name. See, e.g.,

Florida Department of State, Committee Database Search, Search Committees by Name, Search 

Type Containing “PC,” https://bit.ly/3v7jXLo. Likewise, a text box under the US Promise C4 

entry noted, “C4s are allowed to spend 50% of revenues on political activities. Each state 

operates under unique state elections.” See fig. 1. The text box under the Fed Promise C4 entry 

simply stated: “Waiting on lawyers.” Id.

38. The second memo attached to Mr. Pitts’ November email appears to provide the 

information missing from the text box below Fed Promise C4. The memo was written by Erika 

Alba (“Alba Memo”), a political law attorney and public affairs director with Foley & Lardner 

LLP. Garcia and Martin, Operatives pitched secretive political spending plan; Foley & Lardner 

MUR808200017
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LLP, People, Erika E. Alba, https://bit.ly/33erxZd. In her memo, according to the Orlando 

Sentinel, Ms. Alba “explained the legalities of using nonprofits to spend money on federal 

elections” while warning that “a nonprofit might have to disclose its donors if it spent money 

directly supporting a candidate.” Garcia and Martin, Operatives pitched secretive political 

spending plan. Ms. Alba noted, however, that a nonprofit would not face the same risk of donor 

disclosure if it gave money to a super PAC that then spent the money supporting a candidate. Id. 

“‘Thus, it could be strategic for a [nonprofit] who wishes to make Independent Expenditures to 

do so via a Super PAC,’ Alba wrote.” Id. 

39. A spokesperson for Florida Power & Light seemingly confirmed the authenticity 

of the proposal obtained by the Orlando Sentinel, saying, “We are aware of the proposed 

structure as the legal memo was shared with us” but suggested the company did not utilize it, 

saying “[n]either FPL nor Eric Silagy requested Matrix to set up any proposed funding structure 

for 501C(4) organizations and we had no knowledge of this structure being used by Matrix.” Id. 

Mr. Reuter, however, has elsewhere indicated that Florida Power & Light and its executives have 

provided financial support to nonprofits that support political candidates. Reuter, FPL: Spare us 

the outrage. 

40. While casting doubt on whether Florida Power & Light utilized the funding 

structure proposed in the Pitts Memo, Mr. Reuter suggested that a similar proposal may have 

been provided to other Matrix clients, saying, “Joe Perkins’ team at Matrix created a proposal to 

fund their clients’ communication and outreach activities during 2020.” Garcia and Martin, 

Operatives pitched secretive political spending plan. Dr. Joseph Perkins is the founder and 

principal of Matrix, LLC and, as discussed below, the two were in litigation with a number of the 

MUR808200018
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Conduit Consultants, including Mr. Pitts, as well as Mr. Pitts’ new firm Canopy Partners, LLC 

(“Canopy Partners”). Kent Faulk, Alabama political crisis management company Matrix sues 

former employees, AL.com, Sept. 9, 2021, https://bit.ly/329T9xA; John Archibald, Archibald: 

Unveiling political dark arts in Alabama and Florida is critical to the republic, AL.com, Sept. 8, 

2021, https://bit.ly/3v3XNKa. An attorney representing Matrix told the Orlando Sentinel that 

neither Dr. Perkins nor any of his remaining employees were involved with the proposal Mr. 

Pitts presented to Mr. Silagy, blaming “rogue” ex-employees instead. Garcia and Martin, 

Operatives pitched secretive political spending plan. 

41. As explained below, during the 2020 election the Unknown Respondents, who 

may or may not include Florida Power & Light, appear to have used a version of the funding 

structure laid out in the Pitts Memo to channel contributions to federally-registered super PACs 

through nonprofits connected to the Conduit Consultants in order to evade public disclosure of 

the true source of the funds. As the Orlando Sentinel noted in its reporting on the Pitts and Alba 

Memos, “Matrix-related nonprofits” made “several donations to federal Super PACs,” the details 

of which match the contributions described below. Id. 

Conduit Consultant-Affiliated Nonprofits Contribute to Super PACs in 2020 

42. In 2020, a series of nonprofits seemingly controlled by the Conduit Consultants 

made contributions to super PACs in a manner consistent with the scheme laid out in the Pitts 

Memo, including using entities identified in the memo. Specifically, the nonprofits contributed a 

total of $1.27 million to super PACs through five channels: (1) Grow United contributed funds to 

Wingman PAC, (2) the Center for Advancement of Integrity & Justice contributed funds to 

American Valor PAC, (3) Florida Promise contributed funds to the Senate Leadership Fund, 

MUR808200019
20 

(4) Broken Promises contributed funds to Concerned Conservatives, Inc., and (5) Stand Up for 

Justice contributed funds to South Florida Residents First. These contributions are consistent 

with the scheme laid out in the Pitts Memo, and the close ties of the groups involved with the 

author of the Pitts Memo and other Conduit Consultants gives rise to a reason to believe the 

transactions represent unlawful passthrough contributions in the name of another. See fig. 2 

(visual summary of cash flows in nonprofit conduit scheme). 

MUR808200020
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Fig. 2. 

Grow United 

43. On October 27, 2020, Grow United transferred $100,000 to Wingman PAC, a 

single-candidate super PAC that spent more than $337,000 on independent expenditures 

benefiting Scott Franklin in the race for Florida’s 15th congressional seat. Wingman PAC, FEC 

MUR808200021
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Form 3X, 2020 Post-General Report, Dec. 3, 2020, https://bit.ly/3n22ZcL; Wingman PAC, 

Independent Expenditures, 2019-2020, Federal Election Commission, https://bit.ly/3y6xCUH; 

Peter Schorsch, Wingman PAC drops pro-Scott Franklin ad blasting Alan Cohn as tax and spend 

liberal, Florida Politics, Oct. 28, 2020, https://bit.ly/3BKJWtq. Grow United’s contribution was 

the single largest contribution the super PAC received during the two-year 2020 election cycle. 

Wingman PAC, Receipts, 2019-2020, Federal Election Commission, https://bit.ly/351b4Zj. 

44. Grow United is controlled by the Conduit Consultants. Based on the records it 

obtained, the Orlando Sentinel reported that the nonprofit was set up and controlled by Conduit 

Consultants, including Mr. Pitts, and described the Conduit Consultants’ involvement in Grow 

United’s operations. Garcia and Martin, Florida Power & Light execs worked closely with 

consultants; Garcia and Martin, Florida’s dark money playbook; see also Jason Garcia and Annie 

Martin, Big-business-linked group funded ‘ghost’ candidate ads, records show, Orlando Sentinel, 

Jan. 18, 2022, https://bit.ly/3Mav2lh. In addition, at all relevant times, Grow United’s chairman 

was Richard Alexander, who is also chairman of a nonprofit group that appeared in the Pitts 

Memo, Florida Promise, and whose sister April Odom is one of the Conduit Consultants who set 

up and controlled Grow United. Garcia and Martin, Chair of dark-money group. 

45. In 2020, Grow United also received funding from one of the intermediary 

nonprofits listed in the Pitts Memo’s funding structure flowchart. According to tax records 

obtained by the Orlando Sentinel, Let’s Preserve the American Dream provided $1.15 million to 

Grow United in 2020. Jason Garcia and Annie Martin, Big business-linked group gave over $1 

million to dark-money entity promoting ‘ghost’ candidates, Orlando Sentinel, Nov. 18, 2021, 

https://bit.ly/3HglNME; Garcia and Martin, Operatives pitched secretive political spending plan; 

MUR808200022
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see fig. 1. Records obtained by the Orlando Sentinel and testimony from Mr. Tyson, the 

executive director of Let’s Preserve the American Dream, show that $600,000 of the $1.15 

million Let’s Preserve the American Dream gave to Grow United was effectively earmarked to 

pass on to political committees to pay for the mailers that promoted the “ghost” candidates in 

Florida state Senate races, with Mr. Tyson both ordering Let’s Preserve the American Dream’s 

transfer to Grow United and telling representatives of the nonprofit to expect a request for a 

donation from the political operative who ran the Florida political committees that Grow United 

subsequently funded. Garcia and Martin, Florida Power & Light execs worked closely with 

consultants; Garcia and Martin, Big-business-linked group funded ‘ghost’ candidate ads, records 

show. 

46. Grow United participated in other state-level conduit schemes as well, as 

indicated in the records obtained by the Orlando Sentinel as well as information produced by the 

Florida state investigation into the “ghost” candidate scandal. Garcia and Martin, Florida Power 

& Light execs worked closely with consultants; Jason Garcia and Annie Martin, Dems gave 

$700K to dark-money group that helped Republicans win races in ‘ghost’ candidate scandal, 

Orlando Sentinel, Sept. 9, 2021, https://bit.ly/3BONzyF; Jeff Weiner, Annie Martin, and Jason 

Garcia, Interviews examine Artiles’ boasts about ‘ghost’ candidate scheme, funding for darkmoney group, Orlando Sentinel, Nov. 17, 2021, https://bit.ly/3hjGpZD; Ana Ceballos and 

Samantha J. Gross, Florida Democrats also used dark money group that paid for sham candidate 

mailers, Tampa Bay Times, Nov. 19, 2021, https://bit.ly/3hwaQMd. 

MUR808200023
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The Center for Advancement of Integrity and Justice

47. On October 27, 2020, the Center for Advancement of Integrity and Justice 

transferred $100,000 to American Valor PAC, a single-candidate super PAC that spent more 

than $286,000 on independent expenditures benefiting candidate Anna Paulina Luna in the race 

for Florida’s 13th congressional district. American Valor PAC, FEC Form 3X, Termination 

Report, Dec. 3, 2020, https://bit.ly/3t25pvO; American Valor PAC, Independent Expenditures, 

2019-2020, Federal Election Commission, https://bit.ly/3IeEmlB; Daniel Molina, Crist Called 

“one of Florida’s Least Effective Congressmen”, The Floridian, Oct. 2, 2020, 

https://bit.ly/3JS8yUa. The Center for Advancement of Integrity and Justice’s contribution was 

the single largest contribution the super PAC received during the two-year 2020 election cycle. 

American Valor PAC, Receipts, 2019-2020, Federal Election Commission, 

https://bit.ly/3JMWP9c. 

48. There is reason to believe the Center for Advancement of Integrity and Justice 

was controlled by the Conduit Consultants. At all relevant times, the president of the Center for 

Advancement of Integrity of Justice was Mr. Alexander, who was also chair of Grow United, an 

entity that participated in state-level conduit schemes, and chairman of an entity that appears on 

the Pitts Memo, Florida Promise. Garcia and Martin, Chair of dark-money group; Garcia, 

Twitter, Oct. 24, 2021. Further, Mr. Alexander’s sister, Ms. Odom, is one of the Conduit 

Consultants who set up and controlled Grow United, and text message obtained by the Orlando 

Sentinel confirmed that Ms. Odom had access to banking information for both Grow United and 

the Center for Advancement of Integrity and Justice. Garcia and Martin, Florida’s dark money 

playbook; see also https://bit.ly/3vc9ZIF. 

MUR808200024
25 

Florida Promise

49. On December 8, 2020, Florida Promise transferred $1 million to the Senate 

Leadership Fund, a federal super PAC with ties to Senate Minority Leader Mitch McConnell (RKY) that spent more than $293 million on independent expenditures benefiting Republicans 

seeking to defend or win Senate seats in 2020. Senate Leadership Fund, FEC Form 3X, 2020 

Year-End Report, Amended, Mar. 18, 2021, https://bit.ly/337G4FQ; Senate Leadership Fund, 

Independent Expenditures, 2019-2020, Federal Election Commission, https://bit.ly/3sg1AC8; 

Lachlan Markay, Late “dark money” flooded key Senate races, Axios, Feb. 5, 2021, 

https://bit.ly/36Iog61; Garcia and Martin, Chair of dark-money group. 

50. There is reason to believe Florida Promise was controlled by the Conduit 

Consultants. As noted above, one of the entities described in the Pitts Memo funding structure 

flowchart was labeled “Florida Promise C4,” and the flowchart suggested it was a vessel for 

making conduit contributions to Florida state political committees. Garcia and Martin, 

Operatives pitched secretive political spending plan; see fig. 1. Florida Promise made 

contributions to Florida state political committees both before and after the Pitts Memo was sent 

to Mr. Silagy. See Contributions Query Results, Election Year: All, With Payee Last Name Starts 

With: florida promise, Division of Elections, Florida Department of State, 

https://bit.ly/3he3Gw9; Florida First, Forever, Inc., Statement of Organization of Political 

Committee, Division of Elections, Florida Department of State, June 30, 2016, 

https://bit.ly/3hbITcL; Florida Republican Senatorial Campaign Committee, By-Laws of the 

Florida Republican Senatorial Campaign Committee, Division of Elections, Florida Department 

of State, Oct. 10, 2014, https://bit.ly/2IHjcTD. Additionally, at all relevant times, Mr. Alexander 

MUR808200025
26 

was the chairman of Florida Promise, the chair of Grow United, an entity involved in state level 

conduit contributions, and president of the Center for Advancement of Integrity and Justice. Mr. 

Alexander’s sister is one of the Conduit Consultants who set up and controlled Grow United. 

Garcia and Martin, Chair of dark-money group. 

Broken Promises

51. On July 14, 2020, Broken Promises transferred $20,000 to Concerned 

Conservatives, Inc., a single-candidate super PAC that spent more than $424,000 on independent 

expenditures benefiting candidate Dane Eagle in the race for Florida’s 19th congressional seat. 

Concerned Conservatives, Inc., FEC Form 3X, 2020 Pre-Primary Report, Aug. 6, 2020, 

https://bit.ly/3n17UdJ; Concerned Conservatives, Inc., Independent Expenditures, 2019-2020, 

Federal Election Commission, https://bit.ly/380ELez; Jacob Ogles, Club for Growth spends big 

boosting Byron Donalds, bashing Casey Askar, Florida Politics, July 28, 2020, 

https://bit.ly/3Iqnf0o. Broken Promise’s contribution was the fourth largest contribution received 

by the super PAC in the two-year 2020 election cycle. Concerned Conservatives, Inc., Receipts, 

2019-2020, Federal Election Commission, https://bit.ly/3t9xcsw. 

52. There is reason to believe Broken Promises was controlled by the Conduit 

Consultants. As noted above, one of the entities described in the Pitts Memo funding structure 

flowchart was labeled “Broken Promises.” Garcia and Martin, Operatives pitched secretive 

political spending plan; see fig. 1. In the flowchart, Broken Promises was stationed between 

Let’s Preserve the American Dream and other nonprofit entities. Id. Bank records obtained by 

the Miami-Dade State Attorney’s Office reveal that Let’s Preserve the American Dream 

provided Broken Promises $26,000 on July 9, 2020, just five days before Broken Promises made 

MUR808200026
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its $20,000 contribution to Concerned Conservatives, Inc. Jeff Weiner and Annie Martin, Bank 

records shed light on dark-money group in ‘ghost’ candidate scandal, Orlando Sentinel, Apr. 18, 

2022, https://bit.ly/3KJVal2. According to the Orlando Sentinel, some of the leaked records it 

received indicated that Broken Promises was controlled by the Conduit Consultants. Garcia and 

Martin, Florida Power & Light execs worked closely with consultants; Garcia and Martin, PAC 

activity in 2020 ‘ghost’ candidate race. Additionally, Broken Promises was chaired by Mr. 

Anderson, an individual who Mr. Pitts identified as an old friend and who nominally ran one or 

more nonprofits Mr. Pitts stated were in actuality under “100 percent control” of Mr. Pitts and 

his associates. Nehamas and Klas, DeSantis ’18 campaign got $25,000 from nonprofit secretly 

funded by FPL cash, records show; Klas, Nehamas, and Chain, ‘Nightmare scenario’: How FPL 

secretly manipulated a Florida state Senate election. 

Stand Up for Justice

53. On March 31, 2020, Stand Up for Justice transferred $50,000 to South Florida 

Residents First, a single-candidate super PAC that spent more than $656,000 on independent 

expenditures benefiting now-Rep. Carlos Gimenez in the race for Florida’s 26th congressional 

seat. South Florida Residents First, FEC Form 3X, 2020 April Quarterly Report, Apr. 15, 2020, 

https://bit.ly/3qWXm0j; South Florida Resident First, Independent Expenditures, 2019-2020, 

Federal Election Commission, https://bit.ly/38ISLtk; Ryan Nicol, From Dade to D.C.: Carlos 

Gimenez defeats Debbie Mucarsel-Powell, Florida Politics, Nov. 3, 2020, 

https://bit.ly/36EWUgY; See also https://bit.ly/3sYMMXG. Stand Up for Justice’s contribution 

was tied for the largest contribution received by the super PAC during the two-year 2020 

MUR808200027
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election cycle. South Florida Residents First, Receipts, 2019-2020, Federal Election 

Commission, https://bit.ly/3IkUIcw. 

54. There is reason to believe Stand Up for Justice is controlled by the Conduit 

Consultants. At all relevant times, Sean Jason Anderson was the board president of Stand up for 

Justice, while also serving as president and chairman of Broken Promises. Martin and Garcia, 

PAC activity in 2020 ‘ghost’ candidate race, an entity listed on the Pitts Memo, Garcia and 

Martin, Operatives pitched secretive political spending plan; see fig. 1. Additionally, Mr. 

Anderson was identified by Mr. Pitts as an old friend who nominally ran at least one nonprofit 

that Mr. Pitts stated were in actuality under “100 percent control” of Mr. Pitts and his associates. 

Nehamas and Klas, DeSantis ’18 campaign got $25,000 from nonprofit secretly funded by FPL 

cash, records show; Klas, Nehamas, and Chain, ‘Nightmare scenario’: How FPL secretly 

manipulated a Florida state Senate election. Stand up for Justice also appeared to be a highly 

similar organization to Broken Promises, as it was founded the same day in 2018, shared the 

same board, and used the same accounting firm to prepare its tax returns. 

Matrix Alleges Conduit Consultants Operated Without the Firm’s Knowledge or Authorization

55. While the Conduit Consultants were employed by Matrix during the period when 

the nonprofit organizations contributed to the super PACs, Matrix later alleged that they were 

operating without the firm’s knowledge or authorization. In or around December 2020, several 

consultants associated with Matrix, including Mr. Pitts and Ms. Odom, left the company and 

formed or joined Canopy Partners. Faulk, Alabama political crisis management company Matrix 

sues former employees; Archibald, Archibald: Unveiling political dark arts in Alabama and 

Florida is critical to the republic. Matrix and Dr. Perkins sued those former consultants and 

MUR808200028
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Canopy Partners. See Complaint, Matrix, LLC v. Canopy Partners LLC, et al., 01-CV-2021-

902121.00 (Jeff. Cnty. Ala. Cir. Ct.), available at https://bit.ly/3v3XNKa; Complaint, Canopy 

Partners, LLC and Jeff Pitts v. Joseph Perkins, 2021-CA-004783 (Fla. Cir. Ct., 4th Jud. Cir., 

Duval Cnty.), available at https://bit.ly/3v3XNKa. In the context of Matrix’s lawsuit, that firm’s 

lawyer alleged that the former consultants “conducted secret, off-the-books communications 

campaigns that were not authorized by Matrix or Dr. Perkins.” Letter from Carson M. Kirby to 

Daniel Tait, Energy and Policy Institute (Jan. 14, 2022), https://bit.ly/3MWXPtt. The lawyer 

further asserted that Dr. Perkins and Matrix employees did not have “any direct or indirect 

involvement in any of the Florida ghost candidate campaigns,” and to the extent that Mr. Pitts or 

others were involved in them, “their involvement was without Matrix’s knowledge or consent 

and contrary to Matrix policy.” Id. Canopy Partners and Mr. Pitts denied the allegations and 

countersued Dr. Perkins, accusing him of extortion. Complaint, Canopy Partners, LLC and Jeff 

Pitts v. Joseph Perkins, 2021-CA-004783 (Fla. Cir. Ct., 4th Jud. Cir., Duval Cnty.); Garcia and 

Martin, Florida’s dark money playbook. The parties agreed to dismiss both cases in August 

2022, ending the litigation. Jeff Weiner, Political operatives whose feud spilled dark money 

secrets agree to settle suit, Orlando Sentinel, Aug. 31, 2022, https://bit.ly/3g6hBa4; Jeff Poor, 

Matrix-Canopy Partners legal dispute ends in an apparent truce, 1819 News, Sept. 1, 2022, 

https://bit.ly/3VwSrlh. 

Count I 

56. The FECA and FEC regulations prohibit knowingly permitting one’s name to be 

used to effect a contribution in the name of another person. 52 U.S.C. § 30122; 11 C.F.R. 

§ 110.4(b). 

MUR808200029
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57. There is reason to believe that Grow United, the Center for Advancement of 

Integrity and Justice, Florida Promise, Broken Promises, and Stand Up for Justice, by and 

through Mr. Alexander and Mr. Anderson, violated this law by allowing their names to be used 

to effect one or more contributions to super PACs by Unknown Respondents who are the true 

source of the contributions. The funding structure developed by the Conduit Consultants, who 

seemingly controlled these conduits, had an explicit goal of making political contributions while 

evading public disclosure, suggesting that the violations were both knowing and willful. 

58. A “reason to believe” exists where a complaint “credibly alleges” a violation of 

the FECA “may have occurred.” Federal Election Commission, Statement of Policy Regarding 

Commission Action in Matters at the Initial Stage in the Enforcement Process, 72 Fed. Reg. 

12545, Mar. 16, 2007. “Reason to believe” is a threshold standard under federal law that does not 

establish by itself that a violation has occurred. The Commission has stated that it “will find 

‘reason to believe’ in cases where the available evidence in the matter is at least sufficient to 

warrant conducting an investigation, and where the seriousness of the alleged violation warrants 

either further investigation or immediate conciliation.” Id. 

59. As detailed above, each of the nonprofits appear to be controlled by the Conduit 

Consultants who pitched clients on a scheme to evade public reporting on corporate funds used 

for political contributions by routing the contributions through conduits. A legal memo on 

“federal elections support” provided by the consultants to one of their clients further suggested 

that because of concerns about disclosure, “it could be strategic for a [nonprofit] who wishes to 

make Independent Expenditures to do so via a Super PAC.” 

MUR808200030
31 

60. There is reason to believe that Grow United, one of the nonprofits controlled by 

the Conduit Consultants which participated in state-level conduit contribution schemes, and Mr. 

Alexander participated in the federal conduit scheme when, on October 27, 2020, Grow United 

transferred $100,000 to Wingman PAC and permitted its name be used in the place of the 

Unknown Respondents who were the true source of the contribution. 

61. Accordingly, there is reason to believe Grow United, by and through Mr. 

Alexander, knowingly permitted its name to be used to effect a contribution in the name of 

another, in violation of 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b). If these violations were 

knowing and willful, they are also subject to criminal penalties and referral to the Department of 

Justice. 52 U.S.C. §§ 30109(a)(5)(C), (d)(1). 

62. There is reason to believe that the Center for Advancement of Integrity and 

Justice, one of the nonprofits seemingly controlled by the Conduit Consultants, and Mr. 

Alexander similarly participated in the conduit scheme when, on October 27, 2020, the Center 

for Advancement of Integrity and Justice transferred $100,000 to American Valor PAC and 

permitted its name to be used in the place of the Unknown Respondents who were the true 

source of the money. 

63. Accordingly, there is reason to believe the Center for Advancement of Integrity 

and Justice, by and through Mr. Alexander, knowingly permitted its name to be used to effect a 

contribution in the name of another, in violation of 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b). 

If these violations were knowing and willful, they are also subject to criminal penalties and 

referral to the Department of Justice. 52 U.S.C. §§ 30109(a)(5)(C), (d)(1). 

MUR808200031
32 

64. There is reason to believe Florida Promise, one of the nonprofits seemingly 

controlled by the Conduit Consultants and which appeared on the Pitts Memo, and Mr. 

Alexander similarly participated in the conduit scheme when, on December 8, 2020, Florida 

Promise transferred $1 million to the Senate Leadership Fund and permitted its name be used in 

the place of the Unknown Respondents who were the true source of the contribution. 

65. Accordingly, there is reason to believe Florida Promise, by and through Mr. 

Alexander, knowingly permitted its name to be used to effect a contribution in the name of 

another, in violation of 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b). If these violations were 

knowing and willful, they are also subject to criminal penalties and referral to the Department of 

Justice. 52 U.S.C. §§ 30109(a)(5)(C), (d)(1). 

66. There is reason to believe Broken Promises, one of the nonprofits seemingly 

controlled by the Conduit Consultants and which appeared on the Pitts Memo, and Mr. Anderson 

similarly participated in the conduit scheme when, on July 14, 2020, Broken Promises 

transferred $20,000 to Concerned Conservatives, Inc. and permitted its name be used in the place 

of the Unknown Respondents who were the true source of the contribution. 

67. Accordingly, there is reason to believe Broken Promises, by and through Mr. 

Anderson, knowingly permitted its name to be used to effect a contribution in the name of 

another, in violation of 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b). If these violations were 

knowing and willful, they are also subject to criminal penalties and referral to the Department of 

Justice. 52 U.S.C. §§ 30109(a)(5)(C), (d)(1). 

68. There is reason to believe Stand Up for Justice, one of the nonprofits seemingly 

controlled by the Conduit Consultants, and Mr. Anderson similarly participated in the conduit 

MUR808200032
33 

scheme when, on March 31, 2020, Stand Up for Justice transferred $50,000 to South Florida 

Residents First and permitted its name be used in the place of the Unknown Respondents who 

were the true source of the contribution. 

69. Accordingly, there is reason to believe Stand Up for Justice, by and through Mr. 

Anderson, knowingly permitted its name to be used to effect a contribution in the name of 

another, in violation of 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b). If these violations were 

knowing and willful, they are also subject to criminal penalties and referral to the Department of 

Justice. 52 U.S.C. §§ 30109(a)(5)(C), (d)(1). 

Count II 

70. The FECA and FEC regulations prohibit knowingly accepting a contribution 

made by one person in the name of another. 52 U.S.C. § 30122; 11 C.F.R. § 110.4(b). The FECA 

and FEC regulations further require political committees to report the identity of the true source 

of contributions, as well as anyone who acted as a conduit for a contribution. 52 U.S.C. 

§ 30104(b)(2); 11 C.F.R. § 104.3(a), (j) (political committees must report “earmarked 

contributions”); see also Instructions for FEC Form 3X and related Schedules at 11 (revised 

May 2016), https://bit.ly/2F19VxP (any political committee receiving an earmarked contribution 

through conduit entities must “report each conduit through which the earmarked contribution 

passed, including the name and address of the conduit, and whether the contribution was passed 

on in cash, by the contributor’s check, or by the conduit’s check”); 52 U.S.C. § 30107(a)(8) 

(FEC forms have force of law). 

71. There is reason to believe Wingman PAC, American Valor PAC, Senate 

Leadership Fund, Concerned Conservatives, Inc., and South Florida Residents First, independent 

MUR808200033
34 

expenditure-only political committees established under the FECA, each violated the prohibition 

on knowingly accepting a contribution made by one person in the name of another and violated 

their obligations to report the identity of the true source or sources of contributions and anyone 

who acted as a conduit for a contribution. 

72. As detailed above, each of the super PACs received contributions from nonprofits 

apparently controlled by the Conduit Consultants who pitched clients on a scheme to minimize 

the public reporting on corporate funds used for political contributions by routing the 

contributions through conduits. A legal memo on “federal elections support” provided by the 

consultants to one of their clients further suggested that because of concerns about disclosure, “it 

could be strategic for a [nonprofit] who wishes to make Independent Expenditures to do so via a 

Super PAC.” 

73. There is reason to believe Wingman PAC participated in the conduit scheme 

when, on October 27, 2020, the super PAC knowingly accepted a $100,000 contribution from 

Unknown Respondents in the name of a conduit entity, Grow United, a section 501(c)(4) 

organization that is not required to disclose its donors. The contribution was also the single 

largest contribution the super PAC received during the 2020 election. 

74. Accordingly, there is reason to believe Wingman PAC by and through its 

treasurer, Abby Dupree, knowingly accepted a contribution made by one person in the name of 

another in violation of 5 U.S.C. § 30122 and 11 C.F.R. § 110.4(b). If Wingman PAC and Ms. 

Dupree’s violations were knowing and willful, they also are subject to criminal penalties and 

referral to the Department of Justice. 52 U.S.C. §§ 30109(a)(5)(C), (d)(1). 

75. Further, there is reason to believe that Wingman PAC, by and through its 

MUR808200034
35 

treasurer, Ms. Dupree, also failed to report the identities of the true source or sources of 

contributions and the identities of each conduit for the contributions falsely attributed to Grow 

United, violating 52 U.S.C. § 30104(b)(2) and 11 C.F.R. § 104.3(a) and (j). If Wingman PAC 

and Ms. Dupree’s violations were knowing and willful, they also are subject to criminal penalties 

and referral to the Department of Justice. 52 U.S.C. §§ 30109(a)(5)(C), (d)(1). 

76. There is reason to believe American Valor PAC participated in the conduit 

scheme when, on October 27, 2020, the super PAC knowingly accepted a $100,000 contribution 

from Unknown Respondents in the name of the conduit entity, Center for Advancement of 

Integrity and Justice, a section 501(c)(4) organization that is not required to disclose its donors. 

The contribution was also the single largest contribution the super PAC received during the 2020 

election. 

77. Accordingly, there is reason to believe American Valor PAC by and through its 

treasurer, Lisa Lisker, knowingly accepted a contribution made by one person in the name of 

another in violation of 5 U.S.C. § 30122 and 11 C.F.R. § 110.4(b). If American Valor PAC and 

Ms. Lisker’s violations were knowing and willful, they also are subject to criminal penalties and 

referral to the Department of Justice. 52 U.S.C. §§ 30109(a)(5)(C), (d)(1). 

78. Further, there is reason to believe American Valor PAC, by and through its 

treasurer, Ms. Lisker, also failed to report the identities of the true source or sources of 

contributions and the identities of each conduit for the contributions falsely attributed to the 

Center for Advancement of Integrity and Justice, violating 52 U.S.C. § 30104(b)(2) and 11 

C.F.R. § 104.3(a) and (j). If American Valor PAC and Ms. Lisker’s violations were knowing and 

willful, they also are subject to criminal penalties and referral to the Department of Justice. 52 

MUR808200035
36 

U.S.C. §§ 30109(a)(5)(C), (d)(1). 

79. There is reason to believe the Senate Leadership Fund participated in the conduit 

scheme when, on December 8, 2020, the super PAC knowingly accepted a $1 million 

contribution from Unknown Respondents in the name of the conduit entity, Florida Promise, a 

section 501(c)(4) organization that is not required to disclose its donors. 

80. Accordingly, there is reason to believe the Senate Leadership Fund by and 

through its treasurer, Caleb Crosby, knowingly accepted a contribution made by one person in 

the name of another in violation of 5 U.S.C. § 30122 and 11 C.F.R. § 110.4(b). If the Senate 

Leadership Fund and Mr. Crosby’s violations were knowing and willful, they also are subject to 

criminal penalties and referral to the Department of Justice. 52 U.S.C. §§ 30109(a)(5)(C), (d)(1). 

81. Further, there is reason to believe the Senate Leadership Fund, by and through its 

treasurer, Mr. Crosby, also failed to report the identities of the true source or source of 

contributions and the identities of each conduit for the contributions falsely attributed to Florida 

Promise, violating 52 U.S.C. § 30104(b)(2) and 11 C.F.R. § 104.3(a) and (j). If the Senate 

Leadership Fund and Mr. Crosby’s violations were knowing and willful, they also are subject to 

criminal penalties and referral to the Department of Justice. 52 U.S.C. §§ 30109(a)(5)(C), (d)(1). 

82. There is reason to believe Concerned Conservatives, Inc. participated in the 

conduit scheme when, on July 14, 2020, the super PAC knowingly accepted a $20,000 

contribution from Unknown Respondents in the name of the conduit entity, Broken Promises, a 

section 501(c)(4) organization that is not required to disclose its donors. The contribution was 

also the fourth largest contribution the super PAC received during the 2020 election. 

83. Accordingly, there is reason to believe Concerned Conservatives, Inc., by and 

MUR808200036
37 

through its treasurer, Nancy H. Watkins, knowingly accepted a contribution made by one person 

in the name of another in violation of 5 U.S.C. § 30122 and 11 C.F.R. § 110.4(b). If Concerned 

Conservatives, Inc. and Ms. Watkins’s violations were knowing and willful, they also are subject 

to criminal penalties and referral to the Department of Justice. 52 U.S.C. §§ 30109(a)(5)(C), 

(d)(1). 

84. Further, there is reason to believe Concerned Conservatives, Inc., by and through 

its treasurer, Ms. Watkins, also failed to report the identities of the true source or sources of 

contributions and the identities of each conduit for the contributions falsely attributed to Broken 

Promises, violating 52 U.S.C. § 30104(b)(2) and 11 C.F.R. § 104.3(a) and (j). If Concerned 

Conservatives, Inc. and Ms. Watkins’s violations were knowing and willful, they also are subject 

to criminal penalties and referral to the Department of Justice. 52 U.S.C. §§ 30109(a)(5)(C), 

(d)(1). 

85. There is reason to believe South Florida Residents First participated in the conduit 

scheme when, on March 31, 2020, the super PAC knowingly accepted a $50,000 contribution 

from Unknown Respondents in the name of the conduit entity, Stand Up for Justice, a section 

501(c)(4) organization that is not required to disclose its donors. The contribution was tied for 

the largest contribution the super PAC received during the 2020 election. 

86. Accordingly, there is reason to believe South Florida Residents First, by and 

through its treasurer, Paul Kilgore, knowingly accepted a contribution made by one person in the 

name of another in violation of 5 U.S.C. § 30122 and 11 C.F.R. § 110.4(b). If South Florida 

Residents First and Mr. Kilgore’s violations were knowing and willful, they also are subject to 

criminal penalties and referral to the Department of Justice. 52 U.S.C. §§ 30109(a)(5)(C), (d)(1). 

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87. Further, there is reason to believe South Florida Residents First, by and through 

its treasurer, Mr. Kilgore, also failed to report the identities of the true source or sources of 

contributions and the identities of each conduit for the contributions falsely attributed to Stand 

Up for Justice, violating 52 U.S.C. § 30104(b)(2) and 11 C.F.R. § 104.3(a) and (j). If South 

Florida Residents First and Mr. Kilgore’s violations were knowing and willful, they also are 

subject to criminal penalties and referral to the Department of Justice. 52 U.S.C. 

§§ 30109(a)(5)(C), (d)(1). 

Count III 

88. The FECA and FEC regulations further prohibit making a contribution in the 

name of another person. 52 U.S.C. § 30122; 11 C.F.R. § 110.4(b). 

89. There is reason to believe Unknown Respondents made a contribution or 

contributions to Wingman PAC using Grow United as a conduit, which contribution or 

contributions were falsely identified as originating from Grow United. By making one or more 

contributions to Wingman PAC in the name of Grow United, Unknown Respondents violated 52 

U.S.C. § 30122 and 11 C.F.R. § 110.4(b). If Unknown Respondents’ violations were knowing 

and willful, they also are subject to criminal penalties and referral to the Department of Justice. 

52 U.S.C. §§ 30109(a)(5)(C), (d)(1). 

90. There is reason to believe Unknown Respondents made a contribution or 

contributions to American Valor PAC using the Center for Advancement of Integrity and Justice 

as a conduit, which contribution or contributions were falsely identified as originating from the 

Center for Advancement of Integrity and Justice. By making one or more contributions to 

American Valor PAC in the name of the Center for Advancement of Integrity and Justice, 

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Unknown Respondents violated 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b). If Unknown 

Respondents’ violations were knowing and willful, they also are subject to criminal penalties and 

referral to the Department of Justice. 52 U.S.C. §§ 30109(a)(5)(C), (d)(1). 

91. There is reason to believe Unknown Respondents made a contribution or 

contributions to the Senate Leadership Fund using Florida Promise as a conduit, which 

contribution or contributions were falsely identified as originating from Florida Promise. By 

making one or more contributions to the Senate Leadership Fund in the name of Florida Promise, 

Unknown Respondents violated 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b). If Unknown 

Respondents’ violations were knowing and willful, they also are subject to criminal penalties and 

referral to the Department of Justice. 52 U.S.C. §§ 30109(a)(5)(C), (d)(1). 

92. There is reason to believe Unknown Respondents made a contribution or 

contributions to Concerned Conservatives, Inc. using Broken Promises as a conduit, which 

contribution or contributions were falsely identified as originating from Broken Promises. By 

making one or more contributions to Concerned Conservatives, Inc. in the name of Broken 

Promises, Unknown Respondents violated 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b). If 

Unknown Respondents’ violations were knowing and willful, they also are subject to criminal 

penalties and referral to the Department of Justice. 52 U.S.C. §§ 30109(a)(5)(C), (d)(1). 

93. There is reason to believe Unknown Respondents made a contribution or 

contributions to South Florida Residents First using Stand Up for Justice as a conduit, which 

contribution or contributions were falsely identified as originating from Stand Up for Justice. By 

making one or more contributions to South Florida Residents First in the name of Stand Up for 

Justice, Unknown Respondents violated 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b). If 

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