1 FEDERAL ELECTION COMMISSION

2 FIRST GENERAL COUNSEL’S REPORT

3 MUR 8082 

4 DATE COMPLAINT FILED: Oct. 27, 2022 

5 DATE OF NOTIFICATIONS: Nov. 03, 2022 

6 LAST RESPONSE RECEIVED: Apr. 25, 2023 

7 DATE ACTIVATED: Apr. 25, 2023 

8 

9 EXPIRATION OF SOL: Mar. 31, 2025 - 

10 Dec. 8, 2025 

11 ELECTION CYCLE: 2020 

12 COMPLAINANTS: Noah Bookbinder 

13 Citizens for Responsibility and Ethics in Washington 

 14 

15 RESPONDENTS: Alleged Undisclosed Contributors 

16 Unknown Respondents 

17 Florida Power & Light Company 

18 Alleged Higher-Level Conduits 

19 SUN Marketing & Advertising LLC 

20 Let’s Preserve the American Dream, Inc.

21 Alleged Lower-Level Conduits and their Officers

22 Florida Promise, Inc. 

23 Center for Advancement of Integrity and Justice, Inc.

24 Grow United, Inc. 

25 Broken Promises 

26 Stand Up for Justice 

27 Richard Alexander

28 Sean J. Anderson 

29 Recipient IEOPCs and Treasurers

30 Senate Leadership Fund and Caleb Crosby in his 

31 official capacity as treasurer and in his personal 

32 capacity 

33 American Valor PAC and Lisa Lisker in her official 

34 capacity as treasurer and in her personal capacity 

35 Conservative Action Fund (f/k/a Wingman PAC) and 

36 Charles Gantt in his official capacity as treasurer

37 Abby Dupree in her personal capacity as the former 

38 treasurer of Wingman PAC 

39 Concerned Conservatives, Inc., and Nancy H. Watkins 

40 in her official capacity as treasurer and in her personal 

41 capacity

MUR808200234
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 2 of 48

1 South Florida Residents First and Paul Kilgore in his 

2 official capacity as treasurer and in his personal 

3 capacity

4 RELEVANT STATUTES 52 U.S.C. § 30122 

5 AND REGULATIONS: 11 C.F.R. § 110.4(b) 

6 

7 INTERNAL REPORTS CHECKED: Disclosure Reports 

8 FEDERAL AGENCIES CHECKED: None 

9 I. INTRODUCTION

10 The Complaint alleges that Unknown Respondents, possibly including Florida Power and 

11 Light Company (“FPL”), made five contributions in the name of another, totaling $1.27 million, 

12 through a network of conduits associated with a political consulting firm called Matrix LLC 

(“Matrix”), to five federal independent expenditure-only political committees (“IEOPCs”).

1 13 The 

14 specific contributions identified in the Complaint are as follows: 

15 • a $1,000,000 contribution reportedly from Florida Promise, Inc. (“Florida Promise”) 

to Senate Leadership Fund, dated December 8, 2020;2 16 

17 • a $100,000 contribution reportedly from the Center for Advancement of Integrity and 

Justice, Inc. (“CAIJ”) to American Valor PAC, dated October 27, 2020;3 18 

19 • a $100,000 contribution reportedly from Grow United, Inc. (“Grow United”) to 

Conservative Action Fund (f/k/a Wingman PAC), also dated October 27, 2020;4 20 

1

 Compl. ¶¶ 2, 5, 27, 42, 89-93 (Oct. 27, 2022).

2

 Senate Leadership Fund, Amended 2020 Year End Report at 72 (Mar. 18, 2021), https://docquery.fec.gov/

pdf/807/202103189441299807/202103189441299807.pdf; see also Compl. ¶¶ 49-50.

3

 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/2020

12039337569242/202012039337569242.pdf; see also Compl. ¶¶ 47-48.

4

 Wingman PAC, 2020 30-Day Post Election Report at 1, 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting a $100,000 contribution from Grow United, Inc., on 

October 27, 2020, and the committee’s FEC identification number of C00742296); Conservative Action Fund, 

Amended Statement of Organization at 1 (May 20, 2022), https://docquery.fec.gov/pdf/048/202205209512421048/

202205209512421048.pdf (reflecting that its name has changed to Conservative Action Fund and that its FEC 

identification number is C00742296); see also Compl. ¶¶ 43-44. 

MUR808200235
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 3 of 48

1 • a $20,000 contribution reportedly from Broken Promises to Concerned 

Conservatives, Inc., dated July 14, 2020;5 2 and 

3 • a $50,000 contribution reportedly from Stand Up for Justice to South Florida 

Residents First, dated March 31, 2020.6 4 

5 The Complaint relies on news articles regarding a 2019 email and two accompanying 

6 memoranda sent from Jeff Pitts, Matrix’s former CEO, to Eric Silagy, FPL’s former CEO, 

7 reportedly proposing a method for FPL to make anonymous contributions to federal and state

political committees by transferring funds through multiple levels of conduits.7 8 The proposal 

9 called for funds to be first sent to and passed through higher-level Matrix-associated conduits, 

10 including SUN Marketing & Advertising LLC (“SUN”) and Let’s Preserve the American Dream, 

11 Inc. (“LPAD”), before being sent to various lower-level Matrix-controlled conduits, including 

12 Florida Promise, that would be reported as the source of the contributions. Thus, the Complaint 

13 alleges that each of the five alleged lower-level Matrix-controlled conduits (referred to herein as 

14 the “Conduit Corporations”) permitted their names to be used to effect contributions in the name 

15 of another pursuant to Pitts’s and Matrix’s proposal. 

16 To support its central allegation, the Complaint alleges that all five of the alleged Conduit 

17 Corporations had ties to Pitts or Matrix through having either Richard Alexander or Sean J. 

Anderson as a director or officer.

8 18 Citing news articles, the Complaint alleges that Alexander’s 

5

 Concerned Conservatives, Inc., 2020 12-Day Pre-Primary Election Report at 6 (Aug. 6, 2020), https://doc

query.fec.gov/pdf/823/202008069261263823/202008069261263823.pdf; see also Compl. ¶¶ 51-52.

6

 South Florida Residents First, 2020 April Quarterly Report at 11 (Apr. 13, 2020), https://docquery.fec.gov/

pdf/294/202004159216942294/202004159216942294.pdf; see also Compl. ¶¶ 53-54.

7

 Compl. ¶¶ 3-4, 28-41; see, e.g., Jason Garcia & Annie Martin, Florida’s Dark Money Playbook: How 

‘Ghost’ Candidate Scheme Revealed Secretive Political Tactics, ORLANDO SENTINEL (Dec. 30, 2021), 

https://www.orlandosentinel.com/news/os-ne-dark-money-ghost-candidates-tactics-20211230-7zelkoadffclde3z

76ax3cgx3m-htmlstory.html [hereinafter Dark Money Playbook].

8

 Compl. ¶¶ 13, 16; see also Alexander & Anderson Resp. at 2 (Jan. 18, 2023) (conceding that Alexander 

served either as director or officer of Grow United, Florida Promise, and CAIJ, while Anderson served either as 

director or officer of Broken Promises and Stand Up for Justice). 

MUR808200236
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 4 of 48

sister was a Matrix contractor at the time of the allegations9 1 and that Anderson was a former 

Matrix employee and a good friend of Pitts.10 2 The Complaint also alleges, without providing a 

3 specific basis, that each of the five recipient IEOPCs and their treasurers accepted the 

contributions with the knowledge that they came from another source.11 4 

5 Respondents generally deny the allegations. They make a variety of factual and legal 

6 arguments, summarized as follows: 

7 • FPL’s Response states that the news articles relied on by the Complaint were from 

8 anonymous sources, that Matrix’s proposal pertained to legal activity only, and that 

9 FPL did not contribute funds to LPAD with the understanding that the funds would 

ultimately be contributed to federal IEOPCs.

12 10 FPL also provided a sworn 

11 declaration from its former CEO denying that FPL funds donated to nonprofits during 

2020 were earmarked to make federal political contributions.

13 12 

13 • Alexander and Anderson, who were collectively either a director or officer of the five 

14 alleged Conduit Corporations, state in their joint Response that the Complaint fails to 

15 present any information suggesting that they accepted any funds earmarked for 

16 making specific political contributions and argue that Matrix’s proposal did not 

address making federal political contributions.14 17 

18 • None of the five alleged Conduit Corporations, which were reported by the IEOPCs 

19 as contributors and are now defunct, submitted any response for the Commission to 

20 consider. 

21 • LPAD’s Response states that it was unaware of Matrix’s proposal and provides a 

22 sworn declaration from its executive director stating that it is vested with the sole 

9

 Compl ¶ 13; see Dark Money Playbook, supra note 7 (reporting that Alexander’s sister, April Odom, was a 

Matrix employee at the time of the allegations, and that she worked on matters relating to Grow United and CAIJ).

10 Compl ¶ 16; see John Archibald, Archibald: ‘Bachelor party’ Makes For Strange Bedfellows, AL.COM

(Nov. 14, 2010), https://www.al.com/archiblog/2010/11/archibald_bachelor_party_makes.html [hereinafter 

“Bachelor Party”] (reporting that Pitts attended Anderson’s bachelor party and that they were both employed by 

Matrix at the time); Mary Ellen Klas, et al., ‘Nightmare Scenario’: How FPL Secretly Manipulated a Florida State 

Senate Election, MIAMI HERALD (Aug. 29, 2022), https://www.miamiherald.com/news/politics-government/statepolitics/article264196761.html [hereinafter “Nightmare Scenario”] (reporting that Pitts texted FPL vice president 

Daniel Martell that Anderson was an old friend of his and that Pitts was in control of the nonprofits run by 

Anderson).

11 Compl. ¶¶ 5, 73-87.

12 FPL Resp. at 1, 4-5, 7 (Feb. 22, 2023).

13 Id., Ex. B ¶ 5 (sworn declaration of Eric E. Silagy dated February 22, 2023) [hereinafter Silagy Decl.”].

14 Alexander & Anderson Resp. at 3.

MUR808200237
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 5 of 48

1 discretion to spend the funds it receives; that it relinquishes control of any funds it 

2 donates to other organizations; and that Pitts has never contacted LPAD about a 

3 proposal to route contributions from FPL through LPAD with the intention to make 

political contributions.15 4 

5 • SUN’s Response states that it did not make any payments to a political candidate, 

campaign, or committee, or to any section 501(c)(4) entity.16 6 

7 • The five recipient IEOPCs and their treasurers state that they were unaware of 

8 Matrix’s proposal, and/or lacked information suggesting that the contributions were 

made in the name of another.17 9 

10 As discussed below, the five contributions purportedly made by the alleged Conduit 

11 Corporations as identified by the Complaint appear to be consistent with the conduit 

12 contributions proposed by Pitts and Matrix to FPL to anonymize its political contributions. In 

13 addition, all five of the alleged Conduit Corporations appear to be controlled by or associated 

14 with Pitts and Matrix. While FPL denies participating in the proposed scheme, it appears likely 

15 that Unknown Respondents, who were likely clients of Pitts and/or Matrix, funded the 

16 contributions made through the network of conduits described in the Matrix memo. 

17 Accordingly, we recommend that the Commission find reason to believe that Unknown 

18 Respondents violated 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b) by making contributions in 

19 the name of another, and reason to believe that the five alleged Conduit Corporations, Florida 

20 Promise, CAIJ, Grow United, Broken Promises, and Stand Up for Justice, violated 52 U.S.C. 

21 § 30122 and 11 C.F.R. § 110.4(b) by knowingly permitting their names to be used to effect

22 contributions in the name of another. As for the remaining Respondents, including FPL, Richard 

15 LPAD Resp. at 1-2 (Dec. 21, 2022); id., Ex. A ¶¶ 4-7, 13 (sworn declaration of Ryan Tyson dated 

December 20, 2022) [hereinafter “Tyson Decl.”]. 

16 SUN Resp. at 1 (Nov. 23, 2022).

17 See generally Concerned Conservatives Inc. Resp. at 2 (Apr. 21, 2023); Dupree Resp. at 3 (Dec. 30, 2022); 

American Valor PAC Resp. at 1-2 (Dec. 21, 2022); Conservative Action Fund Resp. at 2 (Dec. 21, 2022); South 

Florida Residents First Resp. at 1 (Nov. 18, 2022); Senate Leadership Fund Resp. at 2 (Nov. 17, 2022).

MUR808200238
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 6 of 48

1 Alexander, Sean J. Anderson, LPAD, SUN, and the five recipient IEOPCs and their treasurers, 

2 we recommend that the Commission take no action at this time, pending results of the proposed 

3 investigation. 

4 II. FACTUAL BACKGROUND

5 A. Jeff Pitts of Matrix Appears to Have Created a Plan to Anonymize Federal 

6 Political Contributions Using a Network of Conduits Controlled by or 

7 Associated with Pitts or Matrix 

Matrix is a “strategic communications firm” based in Alabama.18 8 According to the 

9 Orlando Sentinel, it received a cache of internal documents from Matrix, “includ[ing] checks, 

10 bank statements, emails, text messages, invoices, internal ledgers and more, all apparently 

11 unearthed during an internal investigation Matrix launched after its former employees left the 

firm at the end of 2020.”19 12 These internal records included a copy of a November 26, 2019 

13 email sent from former Matrix CEO, Jeff Pitts, to former FPL CEO, Eric Silagy, stating, 

14 “‘Attached is an updated funding memo along with a separate legal memo on federal elections 

support.’”20 15 The “funding memo” noted goals such as making “federal campaign contributions” 

and “‘minimiz[ing] all public reporting of entities and activities.’”21 16 It also included a flowchart

17 depicting money flowing from FPL through a network of conduits before being contributed to

federal and state political committees, as reproduced below:22 18 

18 Matrix, LLC, v. Canopy Partners, LLC, et al, 2021 WL 3127729 (Ala. Cir. Ct.).

19 Jason Garcia & Annie Martin, Operative Pitched Secretive Political Spending Plan to FPL Exec’s Email 

Alias, Records Reveal, ORLANDO SENTINEL (Jan. 24, 2022), https://www.orlandosentinel.com/politics/os-ne-floridapower-and-light-matrix-dark-money-20211217-v64274eytjeb5hnstdognvqds4-story.html [hereinafter “Secretive 

Political Spending Plan”].

20 Id.; see also Compl. ¶¶ 3, 31-38.

21 See Secretive Political Spending Plan, supra note 19; Compl. ¶ 32.

22 See Secretive Political Spending Plan, supra note 19; Compl. ¶ 33 Fig. 1.

MUR808200239
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 7 of 48

1 Notably, next to or below the name of each conduit is a parenthetical, which may indicate the 

2 person or entity controlling or associating with that conduit. Specifically, the flowchart 

3 identifies a “LPAD C4 (Tyson),” which appears to refer to LPAD and its executive director Ryan 

MUR808200240
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 8 of 48

Tyson.23 1 The flowchart also identifies “Matrix/Foley” in a parenthetical next to or below the 

2 names of the following conduits: “Broken Promises,” “Florida Promise C4,” “US Promise C4,” 

3 and “Fed Promise C4,” suggesting that these conduits are directly associated with and/or 

controlled by Matrix and its legal counsel, Foley and Lardner, LLP (“Foley”).24 4 

5 According to the flowchart, money could flow to a “Florida Promise C4,” which could 

6 “spend 50% of revenues on political activities” due to its tax status as a section 501(c)(4) 

7 corporation, and be used to contribute to Florida state political committees on the basis that 

“Florida PCs are allowed to take unlimited funds from C4s.”25 8 Money could also flow to a “US 

9 Promise C4,” which similarly could “spend 50% of revenues on political activities” due to its tax 

10 status, and be used to contribute to other states’ political committees on the basis that “[e]ach 

state operates under unique state elections.”26 11 Lastly, the flowchart indicates that money could 

12 flow to a “Fed Promise C4,” but because Matrix was “[w]aiting on lawyers,” it could not state

the purpose of this proposed funding.27 13 

14 The legal memo attached to the email, which was drafted by Foley attorney Erika Alba, 

addressed “the legalities of using nonprofits to spend money on federal elections.”28 15 The memo 

16 states that “a nonprofit might have to disclose its donors if it spent money directly supporting a 

17 candidate,” but that “the nonprofit would not have to disclose its donors if it gave money to a 

23 See LPAD Resp. at 1 (stating that it is a section 501(c)(4) organization and that its executive director is 

Ryan Tyson); see also Compl. ¶ 35.

24 See Secretive Political Spending Plan, supra note 19 (noting that Erika Alba of Foley & Lardner LLP 

drafted a legal memo attached to the email); see also Compl. ¶ 38 (alleging the same). 

25 Secretive Political Spending Plan, supra note 19; see also Compl. ¶¶ 33 Fig. 1, 37.

26 Secretive Political Spending Plan, supra note 19; see also Compl. ¶ 33 Fig. 1.

27 Secretive Political Spending Plan, supra note 19; see also Compl. ¶ 33 Fig. 1.

28 Secretive Political Spending Plan, supra note 19; see also Compl. ¶ 38.

MUR808200241
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 9 of 48

1 type of political committee known as a “‘Super PAC’” (i.e., an IEOPC) “that then spent money 

supporting the candidate.”29 2 The legal memo then concluded: “‘Thus, it could be strategic for a 

[nonprofit] who wishes to make Independent Expenditures to do so via a Super PAC.’”30 3 

4 Based on the record of contributions disclosed by the recipient IEOPCs and news articles 

5 reporting that LPAD provided funding to Grow United and Broken Promises, the Complaint 

depicts the implementation of the Matrix plan as taking the following altered form:31 6 

7 

29 Secretive Political Spending Plan, supra note 19; see also Compl. ¶ 38.

30 Secretive Political Spending Plan, supra note 19 (alteration in original); see also Compl. ¶ 38.

31 Compl. ¶¶ 42 Fig. 2, 45, 52.

MUR808200242
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 10 of 48

1 In its Response, FPL denies that it contributed funds to LPAD with the understanding 

that the funds would be contributed to federal IEOPCs,32 2 and attaches a sworn declaration from 

3 its former CEO, Silagy, denying that he directed any nonprofit organizations to make 

4 contributions to federal political committees using FPL funds during 2020, or that he otherwise 

exercised control over how any nonprofit organizations used their FPL funds that year.33 5 The 

6 Complaint, however, also alleges that Matrix pitched the above-referenced plan to Unknown 

7 Respondent clients other than FPL, noting that FPL’s spokesperson, David Reuter, stated, “‘We 

8 are aware of the proposed structure as the legal memo was shared with us, and as we understand 

9 it, Joe Perkins’[s] team at Matrix created a proposal to fund their clients’ communication and 

outreach activities during 2020.’”34 10 

11 B. The Alleged Conduit Corporations Appear to Have Been Controlled by or 

12 Associated with Pitts and/or Matrix 

13 The Complaint alleges that five alleged Conduit Corporations, Florida Promise, CAIJ, 

14 Grow United, Broken Promises, and Stand Up for Justice, permitted their names to effect the 

15 $1.27 million in contributions that they purportedly made to IEOPCs on behalf of Unknown 

Respondents.35 16 Richard Alexander served as a director or officer of the first three alleged 

Conduit Corporations, while Sean J. Anderson was a director or officer of the latter two.36 17 

18 According to news reports, both Alexander and Anderson had close ties to Matrix. 

19 Alexander’s sister, April Odom, was a Matrix contractor at the time of the allegations and 

32 FPL Resp. at 1.

33 Silagy Decl. ¶ 5. 

34 Secretive Political Spending Plan, supra note 19 (emphasis added); Compl. ¶ 40 (emphasis added). 

35 Compl. ¶¶ 5, 43-54.

36 Alexander & Anderson Resp. at 2.

MUR808200243
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 11 of 48

1 reportedly worked on behalf of Matrix regarding CAIJ and Grow United, which were entities 

associated with Alexander.

37 2 Anderson, on the other hand, was a former Matrix employee, and 

reportedly a close friend of Pitts. 38 3 Anderson also has a history of working with Pitts, as Pitts 

4 reportedly texted FPL Vice President Daniel Martell in 2016, four years prior to the alleged 

5 contributions, as follows: “‘Bottom line is we are the ones with the check books and in control 

100 percent’” of the nonprofits purportedly run by Anderson.39 6 

7 Without denying that the events as alleged in the Complaint occurred, Alexander and 

8 Anderson argue in their joint Response that the Complaint fails to include any evidence that 

9 Matrix’s plan involved making federal political contributions or that the Conduit Corporations 

10 received funds with the direction that the funds be used to make any specific political 

contribution.40 11 Alexander and Anderson also do not provide any insight as to whether the 

12 Conduit Corporations engaged in any activities other than making federal and Florida state 

13 political contributions, or explain why the Conduit Corporations made the contributions at issue 

14 here. The discussion below sets out the available information about each of the alleged Conduit 

15 Corporations and their relationships with Pitts and/or Matrix.

16 1. Florida Promise, Inc. 

17 Florida Promise is a corporation identified in Matrix’s proposal to FPL that could be used 

as a conduit to make contributions to Florida political committees,

41 18 and it was incorporated on 

37 Dark Money Playbook, supra note 7 (reporting that April Odom is Anderson’s sister and was a former 

Matrix employee); see also Compl. ¶¶ 13, 48.

38 Bachelor Party, supra note 10; Nightmare Scenario, supra note 10 (reporting that Pitts texted FPL Vice 

President Martell that Anderson was an old friend of his); see also Compl. ¶ 16.

39 Nightmare Scenario, supra note 10; see also Compl. ¶ 16. 

40 Alexander & Anderson Resp. at 3.

41 See Secretive Political Spending Plan, supra note 19; see also Compl. ¶¶ 33 Fig. 1, 50. 

MUR808200244
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 12 of 48

December 18, 2018.42 1 According to Florida Promise’s 2018 federal tax return, it is a 501(c)(4) 

2 corporation; its mission is to “develop and advocate for legislation, regulations, and government 

3 programs related to policies to benefit Floridians”; Alexander was its chairman; it did not have a 

website; and it did not have any expenses or revenue that year.43 4 

5 On December 8, 2020, Florida Promise made a $1,000,000 contribution to the Senate 

Leadership Fund.44 6 In addition, consistent with Matrix’s proposal to use Florida Promise to

7 make Florida political contributions, Florida Promise also made contributions to Florida political 

committees on June 12, 2019, and January 27, 2021, totaling $230,000.45 8 Other than making the 

9 $1,230,000 in federal and Florida state political contributions, there is no publicly available 

10 information regarding Florida Promise’s activities. 

42 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Florida Promise”); see also Compl. ¶ 12.

43 IRS Form 990-EZ, Florida Promise, Inc., 2018 Short Form Return of Organization Exempt from Income 

Tax at 2-3, 6 (Nov. 13, 2019), https://apps.irs.gov/pub/epostcard/cor/832961305_201812_990EO_202006011716

8825.pdf [hereinafter Florida Promise 2018 Tax Return]. 

44 Senate Leadership Fund, Amended 2020 Year End Report at 72 (Mar. 18, 2021), https://docquery.fec.gov/

pdf/807/202103189441299807/202103189441299807.pdf; see also Compl. ¶ 49.

45 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (searching “all” election years with contributor’s last name 

starting with “Florida Promise”); see also Compl. ¶ 50.

MUR808200245
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 13 of 48

1 2. Center for Advancement of Integrity and Justice, Inc. 

CAIJ was incorporated on October 1, 2018,46 2 and shared a mailing address with Stand Up 

for Justice.47 There are no publicly available CAIJ federal tax returns.48 3 Alexander served as 

either a director or officer of CAIJ.49 4 

On October 27, 2020, CAIJ made a $100,000 contribution to American Valor PAC,

50 5 an 

6 IEOPC that made independent expenditures during the 2020 election cycle solely in Florida’s

7 13th Congressional District, which supported Anna Paulina Luna, the Republican nominee, and 

opposed Charlie Joseph Crist, the Democratic nominee.51 8 CAIJ also made contributions to 

46 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Center for Advancement of Integrity and 

Justice”); see also Compl. ¶ 11.

47 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting that CAIJ’s address was at 2020 Pennsylvania Avenue, 

NW, Ste. 449, Washington DC 20006); CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing

(last visited Sept. 25, 2023) (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for 

Justice’s business address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006). 

48 On May 15, 2021, the IRS automatically revoked CAIJ’s 501(c)(4) status for not filing a Form 990s-series 

return for three consecutive years, suggesting that CAIJ has not filed any tax returns. See Tax Exempt Organization 

Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited July 25, 2023) (searching the organization name “center 

for advancement of integrity” which reflect that CAIJ’s federal tax exempt status was automatically revoked on May 

15, 2021for not filing a Form 990-series return or notice for three consecutive years).

49 Alexander & Anderson Resp. at 2 (stating that Alexander was associated with CAIJ in either a director or 

officer capacity).

50 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf; see also Compl. ¶ 47. 

51 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00757179&is_notice=false&most_recent=true (last visited 

Aug. 18, 2023) (reflecting independent expenditures made by American Valor PAC); November 3, 2020 General 

Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=

11/3/2020&DATAMODE= (last visited Sept. 25, 2023) (selecting “Federal Offices”) (reflecting that Anna Luna 

was the Republican nominee and that Charlie Crist was the Democratic nominee in Florida’s 13th Congressional 

District).

MUR808200246
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 14 of 48

1 Florida political committees totaling $307,000, starting in November 2018 and through 

December 2020.

52 2 

3 While CAIJ was not referenced by name in Matrix’s proposal to FPL, news reports 

4 suggest that it was controlled by Matrix. Specifically, Matrix’s internal files reportedly include a 

5 September 23, 2020 text message from Odom, Alexander’s sister and a Matrix contractor at the 

time of the allegations, stating that she procured access to CAIJ’s bank account.53 6 In addition, 

7 on October 16, 2018, just 15 days after CAIJ’s incorporation, CAIJ made a $25,000 contribution 

to House Majority PAC.54 8 According to news reports, FPL directed Matrix to make this 

9 contribution on its behalf to support Lauren Baer, who was seeking election in Florida’s 18th 

10 Congressional District, and asked Matrix to ensure that House Majority PAC “‘do[es]n’t 

triangulate this donation to others we have done.’”55 11 Other than making the $432,000 in federal 

12 and Florida state political contributions, there is no publicly available information regarding 

13 CAIJ’s activities. 

52 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited July 25, 2023) (searching “all” election years with contributor’s last name starting 

with “center for advancement”).

53 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right-hand corner 

of the article’s sixth picture); see also Compl. ¶ 48.

54 House Majority PAC, 2018 Amended 12-Day Pre-Election Report at 655 (Dec. 3, 2018), https://docquery

.fec.gov/pdf/085/201812069135107085/201812069135107085.pdf. 

55 Jason Garcia & Annie Martin, Florida Power & Light Execs Worked Closely with Consultants Behind 

‘Ghost’ Candidate Scheme, Records Reveal, ORLANDO SENTINEL (Apr. 14, 2022), https://www.orlandosentinel.com/

politics/os-ne-florida-power-and-light-senate-ghost-candidates-20211202-szjhv7ox6vcmphm6pgd437y52i-htmlstory

.html [hereinafter “FPL Execs”] (reporting that Silagy forwarded Pitts instructions to make a contribution to House 

Majority PAC to support Lauren Baer and to make sure that “they don’t triangulate this donation to others we have 

done”); November 6, 2018 General Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.my

florida.com/Index.asp?ElectionDate=11/6/2018&DATAMODE= (last visited Sept. 25, 2023) (reflecting that Lauren 

Baer was the democratic nominee in Florida’s 18th Congressional District). 

MUR808200247
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 15 of 48

1 3. Grow United, Inc. 

Grow United was incorporated on July 24, 2019.56 2 There are no publicly available Grow 

3 United federal tax records and it did not identify itself as a nonprofit organization to the Internal 

Revenue Service.

57 Alexander served either as a director or officer of Grow United.58 4 

On October 27, 2020, Grow United made a $100,000 contribution to Wingman PAC,59 5 

now known as the Conservative Action Fund.60 6 Wingman PAC made independent expenditures 

7 during the 2020 election cycle solely in Florida’s 15th Congressional District, which supported 

8 Scott Franklin, the Republican nominee; opposed Alan Michael Cohn, the Democratic nominee; 

9 and opposed Vincent Spano Ross, who competed against Franklin for the Republican 

56 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Grow United”). 

57 See Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited Sept. 25, 2023)

(reflecting that there are no results when searching Grow United’s name or its EIN number identified in the 

Complaint, 84-2546999). 

58 Alexander & Anderson Resp. at 2 (conceding that Alexander was associated with Grow United in either a 

director or officer capacity). 

59 Wingman PAC, 2020 30-Day Post Election Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/423/

202012039338666423/202012039338666423.pdf (reflecting a $100,000 contribution from Grow United on October 

27, 2020).

60 Id. at 1 (reflecting an FEC identification number of C00742296); Conservative Action Fund, Amended 

Statement of Organization at 1 (May 20, 2022), https://docquery.fec.gov/pdf/048/202205209512421048/2022

05209512421048.pdf (reflecting that its name has changed to Conservative Action Fund and its FEC identification 

number is C00742296). 

MUR808200248
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 16 of 48

nomination.61 1 Earlier that month, from October 3, 2020, through October 20, 2020, Grow 

United made contributions to Florida state political committees totaling $1,462,500.62 2 

3 Grow United appears to have been created and controlled by Pitts and Matrix. Ryan 

4 Tyson, the executive director of LPAD — which contributed $1,150,000 to Grow United in 

202063 5 — was deposed by the Miami-Dade State Attorney’s Office in a criminal matter 

6 regarding a former LPAD contractor’s creation of fake Florida state senate candidates during the 

2020 election cycle.64 7 Tyson testified in the deposition that he understood that Jeff Pitts started 

and ran Grow United.65 8 In addition, FPL reportedly asserted that Grow United was created by 

Matrix.66 9 

61 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00742296&is_notice=false&min_date=01%2F01%2F2019&max

_date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting Wingman PAC’s independent expenditures in the 

2020 election cycle); November 3, 2020 General Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results

.elections.myflorida.com/Index.asp?ElectionDate=11/3/2020&DATAMODE= (last visited Sept. 25, 2023) 

(selecting “Federal Offices”) (reflecting that Scott Franklin was the Republican nominee and Alan Cohn was the 

Democratic nominee in Florida’s 15th Congressional District); August 18, 2020 Primary Election Republican 

Primary, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate

=8/18/2020&DATAMODE= (last visited Sept. 25, 2023) (selecting “Federal Offices” in the Republican Primary 

section) (reflecting that both Scott Franklin and Ross Spano were seeking the Republican nomination in Florida’s 

15th Congressional District).

62 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (selecting election year “all” and searching contributor last name 

starting with “grow united”); see also Compl. ¶ 46.

63 LPAD Resp. at 3; see also Compl. ¶ 45.

64 See FPL Resp., Ex. A (deposition of Ryan Tyson conducted by the Miami-Dade State Attorney’s Office on 

September 30, 2021) [hereinafter “Tyson Dep.”]. 

65 Tyson Dep. at 16:18-23 (Tyson testifying that Pitts told him that he was starting Grow United), id. at 18:4-9 

(Tyson testifying that his understanding was that Pitts “was running Grow United”).

66 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Dec. 10, 2021, updated Sept. 2, 

2022), https://www.jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-citycouncil-member-mysterious-job-offer-dark-money-group-nate-monroe/8850689002/. Joe Perkins, owner of Matrix, 

denies that Matrix created Grow United, and Perkins’s attorney asserts that “[t]o the extent any rogue Matrix 

employees were involved in those activities, they were undertaken in secret, without Dr. Perkins’[s] knowledge or 

consent.” Id.

MUR808200249
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 17 of 48

1 Matrix’s internal records also reportedly indicate that it had control of Grow United. 

2 According to news reports, Matrix’s internal ledger reflect an August 7, 2019 entry billed to FPL 

3 for “‘Grow United SOS Fees,’” which likely referred to the fees charged by the Delaware 

Secretary of State for incorporating Grow United a few weeks prior.

67 4 Matrix’s internal records 

5 also reportedly include a September 23, 2020 message from Odom stating that she procured 

access to Grow United’s bank account.68 6 In addition, as part of her duties at Matrix, Odom 

7 reportedly sent checks from Grow United to make contributions to Florida committees, asked the 

committees to confirm their receipt of the checks,69 8 and emailed a $12,813.54 invoice to Matrix

9 with the subject line, “FPL Expenses for Grow United c4,” for expenses that included traveling 

to Colorado to update the nonprofit’s mailbox at a UPS Store in Denver.70 10 

11 News articles also report that, in the summer of 2019, Matrix used Grow United to offer a 

job to a Jacksonville City Councilmember on behalf of FPL.71 12 Furthermore, Foley attorney 

13 Erika Alba reportedly billed Matrix in the fall of 2020 for her work on IRS submission forms for 

Grow United.72 14 Other than making the $1,562,500 in political contributions, there is no publicly 

15 available information regarding Grow United’s activities.

67 FPL Execs, supra note 55. 

68 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right corner of the 

article’s sixth picture); see also Compl. ¶ 48.

69 Dark Money Playbook, supra note 7. 

70 FPL Execs, supra note 55. 

71 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/. FPL reportedly confirmed that Matrix 

employees came up with an idea to offer the City Council member a job, but that it rejected the idea. Id. 

72 Nate Monroe, Law Firm that Advised on Botched JEA Sale Also Helped Former FPL Consultants On 

Dark-Money Projects, FL TIMES-UNION (Dec. 17, 2021), https://www.jacksonville.com/story/news/columns/natemonroe/2021/12/17/jea-privatization-law-firm-foley-lardner-also-helped-former-fpl-consultants-political-giving/

8850686002/. There are no publicly available tax forms from Grow United, Inc., however. See Tax Exempt 

MUR808200250
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 18 of 48

1 4. Broken Promises 

2 Broken Promises is referenced by name in Matrix’s proposal to FPL as a middleman that 

3 would receive funds and send them to conduits, including Florida Promise, that would in turn 

make political contributions.73 4 Broken Promises was incorporated on August 29, 2018, along 

with Stand Up for Justice.74 5 According to Broken Promises’s federal tax return for the 2018 

6 calendar year, it is a 501(c)(4) corporation; its purpose is to “develop[] and advocat[e] for 

7 legislation, regulations, and government programs to improve social environmental, economy 

8 and social environment”; Sean J. Anderson is its president and chairman; it did not have a 

website; and it received $200,000 of funding that year.75 9 In addition, according to news reports, 

Broken Promises reportedly received $26,000 from LPAD on July 9, 2020.76 10 

11 On July 14, 2020, five days after reportedly receiving the $26,000 from LPAD, Broken 

Promises made a $20,000 contribution to Concerned Conservatives, Inc., an IEOPC.77 12 During 

13 the 2020 election cycle, Concerned Conservatives, Inc., made independent expenditures only in 

14 Florida’s 19th Congressional District to support Dane Eagle, who unsuccessfully ran for the 

15 Republican nomination, and oppose his competitors, William Matthew Figlesthaler, Byron 

Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited Sept. 25, 2023) (reflecting that there are no 

results when searching Grow United’s name or its EIN number identified in the Complaint, 84-2546999).

73 See Secretive Political Spending Plan, supra note 19; Compl. ¶¶ 33 Fig. 1, 52. 

74 CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023) 

(searching the organization name “Broken Promises” and “Stand Up for Justice”).

75 See IRS Form 990, Broken Promises, 2018 Return of Organization Exempt from Income Tax at 1, 7 

(Nov. 15, 2019), https://apps.irs.gov/pub/epostcard/cor/831745117_201812_990O_2020012317057600.pdf

[hereinafter Broken Promises 2018 Tax Return] (reflecting an unfilled line for the organization’s website).

76 Jeff Weiner & Annie Martin, Bank Records Shed Light on Dark-Money Group in ‘Ghost’ Candidate 

Scandal, ORLANDO SENTINEL (Apr. 18, 2022), https://www.orlandosentinel.com/2022/04/18/bank-records-shedlight-on-dark-money-group-in-ghost-candidate-scandal/; see also LPAD Resp. at 3 (conceding it donated $26,000 to 

Broken Promises in 2020); Compl. ¶ 52.

77 Concerned Conservatives, Inc., 2020 12-Day Pre-Primary Election Report at 6 (Aug. 6, 2020), 

https://docquery.fec.gov/pdf/823/202008069261263823/202008069261263823.pdf; see also Compl. ¶ 51.

MUR808200251
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 19 of 48

Donalds, and Casey Askar.78 1 In addition, in 2018, Broken Promises made $160,470 in Florida 

2 state political contributions, and in 2019, it made $21,500 in Florida state political 

contributions.79 3 Thus, it appears that Broken Promises made at least $201,970 in political 

4 contributions during its existence. 

5 According to Broken Promises’s federal tax returns and LPAD’s Response, it received a 

total of $226,000 to $300,000 in funding during its existence: $200,000 in 2018,80 6 $50,000 or 

less in 2019, and $26,000 to $50,000 in 2020 before terminating later that year.

81 7 Broken 

8 Promises’s 2018 federal tax return also indicates that it spent $500 on legal expenses and $40 on 

management and general expenses that year.82 9 Although Broken Promises characterized 

10 spending $45,000 on lobbying and $115,470 on “other” program expenses in its 2018 federal tax 

11 return, this sum of $160,470 corresponds precisely to the dollar with its 2018 Florida state 

political contributions also totaling $160,470.83 12 Thus, Broken Promises spent at least 67% to 

13 89% of its total funding on making political contributions.

78 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data type=processed&q spender=C00728402&is notice=false&min date=01%2F01%2F2019&max

date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting Concerned Conservatives, Inc.’s, independent 

expenditures during the 2020 election cycle); August 18, 2020 Primary Election Republican Primary, FL DEP’T OF 

STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=8/18/2020&DATA

MODE= (last visited Sept. 25, 2023) (selecting “Federal Offices” in the Republican Primary section) (reflecting that 

Dane Eagle, William Figlesthaler, Byron Donalds, and Casey Askgar were seeking the Republican nomination in 

Florida’s 19th Congressional District).

79 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and contributor last name “Broken 

Promises”).

80 Broken Promises 2018 Tax Return at 1, supra note 75. 

81 LPAD Resp. at 3 (conceding it donated $26,000 to Broken Promises in 2020). For 2019 and 2020, Broken 

Promises filed an IRS Form 990-N, indicating that its gross receipts were $50,000 or less in those years. Tax 

Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited Sept. 25, 2023) (searching 

organization name “Broken Promises”). 

82 Broken Promises 2018 Tax Return at 10, supra note 75. 

83 Id.; see also Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/

campaign-finance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and contributor last name 

MUR808200252
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 20 of 48

1 According to the Miami Herald, Broken Promises’s entire $200,000 of funding in 2018 

was from FPL.84 2 Specifically, the Miami Herald claims it received an internal Matrix ledger 

3 showing how, in 2018, Matrix distributed $200,000 of funds labeled as coming from FPL to 

Broken Promises.85 4 The ledger reportedly shows that Matrix sent $100,000 of FPL funds to 

Broken Promises on September 26, 2018, and again on October 16, 2018, totaling $200,000.86 5 

6 This money was likely transmitted through other Matrix-controlled corporations before coming 

7 to Broken Promises, because federal tax records show that the Alliance for Consumer Protection 

Inc., donated $100,000 to Broken Promises in 2018.87 8 According to a news report regarding a 

9 text message between Pitts and FPL Vice President Martell, the director of the Alliance for 

Consumer Protection Inc., David Calvert, is Pitts’s former college roommate.

88 10 

“Broken Promises”) (reflecting that Broken Promises made $160,470 in Florida state political contributions in 2018, 

of which $45,000 were cash contributions and $115,470 were in-kind contributions in the forms of direct mail and 

advertising).

84 Nicholas Nehamas & Mary Ellen Klas, DeSantis ’18 Campaign Got $25,000 From Nonprofit Secretly 

Funded by FPL Cash, Records Show, MIAMI HERALD (Sept. 9, 2022), https://www.miamiherald.com/news/politicsgovernment/state-politics/article265213541.html. 

85 Id. FPL spokesperson Reuter called the ledger “fake” and stated, “We have no record of FPL, or any 

NextEra Energy entity for that matter, ever having paid Broken Promises.” Id

86 Nightmare Scenario, supra note 10; see also Nicholas Nehamas & Mary Ellen Klas, DeSantis ’18 

Campaign Got $25,000 From Nonprofit Secretly Funded by FPL Cash, Records Show, MIAMI HERALD (Sept. 9, 

2022), https://www.miamiherald.com/news/politics-government/state-politics/article265213541.html. 

87 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095_201812_990O_20211020

19109756.pdf. 

88 Nightmare Scenario, supra note 10. 

MUR808200253
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 21 of 48

1 5. Stand Up for Justice 

As discussed above, Stand Up for Justice was incorporated on August 29, 2018,89 2 the 

same day as Broken Promises, and it shared a mailing address with CAIJ.

90 3 According to its 

4 2018 federal tax return, Stand Up for Justice is a 501(c)(4) corporation; its purpose is to 

5 “develop[] and advocat[e] for legistlation [sic], regulations and government programs to improve 

6 social environment, economy & society”; Anderson was a director and its president; it did not 

have a website; and it received $350,000 in funding that year.91 7 

8 On March 31, 2020, Stand Up for Justice made a $50,000 contribution to South Florida 

Residents First,

92 9 an IEOPC that made independent expenditures during the 2020 election cycle 

10 only in Florida’s 26th Congressional District, which supported Republican nominee Carlos 

Gimenez and opposed Democratic nominee Debbie Mucarsel-Powell.93 11 In addition, just two 

12 months after it was incorporated, Stand Up for Justice made contributions to a Florida political 

89 CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023) 

(searching the organization names “Stand Up for Justice” and “Broken Promises”). 

90 Id. (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for Justice’s business 

address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006); American Valor PAC, 2020 

Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/202012039337569242/20201203

9337569242.pdf (reflecting that CAIJ’s address is at 2020 Pennsylvania Avenue, NW, Ste. 449, Washington DC 

20006). 

91 IRS Form 990, Stand Up for Justice, 2018 Return of Organization Exempt from Income Tax at 1-2, 7 

(Nov. 15, 2019), https://apps.irs.gov/pub/epostcard/cor/831749759_201812_990O_2020021317141891.pdf

[hereinafter Stand Up for Justice 2018 Tax Return]. 

92 South Florida Residents First, 2020 April Quarterly Report at 11 (April 13, 2020), https://docquery.fec

.gov/pdf/294/202004159216942294/202004159216942294.pdf; see also Compl. ¶ 53.

93 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00733402&is_notice=false&min_date=01%2F01%2F2019&max

_date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting South Florida Residents First’s independent 

expenditures in the 2020 election cycle); November 3, 2020 General Election, FL DEP’T OF STATE DIV. OF 

ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=11/3/2020&DATAMODE= (last visited 

Sept. 25, 2023) (selecting “Federal Offices”) (reflecting that Carlos Gimenez was the Republican nominee and 

Debbie Mucarsel-Powell was the Democratic nominee in Florida’s 26th Congressional District); see Compl. ¶ 53. 

MUR808200254
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 22 of 48

committee in October 2018, totaling $300,000,94 1 which Stand Up for Justice characterized as 

“lobbying” on its 2018 federal tax return.95 2 Thus, it appears that Stand Up for Justice made at 

3 least $350,000 in political contributions during its existence. 

4 According to Stand Up for Justice’s federal tax returns, it received $350,000 to $450,000 

during its existence: $350,000 in 2018,96 5 and $50,000 or less per year in each of 2019 and 2020 

before terminating.97 6 Stand Up for Justice’s federal tax returns also state that it spent $20,577 on 

legal fees and $100 on bank service charges in 2018,98 7 indicating that its total funding was at 

8 least $370,677 to cover its lifetime spending. Thus, Stand Up for Justice spent at least 78% to 

9 94% of its total funding on making political contributions.

10 Federal tax records show that Alliance for Consumer Protection Inc., contributed 

$150,000 to Stand Up for Justice in 2018.99 11 As indicated above, the Alliance for Consumer 

12 Protection Inc. also contributed $100,000 to Broken Promises in 2018, and its executive director 

is reportedly Pitts’s former college roommate.

100 13 

94 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited July 25, 2023) (searching election year “all” and contributor last name starting 

with “Stand Up for Justice”).

95 Stand Up for Justice 2018 Tax Return at 10, supra note 91. 

96 Id. at 1.

97 For 2019 and 2020, Stand Up for Justice filed an IRS Form 990-N, and indicated that its gross receipts 

were not greater than $50,000 in those years. Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/

eos/ (last visited Sept. 25, 2023) (searching organization name “Stand Up for Justice”).

98 Stand Up for Justice 2018 Tax Return at 10, supra note 91. 

99 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095_201812_990O_20211020

19109756.pdf. 

100 Id.; Nightmare Scenario, supra note 10. 

MUR808200255
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 23 of 48

1 C. Let’s Preserve the American Dream, Inc., was Associated with Pitts and 

2 Matrix

3 Relying on news reports of Matrix’s proposal to FPL, which reference LPAD as a higher4 level Matrix-associated conduit that would receive funds and transmit them to other entities in 

5 Matrix’s network, and news reports indicating that LPAD made donations to Grow United and 

6 Broken Promises, the Complaint alleges that Unknown Respondents used LPAD as a middleman 

to make contributions using the names of Grow United and Broken Promises.101 7 While LPAD 

8 admits that, in 2020, it donated $1.15 million to Grow United and $26,000 to Broken 

Promises,102 9 it denies having knowledge or involvement in Pitts’s and Matrix’s proposed plan to 

make conduit contributions.103 10 LPAD also states in its Response that “LPAD exercises total 

11 discretion over how to spend the funds it receives” and that “LPAD never conferred with any of 

12 the Respondents named in the Complaint concerning how it should spend or donate its funds, nor 

did it otherwise seek their input when making those decisions.”104 13 LPAD’s executive director, 

14 Ryan Tyson, similarly declared, “Neither Mr. Pitts nor any other individual has ever suggested to 

me that LPAD should contribute to a particular cause or political candidate.”105 15 

16 However, in a deposition conducted by the Miami-Dade State Attorney’s Office 

17 regarding a former LPAD contractor’s creation of fake Florida state senate candidates, Tyson 

18 stated that he discussed LPAD’s donation to Grow United with Matrix’s former CEO, Jeff Pitts, 

101 Compl. ¶¶ 33 Fig. 1, 35, 37, 42 Fig. 2, 45, 52; see also Secretive Political Spending Plan, supra note 19. 

102 LPAD Resp. at 3. 

103 Id. at 1-2; see also Tyson Decl. ¶¶ 10-11, 13-14. 

104 LPAD Resp. at 1. 

105 Tyson Decl. ¶ 14.

MUR808200256
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 24 of 48

and that it was actually Pitts who proposed for LPAD to make that donation.106 1 Specifically, 

2 Tyson testified: 

3 Well, as best as I can recall, I called [Pitts] up and I said, “Do you 

4 have any social welfare groups that are interested in working on 

5 issues that are amenable to my organizational narrative? Are they 

6 interested in supporting other interests in other committees around 

7 the country, in Florida specifically too, that would focus purely on 

the center left spectrum and on issues that are center left?”107 8 

9 According to Tyson, Pitts “said he did,” referring to Grow United, and so Tyson “said we’d be 

happy to support them.”108 10 

11 In addition, LPAD states in its Response that when it makes a donation to another 

12 organization, including when it made the donations to Grow United and Broken Promises, it

13 signs an assurance letter stating that the recipient is vested with the sole discretion as to the use 

of the donation.109 14 Tyson further declared, “LPAD has no further discussions with the recipient 

15 concerning the disposition or use of any of the funds LPAD has donated to other 501(c)(4) 

nonprofit organizations or political committees.”110 16 However, in the same above-referenced 

17 deposition, Tyson testified that in fact he spoke with Pitts about how Grow United should use 

LPAD’s donation.111 18 Specifically, in response to whether Tyson knew that Alex Alvarado’s 

19 Florida state political committees received their funding from Grow United, Tyson stated, “I told 

20 you earlier I knew it came from Grow United. There was a story about it. And I knew, I 

106 See Tyson Dep. at 16:18-17:14.

107 Id. at 17:10-14 (in response to the question,“So give me your best recollection of the content of the 

conversation that you had with Jeff Pitts that caused you to want to send the money to Grow United.”).

108 Id. at 17:14.

109 LPAD Resp. at 4; see also Tyson Decl. ¶ 7 (stating that LPAD signs an assurance letter relinquishing 

control over its funds when it donates them). 

110 Tyson Decl. ¶ 8.

111 Tyson Dep. at 25:8-17. 

MUR808200257
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 25 of 48

actually told Grow United that Alvarado would probably call them and ask, raise money.”112 1 

Tyson further explained that the person he spoke with was Jeff Pitts.113 2 According to text 

3 messages obtained by the Orlando Sentinel, on September 24, 2020, just five days prior to LPAD 

4 making its first $600,000 donation to Grow United on September 29, 2020, Tyson communicated 

5 with Pitts and Abigail MacIver, another former Matrix employee, regarding the Florida state 

senate races that the Alvarado committees were seeking to impact.114 6 

7 When further queried as to whether Tyson “did not authorize the money, the $600,000 

8 [from LPAD], to go to Grow United so they can then turn around and send it to Alex Alvarado’s 

9 two political campaigns,” Tyson testified that he “can’t tell [Grow United] how to spend their 

money” and that he “do[es]n’t have the ability to restrain how they spend their funds.”115 10 

11 However, when asked, “Did you know when this $600,000 [from LPAD] was sent to Grow 

12 United, that it was going to [⸺] that 550,000 of it was going to go to Alex Alvarado’s two 

13 political committees,” Tyson testified that he “had a hunch” that Grow United would be 

supportive of the Alvarado committees and that he was “not testifying it’s a coincidence.”116 14 

15 Tyson further stated, “I knew [Grow United] would likely be supportive, but I also didn’t know 

16 when, I mean, we made other contributions to them as well. We were supporting a lot of what 

they were doing.”117 17 Tyson then testified that he “assume[d] [Grow United would] probably be 

112 Id. at 25:5-10 (emphasis added); see also id. at 27:21-24 (Tyson testifying that he assumed that Alvarado 

would call Grow United for funding when asked again whether he knew about the source of the Alvarado

committees’ funding).

113 Id. at 25:11-12.

114 FPL Execs, supra note 55; Tyson Dep., Ex. A (reflecting that Grow United received a $600,000 donation 

from LPAD on September 29, 2020).

115 Tyson Dep. at 29:19-23.

116 Id. at 29:24-30:05. 

117 Id. at 30:05-:07.

MUR808200258
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 26 of 48

1 supported [sic] if Alex called, but I had no way to know if they actually would. Because once I 

make a contribution to an entity, I lose control of how they spend that money.”118 2 

3 D. SUN Marketing & Advertising LLC Appears to be Associated with Matrix

4 SUN Marketing & Advertising LLC is another conduit identified in Matrix’s proposal to 

FPL,

119 and it appears to have been created by Matrix after the memo was circulated.120 5 

6 Specifically, SUN was formed on December 13, 2019, about two weeks after Pitts reportedly 

emailed the above-referenced proposal to Silagy on November 26, 2019.121 7 However, despite 

8 the proposal’s flowchart depicting that money would flow from FPL to SUN before passing 

through a network of corporations controlled by Matrix,122 9 SUN states in its Response that it did 

10 not make any payments or contributions to any 501(c)(4) entity, or to any political candidate, 

11 campaign, or committee, and that it only provided marketing and communications consulting 

services.123 12 FPL spokesman Reuter reportedly confirmed that FPL gave $250,000 to SUN in 

13 December 2019, but stated that the purpose was to purchase advertising related to a proposed 

constitutional amendment that FPL opposed.124 14 According to Reuter, FPL believes that SUN is 

118 Id. at 31:15-20 (Tyson answering in response to a question asking if he “kn[e]w with certainty” that Grow 

United would send funds to Alvarado). 

119 Secretive Political Spending Plan, supra note 19; see also Compl. ¶ 32 Fig. 1.

120 SUN Resp. at 1.

121 Id.; Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “SUN Marketing & Advertising”).

122 Compl. ¶ 32 Fig. 1.

123 SUN Resp. at 1.

124 Secretive Political Spending Plan, supra note 19. 

MUR808200259
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 27 of 48

owned by Matrix.125 1 News reports indicate that SUN was used to create favorable press for 

FPL.126 SUN’s former sole member, Tim Fitzpatrick, was a former FPL officer.127 2 

3 E. The Complaint Alleges that the Recipient IEOPCs Were Aware of the 

4 Alleged Conduit Scheme and Knowingly Accepted Contributions Made in 

5 the Name of Another 

6 The Complaint also alleges, without providing a specific basis, that each of the five 

7 recipient IEOPCs and their treasurers accepted the contributions with the knowledge that they 

were made in the name of another.128 8 

The five recipient IEOPCs and their treasurers deny the allegations.129 9 According to 

10 Dupree, who was the treasurer of Wingman PAC at the time of the allegations, while she was 

11 made aware that Wingman PAC received a contribution via wire transfer from Grow United, she 

found “nothing unusual about th[e] transaction.”130 12 Senate Leadership Fund similarly stated that, 

13 while one of its representatives spoke with a Florida Promise representative who completed a 

14 donor form, its own “representatives had no reason to think that the donation was from anyone 

other than Florida Promise.”131 15 

125 Id.

126 Sarah Blaskey, Powerbrokers: How FPL Secretly Took Over a Florida News Site and Used It to Bash 

Critics, MIAMI HERALD (Aug. 13, 2022), https://www.miamiherald.com/article263757423.html. 

127 SUN Resp. at 1; PG&E Names Tim Fitzpatrick As Vice President And Chief Communications Officer, 

CISION PR NEWSWIRE (Mar. 11, 2013), https://www.prnewswire.com/news-releases/pge-names-tim-fitzpatrick-asvice-president-and-chief-communications-officer-197098061.html (“Fitzpatrick joined NextEra Energy in January 

2008, serving as Vice President of Marketing and Corporate Communications and as an officer of Florida Power & 

Light Company (FPL).”).

128 Compl. ¶¶ 5, 73-87.

129 See generally Concerned Conservatives Inc. Resp.; Dupree Resp.; American Valor PAC Resp.; 

Conservative Action Fund Resp.; South Florida Residents First Resp.; Senate Leadership Fund Resp.

130 Dupree Resp. at 2-3. 

131 Senate Leadership Fund Resp. at 2.

MUR808200260
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 28 of 48

1 III. LEGAL ANALYSIS

2 A. The Commission Should Find Reason to Believe that the 2020 Contributions 

3 Reported as Having Been Made By the Alleged Conduit Corporations Were 

4 Contributions Made In the Name of Another

5 The Act and the Commission’s regulations prohibit a person from (1) making a 

6 contribution in the name of another person, (2) knowingly permitting his or her name to be used 

to effect such a contribution, and (3) knowingly accepting such a contribution.132 7 The term 

8 “person” in this context includes partnerships, corporations, and “any other organization or group 

of persons.”133 9 In its regulations, the Commission has illustrated examples of activities that 

10 constitute making a contribution in the name of another, as follows: 

11 (i) Giving money or anything of value, all or part of which was 

12 provided to the contributor by another person (the true contributor) 

13 without disclosing the source of money or the thing of value to the 

14 recipient candidate or committee at the time the contribution is 

15 made; or

16 (ii) Making a contribution of money or anything of value and 

17 attributing as the source of the money or thing of value another 

person when in fact the contributor is the source.134 18 

19 Because a primary purpose of the Act’s disclosure provisions is to reveal the true source from 

20 which a contribution to a candidate or committee originates, regardless of the mechanism by 

which the funds are transmitted,135 21 the Commission examines the structure of the transaction 

132 52 U.S.C. § 30122; see also 11 C.F.R. § 110.4(b).

133 52 U.S.C. § 30101(11); 11 C.F.R. § 100.10.

134 11 C.F.R. § 110.4(b)(2)(i)-(ii).

135 See Campaign Legal Ctr. v. FEC, 952 F.3d 352, 354 (D.C. Cir. 2020) (“As the Supreme Court has 

repeatedly declared, the electorate has an interest in knowing where political campaign money comes from and how 

it is spent by the candidate. To that end, the [Act] imposes disclosure requirements on those who give and spend 

money to influence elections. The straw donor provision, 52 U.S.C. § 30122, is designed to ensure accurate 

disclosure of contributor information.”) (internal citations and quotation marks omitted). 

MUR808200261
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 29 of 48

1 itself and the arrangement between the parties to determine who in fact “made” a given 

contribution.136 2 

3 In prior matters, the Commission has found reason to believe that a contribution was 

4 made in the name of another where the available information indicates that another person 

5 provided the funds for the purpose of making the contribution and his or her identity was not 

disclosed to the recipient committee or candidate at the time of the contribution.

137 6 Absent direct 

7 evidence as to the purpose of providing the funds, the Commission considers the overall record

8 to determine its purpose. In the context of contributions made by limited liability companies 

9 (“LLCs”), the Commission has addressed whether the LLC “had the means to make the 

10 contribution absent an infusion of funds provided for that purpose,” the “temporal proximity

11 between the LLC’s formation date and the contribution,” “the amount of the contribution relative 

12 to [the LLC’s] other activities, the LLC’s known activities prior to making the contribution, and 

13 whether any other information suggests an attempt to circumvent the Act’s disclosure 

requirements.”139 14 

136 Cf. 11 C.F.R. § 110.6(a) (“All contributions by a person made on behalf of or to a candidate, including 

contributions which are in any way earmarked or otherwise directed to the candidate through an intermediary or 

conduit, are contributions from the person to the candidate.”).

137 See, e.g., Factual and Legal Analysis (“F&LA”) at 5, MUR 7903 (Tomfoolery, LLC, et al.) (“[T]he 

contributions made in Tomfoolery’s name were, in fact, actually made by Thomas A. Chavez, when Chavez 

furnished Tomfoolery with funds for the purpose of having the LLC make the contributions.”); F&LA at 1-2, 

MUR 6920 (American Conservative Union) (finding reason to believe that the contribution was made in the name of 

another where the organization who was reported as the contributor later indicated that it was not the true source of 

the contribution, and instead merely delivered the contribution upon receipt of the funds from another person); see 

also 11 C.F.R. § 110.4(b)(2)(i)-(ii).

139 Id.; see also F&LA at 11, MUR 7464 (LZP, LLC) (explaining that the two days between the LLC’s 

formation and its contribution, in conjunction with the absence of any public information regarding the LLC’s 

activities other than making the contribution, indicated that funds were provided to the LLC for the purpose of 

making a contribution). The Commission ultimately split 3-3 in its votes to find probable cause and to dismiss the 

allegations that the LLC in MUR 7464 made a contribution in the name of another. Certification (“Cert.”) ¶¶ 1-2 

(Apr. 6, 2023), MUR 7464 (LZP, LLC, et al.). 

MUR808200262
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 30 of 48

1 Here, the available information indicates that the five 2020 political contributions 

2 purportedly made by the alleged Conduit Corporations — Florida Promise, Broken Promises, 

3 Grow United, CAIJ, and Stand Up for Justice — were actually made on behalf of Unknown 

4 Respondents. The overall record indicates that there was plan whose purpose was “to 

5 circumvent the Act’s disclosure requirements” by using the names of the Conduit Corporations 

6 to make contributions and that this plan was implemented in largely the way the blueprint set 

7 out. In addition, the overall record of the Conduit Corporations’ known activities indicate that 

8 they may have been formed for the purpose of making conduit contributions.

9 Specifically, news articles indicate that, during the 2020 election cycle, Matrix invited 

10 FPL to anonymize its political activities by funneling money through several layers of conduits, 

11 including Florida Promise and Broken Promises, and then using those funds to make federal and 

state political contributions.

142 12 The articles report that Jeff Pitts, former CEO of Matrix, emailed

13 Eric Silagy, former CEO of FPL, a “‘funding memo’” with goals such as making “federal 

14 campaign contributions” and “‘minimiz[ing] all public reporting of entities and activities,’” and a 

“‘legal memo on federal elections support.’”143 15 According to the Orlando Sentinel, the funding 

16 memo included a flowchart depicting FPL’s funds flowing through several layers of conduits 

17 controlled by Pitts and Matrix, including Florida Promise and Broken Promises, before being 

contributed to federal and state political committees.144 18 While the specific plan reported by the 

19 news articles did not directly identify CAIJ, Grow United, or Stand Up for Justice, the proposal 

 

 

142 Secretive Political Spending Plan, supra note 19; see also Compl. ¶¶ 3, 31-38. 

143 Secretive Political Spending Plan, supra note 19; see also Compl. ¶¶ 3, 31-32. 

144 Secretive Political Spending Plan, supra note 19; see also Compl. ¶ 33 Fig. 1.

MUR808200263
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 31 of 48

1 establishes the preexisting idea of making conduit contributions with entities just like these, 

2 which as discussed below, was ultimately carried out using the five alleged Conduit 

3 Corporations. 

4 Although FPL argues that Matrix’s proposal was limited to activity “‘where laws 

allow,’”145 5 it does not deny that Matrix shared with it such a proposal to make anonymous 

6 conduit contributions as reported in the news articles. Similarly, while Alexander and Anderson 

7 contend that Pitts’s and Matrix’s proposal did not include making federal political contributions, 

8 and that the Complaint lacks evidence that they, or the Conduit Corporations, received funds 

9 with the explicit request or suggestion that the funds be used to make specific federal political 

contributions,146 10 they also do not contend that the news articles’ description of Pitts’s and 

11 Matrix’s plan to anonymize political activities was incorrect. Moreover, contrary to FPL’s 

argument that the news articles describing the proposal relied on anonymous sources,147 12 the news

13 articles stated that the sources of the documents were from Matrix itself, noting that the 

documents were internal Matrix documents.148 14 FPL’s spokesperson, David Reuter, reportedly 

15 confirmed that the proposal as reported was indeed shared with its CEO, stating, “‘We are aware 

16 of the proposed structure as the legal memo was shared with us, and as we understand it, Joe 

17 Perkins’[s] team at Matrix created a proposal to fund their clients’ communication and outreach 

activities during 2020.’”149 18 Thus, there is no available information indicating that the news 

145 See FPL Resp. at 1, 4.

146 Alexander & Anderson Resp. at 3.

147 See FPL Resp. at 5.

148 See Secretive Political Spending Plan, supra note 19 (stating that the Orlando Sentinel received records 

“includ[ing] checks, bank statements, emails, text messages, invoices, internal ledgers and more, all apparently 

unearthed during an internal investigation Matrix launched after its former employees left the firm at the end of 

2020.”).

149 Id.

MUR808200264
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 32 of 48

1 articles’ report that Pitts and Matrix created and shared a proposal to anonymize political 

2 contributions was inaccurate or not credible. 

3 Moreover, the weight of the available information does not support FPL’s argument that 

4 the proposal was limited to acting solely within the legal bounds of minimizing public reporting 

of political activities.150 5 Specifically, the proposal did not indicate that Pitts and Matrix were 

6 soliciting funds from FPL on behalf of nonprofit corporations that would independently decide to 

7 make political contributions. Rather, the proposal indicated that funds would flow from FPL, 

8 through several layers of conduits controlled or associated with Matrix, before landing at 

9 “Florida Promise C4,” “US Promise C4” and “Fed Promise C4,” which would also be controlled 

by Matrix, to make contributions to state and federal political committees.151 10 

11 Notably, there is no available information indicating that Pitts or Matrix presented the 

12 purposes or goals of the conduits referenced in its flowchart, besides being able to making 

13 political contributions, to explain why FPL’s funds would be expected to flow from one 

corporation to another.152 14 There is also no available information indicating that Pitts and Matrix 

15 presented any information as to why “Florida Promise C4,” “US Promise C4” and “Fed Promise 

16 C4,” would be expected to engage in political activity that FPL would support. Instead, Pitts’s 

17 and Matrix’s flowchart simply noted “Matrix” in a parenthetical below the names of “Broken 

18 Promises,” “Florida Promise C4,” “US Promise C4” and “Fed Promise C4,” similar to how 

19 Tyson, the executive director of LPAD, was included in a parenthetical under LPAD, suggesting 

150 See FPL Resp. at 4.

151 Secretive Political Spending Plan, supra note 19; see also Compl. ¶¶ 33 Fig. 1, 36-37. 

152 See Secretive Political Spending Plan, supra note 19 (noting that, for example, “Florida Promise C4” would 

“allowed to spend 50% of revenues on political activities” and that “Florida PCs are allowed to take unlimited funds 

from C4s”); see also Compl. ¶ 33 Fig. 1 (same).

MUR808200265
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 33 of 48

that these entities are controlled by “Matrix,” similar to how Tyson controlled LPAD.153 1 

2 Moreover, the conduits depicted on the flowchart appear to have been in fact controlled 

3 by or associated with Matrix. Of the conduits mentioned, only Florida Promise, Broken 

4 Promises, LPAD, and SUN existed or eventually came into existence, and they all have ties to 

5 Pitts and/or Matrix. As explained above, Richard Alexander was the chairman of Florida 

Promise, and his sister, April Odom, was a Matrix contractor at the time of the allegations.154 6 

7 Sean J. Anderson, who was the president and chairman of Broken Promises, was also a former 

8 Matrix employee, a close friend of Pitts, and has a history of allowing Pitts to control the 

nonprofits that he purportedly ran.155 9 Tyson, the executive director of LPAD, reportedly 

10 associated with Pitts and Abigail MacIver, another former Matrix employee, as they 

communicated via text messages regarding Florida state senate races.156 11 Finally, as for SUN ⸺

12 FPL, which reportedly gave $250,000 to SUN in December 2019, states that it believes that SUN 

is owned by Matrix.157 13 Thus, the layers of corporations depicted on the flowchart appear to be 

14 linked together because they are controlled by persons associated with Pitts or Matrix. 

15 Therefore, in contrast to FPL’s argument, the available information indicates that Pitts’s and 

16 Matrix’s proposal was not solely limited to acting within the legal bounds of minimizing public 

153 See Secretive Political Spending Plan, supra note 19; see also Compl. ¶ 33 Fig. 1. While the term “person” 

appears in the parenthetical next to SUN, SUN had not yet been formed when Pitts sent the memo, and thus this

denotation appears to suggest that they were looking for a “person” to be in control of SUN at that time. See SUN 

Resp. at 1 (stating that it was formed on December 13, 2019); Secretive Political Spending Plan, supra note 19

(reporting that Pitts sent the memo to Silagy on November 26, 2019).

154 Florida Promise 2018 Tax Return at 3, supra note 43; Dark Money Playbook, supra note 7 (reporting that 

April Odom is Anderson’s sister and was a former Matrix employee).

155 Broken Promises, 2018 Tax Return at 1, 7, supra note 75; Bachelor Party, supra note 10 (reporting Pitts as 

having attended Anderson’s bachelor party); Nightmare Scenario, supra note 10 (reporting that Pitts texted FPL 

Vice President Martell that Anderson was an old friend of his and that he was “‘in control 100 percent’” of the 

nonprofits purportedly run by Mr. Anderson).

156 FPL Execs, supra note 55. 

157 Secretive Political Spending Plan, supra note 19. 

MUR808200266
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 34 of 48

1 reporting, and instead included the making of prohibited conduit contributions. 

2 The available information also does not support Alexander and Anderson’s argument that 

the proposal did not include references to making federal political contributions.158 3 According to 

4 news articles, Pitts’s email to Silagy included a “‘funding memo’” noting making “federal 

campaign contributions” as one of its goals.159 5 Pitts’s email to Silagy also included “‘a separate 

6 legal memo on federal elections support’” explaining that “a nonprofit might have to disclose its 

7 donors if it spent money directly supporting a candidate” but that “the nonprofit would not have 

8 to disclose its donors if it gave money to a type of political action committee known as a ‘Super 

PAC,’”160 which is a colloquial reference to federal independent expenditure-only committees.161 9 

10 Moreover, this legal memo appears to provide the missing explanation as to the purpose of 

11 providing funds to the “Fed Promise C4” entity in the funding memo’s flowchart, indicating that 

this purpose would be to make federal political contributions.162 12 The name, “Fed Promise C4,” 

13 also suggests that this conduit would be used to make federal political contributions, as this

14 would be consistent with and parallel to the flowchart’s statements that “Florida Promise C4” 

15 would be used to fund “Florida PCs” and that “US Promise C4” would be used to fund other 

state-level political activities.163 16 Thus, the available information indicates that the Pitts/Matrix 

17 proposal included making federal political contributions.

158 See Alexander & Anderson Resp. at 3.

159 Secretive Political Spending Plan, supra note 19; see also Compl. ¶ 32.

160 Secretive Political Spending Plan, supra note 19; see also Compl. ¶ 38.

161 See McCutcheon v. FEC, 572 U.S. 185, 193 (2014) (“A so-called ‘Super PAC’ is a PAC that makes only 

independent expenditures and cannot contribute to candidates. The base and aggregate limits govern contributions 

to traditional PACs, but not to independent expenditure PACs.”).

162 See Secretive Political Spending Plan, supra note 19; see also Compl. ¶ 33 Fig. 1 (noting that it was 

“[w]aiting on lawyers” to explain the purpose of Fed Promise C4).

163 Secretive Political Spending Plan, supra note 19; see also Compl. ¶ 33 Fig. 1.

MUR808200267
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 35 of 48

1 Although Alexander and Anderson argue that the Complaint fails to include evidence that 

2 neither they, nor the alleged Conduit Corporations that they controlled, received funds with the 

direction that they be used for federal contribution purposes,164 3 federal courts have stated that a 

4 donor’s intent can be inferred from the donee’s solicitations. Specifically, in the context of 

5 interpreting 52 U.S.C. § 30104(c)(1) of the Act, which courts have held to require not-political 

committees to disclose donations received for political purposes,165 6 a district court in Wisconsin 

7 observed that “whether a contribution is earmarked for political purposes and tied to an election 

8 can depend on whether the contribution is received in response to a solicitation and the way the 

solicitation is worded.”166 9 As explained above, Pitts’s and Matrix’s proposal clearly implicated 

10 the making of federal contributions, and thus the Complaint adequately alleged that the alleged 

11 Conduit Corporations’ received donations for the purposes of making federal contributions in 

12 response to that proposal.

13 In addition to conceiving of and sharing the plan, Pitts and Matrix were also in a position 

14 to carry it out using the names of alleged Conduit Corporations to make the contributions. As 

15 discussed above, the persons nominally in charge of the alleged Conduit Corporations, 

16 Alexander and Anderson, had close relationships with Pitts and Matrix. Alexander, who served 

17 as a director or officer of Florida Promise, CAIJ, and Grow United, is apparently the brother of 

18 April Odom, who was a Matrix contractor at the time of the contributions and worked on matters 

relating to CAIJ and Grow United on behalf of Matrix.167 19 Anderson, who was the chairman and 

164 See Alexander & Anderson Resp. at 3.

165 Citizens for Resp. & Ethics in Washington v. FEC, 316 F. Supp. 3d 349, 389 (D.D.C. 2018), aff’d, 971 F.3d 

340 (D.C. Cir. 2020).

166 Wisconsin Fam. Action v. FEC, No. 21-C-1373, 2022 WL 844436, at *11 (E.D. Wis. Mar. 22, 2022). 

167 Dark Money Playbook, supra note 7 (reporting that April Odom is Anderson’s sister and was a former 

Matrix contractor); see also Compl. ¶¶ 13, 48.

MUR808200268
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 36 of 48

1 president of Broken Promises and a director and president of Stand Up for Justice, was also 

former Matrix employee, and a close friend of Pitts.168 2 Pitts and Matrix also has a history of 

3 working with Anderson’s nonprofit corporations, as Pitts reportedly texted FPL Vice President 

4 Daniel Martell in 2016, four years prior to the contributions at issue here, “‘Bottom line is we are 

5 the ones with the check books and in control 100 percent’” of the nonprofits purportedly run by 

Anderson.169 6 

7 Pitts and Matrix also reportedly used the names of CAIJ and Grow United in other 

operations,170 and had access to CAIJ’s and Grow United’s bank accounts,171 8 further indicating 

9 that they had control over these corporations. Specifically, news reports indicate that, in October 

2018, Pitts used CAIJ to make a contribution to House Majority PAC on behalf of Matrix.172 10 

11 News reports also indicate that in the summer of 2019, Matrix used Grow United to offer a job to 

a Jacksonville City Council member on behalf of FPL.173 12 In addition, according to the Orlando 

168 Bachelor Party, supra note 10 (reporting Pitts as having attended Anderson’s bachelor party); Nightmare 

Scenario, supra note 10 (reporting that Pitts texted FPL Vice President Martell that Anderson was an old friend of 

his); see also Compl. ¶¶ 16, 52.

169 Nightmare Scenario, supra note 10; see also Compl. ¶¶ 16, 52. 

170 FPL Execs, supra note 55 (reporting that Matrix made a conduit contribution using CAIJ’s name on behalf 

of FPL); Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/ (reporting that Matrix offered a city councilman 

a job on behalf of FPL using Grow United’s name).

171 Dark Money Playbook, supra note 7 (reporting that internal Matrix records included a text message from 

Odom stating that she procured access to the bank accounts of CAIJ and Grow United).

172 FPL Execs, see supra note 55 (reporting that Silagy, former CEO of FPL, emailed Pitts, former CEO of 

Matrix, to make a contribution to House Majority PAC to support Lauren Baer, and to make sure that “they don’t 

triangulate this donation to others we have done”); see also House Majority PAC, 2018 Amended 12-Day PreElection Report at 655 (Dec. 3, 2018), https://docquery.fec.gov/pdf/085/201812069135107085/20181206913510

7085.pdf (reflecting CAIJ’s contribution to House Majority PAC on October 16, 2018).

173 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/. FPL reportedly confirmed that Matrix 

employees came up with an idea to offer the City Council member a job, but that it rejected the idea. Id. 

MUR808200269
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 37 of 48

1 Sentinel, it received internal Matrix documents reflecting a September 23, 2020 text message 

from Odom stating that she procured access to CAIJ’s and Grow United’s bank accounts.174 2 

3 Finally, Tyson, the executive director of LPAD who donated $1,150,000 of LPAD funds to 

Grow United, testified that he understood that Pitts created and ran Grow United.175 4 Therefore, 

5 not only did Pitts and Matrix conceive of a plan for the making of conduit contributions, they 

6 also had sufficient control over the alleged Conduit Corporations to cause them to permit their 

7 names to be used to make contributions on behalf of Unknown Respondents. 

8 Although all five of the alleged Conduit Corporations were formed more than a year prior 

9 to making the contributions, the overall record of their known activities indicate that they were 

10 formed for the purpose of making conduit contributions.

11 

12 

13 

14 

15 

16 

17 

18 

19 

174 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right-hand corner 

of the article’s sixth picture); see also Compl. ¶ 48.

175 Tyson Dep. at 16:18-22, 18:4-9.

MUR808200270
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 38 of 48

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 Here, the overall information similarly and strongly supports a finding that the 

11 contributions at issue here were made in the name of another. The only available information as 

12 to the five alleged Conduit Corporations’ activities was that they made federal and Florida state 

political contributions.181 13 Broken Promises and Stand Up for Justice spent at least 67% to 89% 

14 and 78% to 94%, respectively, of their total funding on making federal and Florida state political 

15 contributions, indicating that they were created for the primary purpose of making political 

contributions.182 16 Moreover, consistent with the Pitts’s and Matrix’s proposal, federal tax records 

17 show that their funding was first transmitted through another Matrix-associated conduit, the 

181 Although Matrix reportedly used Grow United to offer a job to a Jacksonville council member, that never 

came to fruition as the council member rejected the offer. Nate Monroe, Amid JEA Privatization Controversy, a 

City Council Member Received a Mysterious Job Offer. A Dark-Money Group May Have Been Behind It, THE FL

TIMES-UNION (Sept. 2, 2022), https://www.jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-salejacksonville-city-council-member-mysterious-job-offer-dark-money-group-nate-monroe/8850689002/. 

182 See supra pages 18-19, 21-22.

MUR808200271
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 39 of 48

1 Alliance for Consumer Protection Inc., which was reportedly controlled by Pitts’s former college 

roommate.183 2 While the available information does not indicate the total funding received by 

3 Florida Promise, CAIJ, or Grow United, the only known activities by these corporations are that 

they made an aggregate of $3,224,500 in federal and Florida state political contributions.184 4 

5 Alexander and Anderson, who were directors or officers of the alleged Conduit 

6 Corporations, similarly did not provide any insight or explanation as to the activities of the 

7 Conduit Corporations in their Response. Only Florida Promise, Broken Promises, and Stand Up 

8 for Justice appeared to have filed federal tax returns, and these returns do not indicate that they 

engaged in any activity other than making political contributions, including through lobbying.185 9 

10 In addition, the purpose statements in these tax returns indicate that Florida Promise, Broken 

11 Promises, and Stand Up for Justice were formed for political purposes, further suggesting they 

only engaged in political activities.

186 12 

13 Furthermore, there are various organizational aspects of the alleged Conduit Corporations 

14 that suggest they were formed to serve as conduits. Specifically, despite the fact that CAIJ and 

183 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095_201812_990O_20211020

19109756.pdf; Nightmare Scenario, supra note 10. 

184 See supra notes 44-45and accompanying text (reflecting that Florida Promise made $1,230,000 in federal 

and Florida state contributions); supra notes 50, 52, 54 and accompanying text (reflecting that CAIJ made $432,000 

in federal and Florida state contributions); supra notes 59, 62 and accompanying text (reflecting that Grow United 

made $1,562,500 in federal and Florida state contributions).

185 See generally Florida Promise 2018 Tax Return, supra note 43; Broken Promises 2018 Tax Return, supra

note 75; Stand Up for Justice 2018 Tax Return, supra note 91. As indicated above, while Broken Promises and 

Stand Up for Justice indicated in their 2018 federal tax returns that they spent funding on “lobbying” and “other” 

program expenses in 2018, the amounts they reportedly spent correspond to the same amounts that they spent on 

making Florida state political contributions. See supra pages 19, 22.

186 Florida Promise 2018 Tax Return at 6, supra note 43 (stating that its purpose is to “develop and advocate 

for legislation, regulations, and government programs related to policies to benefit Floridians”); Broken Promises 

2018 Tax Return at 2, supra note 75 (stating that its purpose is to “develop[] and advocat[e] for legislation, 

regulations, and government programs to improve social environmental, economy and social environment”); Stand 

Up for Justice 2018 Tax Return at 2, supra note 91 (stating that its purpose is to “develop[] and advocat[e] for 

legistlation [sic], regulations, and government programs to improve social environment, economy & society”).

MUR808200272
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 40 of 48

1 Stand Up for Justice were incorporated in different states and do not share any officers, both 

entities reported having the same mailing address in Washington, D.C.187 2 In addition, despite 

3 both Broken Promises and Stand Up for Justice having the same three officers and nearly 

4 identical mission statements, both entities were incorporated on the same day in the same 

state.188 5 Finally, Broken Promises’s federal tax return suggests that it was trying to conceal that 

6 it made political contributions. Specifically, Broken Promises characterized on its 2018 federal 

7 tax return that it spent $115,470 on “other” program service expenses, when that amount was 

actually used to make in-kind contributions to Florida state committees.189 8 

9 

10 

11 

12 

13 

14 In sum, the available information indicates that there was a plan to illegally disguise or 

15 withhold public reporting of political activities, and that this plan included making contributions 

187 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting that CAIJ’s address was at 2020 Pennsylvania Avenue, 

NW, Ste. 449, Washington DC 20006); CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing

(last visited Sept. 25, 2023) (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for 

Justice’s business address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006). 

188 See CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023) 

(searching the organization names “Broken Promises” and “Stand Up For Justice”) (reflecting that both Broken 

Promises and Stand Up for Justice were incorporated on August 29, 2018); Broken Promises 2018 Tax Return at 1, 

7, supra note 75; Stand Up for Justice 2018 Tax Return at 1, 7, supra note 91. 

189 Compare Broken Promises 2018 Tax Return at 10, supra note 75 (stating that it spent $115,470 in “other” 

program service expenses), with Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.

myflorida.com/campaign-finance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and 

contributor last name “Broken Promises”) (reflecting that Broken Promises Broken Promises made $115,470 in inkind Florida state political contributions in 2018).

MUR808200273
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 41 of 48

1 through conduits and in a manner that closely matches what the available information shows had 

2 subsequently occurred. In addition, pursuant to this plan, the alleged Conduit Corporations 

3 permitted their names to be used to make federal political contributions on behalf of Unknown 

4 Respondents. Finally, the only known activities of the alleged Conduit Corporations were that 

5 they made federal and Florida state political contributions, indicating that their purpose was to 

6 serve as conduits. Thus, we recommend that the Commission find reason to believe that 

7 Unknown Respondents, which are likely Pitts and/or Matrix clients, violated 52 U.S.C. § 30122 

8 and 11 C.F.R. § 110.4(b) by making contributions in the name of another, and reason to believe 

9 that Florida Promise, CAIJ, Grow United, Broken Promises, and Stand Up for Justice violated 52 

10 U.S.C. § 30122 and 11 C.F.R. § 110.4(b) by knowingly permitting their names to be used to 

effect contributions in the name of another.191 11 

12 B. The Commission Should Take No Action at this Time as to FPL, LPAD, 

13 SUN, the recipient IEOPCs, Alexander, and Anderson 

14 Pending the investigation of the Conduit Corporations, we recommend that the 

15 Commission take no action at this time as to FPL, the Conduit Corporations’ officers, Alexander 

16 and Anderson, LPAD, SUN, and the recipient IEOPCs and their treasurers.

17 Although the available information indicates that Pitts and Matrix shared their proposal to 

18 make conduit contributions with FPL’s former CEO, Eric Silagy, FPL’s Response denies the 

19 allegations and includes a sworn declaration from Silagy denying that FPL used any of their 

191 Although the available information regarding the alleged Conduit Corporations and the conduit network 

described in the Matrix funding memo could support the conclusion that the violations were a knowing and willful 

attempt to circumvent the Act’s reporting requirements, we are not recommending that the Commission make any 

knowing and willful findings at this time. If more information arises as a result of the investigation, we will make 

appropriate recommendations in the future. 

MUR808200274
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 42 of 48

funds to make conduit contributions through nonprofit organizations in 2020.192 1 However, given 

2 that Silagy’s declaration is limited to “FPL’s 2020 political activities,” and that FPL appears to 

3 have provided funding to the Conduit Corporations prior to 2020, including for the purpose of 

making a contribution to House Majority PAC through CAIJ in 2018,193 4 it is possible that FPL 

5 may have been one of the sources of the alleged contributions at issue here. Moreover, Grow 

United did not identify itself as a nonprofit corporation.194 6 In addition, it appears that FPL did 

7 implement at least some part of Matrix’s proposal, as it admitted to funding SUN, an entity that 

had not yet been formed at the time it was mentioned in Matrix’s proposal.195 8 Therefore, we 

9 recommend that the Commission take no action at this time as to FPL. 

10 With respect to Richard Alexander and Sean J. Anderson, the available information does 

11 not indicate that they are either the true source of the contributions, or that they personally acted 

12 as conduits. However, the investigation could reveal new information indicating that they are the 

13 true sources of the funds. Therefore, we recommend that the Commission take no action as to 

14 them at this time. 

15 As for LPAD, LPAD similarly denies any knowledge or involvement with Matrix’s 

proposal.196 16 According to a sworn declaration from Ryan Tyson, LPAD’s executive director, 

17 “any decision concerning the ultimate use of the funds [donated to LPAD] is left to the sole 

192 FPL Resp. at 1 (denying that it made a donation to LPAD with the understanding that it would be 

contributed to an IEOPC), id. at 10 (noting that Silagy denied knowledge of making a campaign finance violation), 

Silagy Decl. ¶ 5 (describing his personal knowledge of FPL’s 2020 political activities and denying making 

contributions using nonprofit organizations as conduits).

193 FPL Execs, supra note 55. 

194 See Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited Sept. 25, 2023) 

(reflecting that there are no results when searching Grow United’s name or its EIN number identified in the 

Complaint, 84-2546999).

195 See supra Part II(D). 

196 LPAD Resp. at 1-2; see also Tyson Decl. ¶¶ 10-11, 17. 

MUR808200275
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 43 of 48

1 discretion of LPAD;” “[n]either Mr. Pitts nor any other individual has ever suggested to [Tyson] 

2 that LPAD should contribute to a particular cause or political candidate;” and “LPAD has no 

3 further discussions with the recipient concerning the disposition or use of any of the funds LPAD 

has donated to other 501(c)(4) nonprofit organizations or political committees.”197 4 

5 Tyson’s sworn testimony in a deposition conducted by the Miami-Dade State Attorney’s 

6 Office, however, undercuts LPAD’s Response and the accompanying sworn declaration from 

7 Tyson. Specifically, Tyson testified that he did in fact speak to Pitts, who he understood to be 

8 running Grow United, about donating LPAD funds, stating, 

9 Well as best as I can recall, I called [Pitts] up and I said, “Do you 

10 have any social welfare groups that are interested in working on 

11 issues that are amenable to my organizational narrative? Are they 

12 interested in supporting other interests in other committees around 

13 the country, in Florida specifically too, that would focus purely on 

the center left spectrum and on issues that are center left.”198 14 

15 According to Tyson, Pitts answered this question and “said he did,” referring to Grow United, 

and so Tyson “said we’d be happy to support them.”199 16 In addition, Tyson testified that he 

17 discussed with Pitts about how he should use the funds Grow United would be receiving from 

18 LPAD, stating, “I told you earlier I knew [the funds from the Alvarado committees] came from 

19 Grow United. There was a story about it. And I knew, I actually told Grow United that 

Alvarado would probably call them and ask, raise money.”200 20 Thus, notwithstanding Tyson’s 

197 Tyson Decl. ¶¶ 5, 8, 14; see also LPAD Resp. at 1-2, 4.

198 Tyson Dep. at 17:10-14 (in response to the question “So give me your best recollection of the content of the 

conversation that you had with Jeff Pitts that caused you to want to send the money to Grow United.”).

199 Id. at 17:14.

200 Id. at 28:5-10 (emphasis added) (Tyson’s response to a question asking if Tyson discussed with Alvarado 

about the source of the Alvarado committees’ funding); see also id. at 27:21-24 (Tyson testifying that he assumed 

that Alvarado would call Grow United for funding when asked again whether he knew about the source of the 

Alvarado committees’ funding).

MUR808200276
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 44 of 48

1 sworn statement that “LPAD has no further discussions with the recipient concerning the 

2 disposition or use of any of the funds LPAD has donated to other 501(c)(4) nonprofit 

organizations or political committees,”201 3 it appears that Tyson did have discussions with Grow 

4 United about how to use LPAD’s funding, suggesting that he may have also communicated with 

5 other recipients of LPAD funding to discuss how that money should be spent. While LPAD 

6 would not be appear to be violating the Act if its actions were limited to merely helping to 

7 facilitate a contribution in the name of another, LPAD’s statements regarding how it is vested 

8 with the sole discretion as to how to spend its fund could also mean that it was a true source of 

the contributions.202 9 Thus, we recommend that the Commission take no action at this time as to 

10 LPAD. 

11 As for SUN, while the available information indicates that SUN was created and 

12 controlled by Matrix, SUN does not appear to have been used for the making conduit 

contributions.203 13 However, the results from the investigation could indicate otherwise. Thus, we 

14 recommend that the Commission take no action at this time as to SUN.

15 Finally, with respect to the recipient committees and their treasurers, the Complaint’s 

16 allegations are not particularly compelling at this stage because of the general lack of 

17 information indicating that the recipient committees and their treasurers accepted the 

18 contributions knowing that they were actually made in the name of another. While there is some 

19 suggestive information in the available record, it is limited. For example, Senate Leadership 

20 Fund states that one of its representatives “spoke with a representative of Florida Promise, who 

201 Tyson Decl. ¶ 8.

202 See id. ¶ 5.

203 See supra Part II(D).

MUR808200277
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 45 of 48

completed a donor information form.”204 1 In addition, internal Matrix records reportedly show 

2 that, when Silagy requested that Pitts make a contribution to House Majority PAC, both Silagy 

and Pitts communicated with an employee of the committee prior to making the contribution.205 3 

4 Thus, the results from an investigation could reveal new information that Alexander, Anderson, 

5 the alleged Conduit Corporations, or the Unknown Respondents communicated with the 

6 recipient committees while making the contributions and in a manner that indicated that they 

7 would be making conduit contributions. Therefore, we recommend that the Commission take no 

8 action at this time as to the recipient committees and their treasurers.

9 IV. INVESTIGATION

10 While the current record establishes reason to believe that the Conduit Corporations made 

11 contributions in the name of another, the identities of the true sources of the contributions are 

12 unknown. The investigation would seek to obtain further information from the now-defunct 

13 Conduit Corporations and their representatives, including Richard Alexander and Sean J. 

14 Anderson, regarding all communications with Matrix and their representatives, including Jeff 

15 Pitts, Abigail MacIver, and April Odom; with LPAD and their representatives, including Ryan 

16 Tyson; with FPL and their representatives, including Eric Silagy; and with the recipient IEOPCs 

17 and their representatives. 

18 

19 

20 

21 

204 Senate Leadership Fund Resp. at 2.

205 FPL Execs, supra at 55. 

MUR808200278
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 46 of 48

1 

2 

3 

4 

5 While the Office of General Counsel will seek to obtain these responses and materials via 

6 voluntary means, we also recommend that the Commission authorize the use of compulsory 

7 process, including the issuance of appropriate interrogatories, document subpoenas, and 

8 deposition subpoenas, should that become necessary. Such interrogatories and subpoenas would 

9 be directed to the Conduit Corporations and/or their representatives, including but not limited to 

10 Alexander and Anderson. We anticipate that the use of compulsory process is likely necessary in 

11 this matter. 

12 

13 

14 

15 

16 

17 

18 

19 V. RECOMMENDATIONS

20 1. Find reason to believe that Unknown Respondents violated 52 U.S.C. § 30122 and 

21 11 C.F.R. § 110.4(b) by making contributions in the name of another; 

22 2. Find reason to believe that Florida Promise, Inc., violated 52 U.S.C. § 30122 and 

23 11 C.F.R. § 110.4(b) by knowingly permitting its name to be used to effect 

24 contributions in the name of another; 

MUR808200279
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 47 of 48

1 3. Find reason to believe that the Center for Advancement of Integrity and Justice, Inc.,

2 violated 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b) by knowingly permitting its 

3 name to be used to effect contributions in the name of another; 

4 4. Find reason to believe that Grow United, Inc., violated 52 U.S.C. § 30122 and 

5 11 C.F.R. § 110.4(b) by knowingly permitting its name to be used to effect 

6 contributions in the name of another; 

7 5. Find reason to believe that Broken Promises violated 52 U.S.C. § 30122 and 

8 11 C.F.R. § 110.4(b) by knowingly permitting its name to be used to effect 

9 contributions in the name of another; 

10 6. Find reason to believe that Stand Up for Justice violated 52 U.S.C. § 30122 and 

11 11 C.F.R. § 110.4(b) by knowingly permitting its name to be used to effect 

12 contributions in the name of another; 

13 7. Take no action at this time as to Florida Light & Power Company, Let’s Preserve the 

14 American Dream, Inc., SUN Marketing & Advertising LLC, Richard Alexander, and 

15 Sean J. Anderson; 

16 

17 8. Take no action at this time as to Conservative Action Fund (f/k/a Wingman PAC) and 

18 Charles Gantt in his official capacity as treasurer; Abby Dupree, in her former official 

19 capacity as treasurer of Wingman PAC and in her personal capacity; American Valor 

20 PAC and Lisa Lisker in her official capacity as treasurer and in her personal capacity; 

21 Senate Leadership Fund and Caleb Crosby in his official capacity as treasurer and in 

22 his personal capacity; Concerned Conservatives, Inc., and Nancy H. Watkins in her 

23 official capacity as treasurer and in her personal capacity; and South Florida 

24 Residents First and Paul Kilgore in his official capacity as treasurer and in his 

25 personal capacity

26 9. Approve the attached Factual and Legal Analysis; 

27 10. Authorize the use of compulsory process; and 

MUR808200280
MUR 8082 (Unknown Respondents, et al.) 

First General Counsel’s Report

Page 48 of 48

1 11. Approve the appropriate letter. 

2 

3 Lisa J. Stevenson 

4 Acting General Counsel

 5 

6 ___________________ ______________________________________ 

7 Date Charles Kitcher

8 Associate General Counsel for Enforcement

9 _______________________________________ 

10 Mark Shonkwiler 

11 Assistant General Counsel 

12 ________________________________________ 

13 Crystal Liu

14 Attorney 

15 Attachments 

16 1. Factual and Legal Analysis – Unknown Respondents 

17 2. Factual and Legal Analysis – Florida Promise, Inc. 

18 3. Factual and Legal Analysis – Center for Advancement of Integrity and Justice, Inc.

19 4. Factual and Legal Analysis – Grow United, Inc. 

20 5. Factual and Legal Analysis – Broken Promises 

21 6. Factual and Legal Analysis – Stand Up for Justice 

September 29, 2023

MUR808200281
1 FEDERAL ELECTION COMMISSION

2 FACTUAL AND LEGAL ANALYSIS

3 RESPONDENT: Unknown Respondents MUR 8082 

4 I. INTRODUCTION

5 The Complaint alleges that Unknown Respondents made five contributions in the name 

6 of another, totaling $1.27 million, through a network of conduits associated with a political 

7 consulting firm called Matrix LLC (“Matrix”), to five federal independent expenditure-only 

political committees (“IEOPCs”).

1 8 The specific contributions identified in the Complaint are as 

9 follows: 

10 • a $1,000,000 contribution reportedly from Florida Promise, Inc. (“Florida Promise”)

to Senate Leadership Fund, dated December 8, 2020;2 11 

12 • a $100,000 contribution reportedly from the Center for Advancement of Integrity and

Justice, Inc. (“CAIJ”) to American Valor PAC, dated October 27, 2020;3 13 

14 • a $100,000 contribution reportedly from Grow United, Inc. (“Grow United”) to

Conservative Action Fund (f/k/a Wingman PAC), also dated October 27, 2020;4 15 

16 • a $20,000 contribution reportedly from Broken Promises to Concerned

Conservatives, Inc., dated July 14, 2020;5 17 and

1 Compl. ¶¶ 2, 5, 27, 42, 89-93 (Oct. 27, 2022).

2 Senate Leadership Fund, Amended 2020 Year End Report at 72 (Mar. 18, 2021), https://docquery.fec.gov/

pdf/807/202103189441299807/202103189441299807.pdf; see also Compl. ¶¶ 49-50.

3

 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/2020

12039337569242/202012039337569242.pdf; see also Compl. ¶¶ 47-48.

4

 Wingman PAC, 2020 30-Day Post Election Report at 1, 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting a $100,000 contribution from Grow United, Inc., on 

October 27, 2020, and the committee’s FEC identification number of C00742296); Conservative Action Fund, 

Amended Statement of Organization at 1 (May 20, 2022), https://docquery.fec.gov/pdf/048/202205209512421048/

202205209512421048.pdf (reflecting that its name has changed to Conservative Action Fund and that its FEC 

identification number is C00742296); see also Compl. ¶¶ 43-44.

5 Concerned Conservatives, Inc., 2020 12-Day Pre-Primary Election Report at 6 (Aug. 6, 2020), https://doc

query.fec.gov/pdf/823/202008069261263823/202008069261263823.pdf; see also Compl. ¶¶ 51-52.

Attachment 1 

Page 1 of 33

MUR808200282
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 2 of 33

1 • a $50,000 contribution reportedly from Stand Up for Justice to South Florida 

Residents First, dated March 31, 2020.6 2 

3 The Complaint relies on news articles regarding a 2019 email and two accompanying 

4 memoranda sent from Jeff Pitts, Matrix’s former CEO, to Eric Silagy, Florida Power & Light 

5 Company’s (FPL) former CEO, reportedly proposing a method for FPL to make anonymous 

6 contributions to federal and state political committees by transferring funds through multiple 

levels of conduits.7 7 The proposal called for funds to be first sent to and passed through higher8 level Matrix-associated conduits, including SUN Marketing & Advertising LLC (“SUN”) and 

9 Let’s Preserve the American Dream, Inc. (“LPAD”), before being sent to various lower-level 

10 Matrix-controlled conduits, including Florida Promise, that would be reported as the source of 

11 the contributions. Thus, the Complaint alleges that each of the five alleged lower-level Matrix12 controlled conduits (referred to herein as the “Conduit Corporations”) permitted their names to 

13 be used to effect contributions in the name of another pursuant to Pitts’s and Matrix’s proposal. 

14 To support its central allegation, the Complaint alleges that all five of the alleged Conduit 

15 Corporations had ties to Pitts or Matrix through having either Richard Alexander or Sean J. 

Anderson as a director or officer.

8 16 Citing news articles, the Complaint alleges that Alexander’s 

6

 South Florida Residents First, 2020 April Quarterly Report at 11 (Apr. 13, 2020), https://docquery.fec.gov/

pdf/294/202004159216942294/202004159216942294.pdf; see also Compl. ¶¶ 53-54.

7

 Compl. ¶¶ 3-4, 28-41; see, e.g., Jason Garcia & Annie Martin, Florida’s Dark Money Playbook: How 

‘Ghost’ Candidate Scheme Revealed Secretive Political Tactics, ORLANDO SENTINEL (Dec. 30, 2021), 

https://www.orlandosentinel.com/news/os-ne-dark-money-ghost-candidates-tactics-20211230-7zelkoadffclde3z

76ax3cgx3m-htmlstory.html [hereinafter Dark Money Playbook].

8

 Compl. ¶¶ 13, 16. 

Attachment 1 

Page 2 of 33

MUR808200283
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 3 of 33

sister was a Matrix contractor at the time of the allegations9 1 and that Anderson was a former 

Matrix employee and a good friend of Pitts.10 2 

3 As discussed below, the five contributions purportedly made by the alleged Conduit 

4 Corporations as identified by the Complaint appear to be consistent with the conduit 

5 contributions proposed by Pitts and Matrix to FPL to anonymize its political contributions. In 

6 addition, all five of the alleged Conduit Corporations appear to be controlled by or associated 

7 with Pitts and Matrix. Thus, it appears likely that Unknown Respondents, who were likely 

8 clients of Pitts and/or Matrix, funded the contributions made through the network of conduits 

9 described in the Matrix memo. Accordingly, the Commission finds reason to believe that

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

11 contributions in the name of another. 

12 II. FACTUAL BACKGROUND

13 A. Jeff Pitts of Matrix Appears to Have Created a Plan to Anonymize Federal 

14 Political Contributions Using a Network of Conduits Controlled by or 

15 Associated with Pitts or Matrix 

Matrix is a “strategic communications firm” based in Alabama.11 16 According to the 

17 Orlando Sentinel, it received a cache of internal documents from Matrix, “includ[ing] checks, 

18 bank statements, emails, text messages, invoices, internal ledgers and more, all apparently 

9

 Id. ¶ 13; see Dark Money Playbook, supra note 7 (reporting that Alexander’s sister, April Odom, was a 

Matrix employee at the time of the allegations, and that she worked on matters relating to Grow United and CAIJ).

10 Compl ¶ 16; see John Archibald, Archibald: ‘Bachelor party’ Makes For Strange Bedfellows, AL.COM

(Nov. 14, 2010), https://www.al.com/archiblog/2010/11/archibald_bachelor_party_makes.html [hereinafter 

“Bachelor Party”] (reporting that Pitts attended Anderson’s bachelor party and that they were both employed by 

Matrix at the time); Mary Ellen Klas, et al., ‘Nightmare Scenario’: How FPL Secretly Manipulated a Florida State 

Senate Election, MIAMI HERALD (Aug. 29, 2022), https://www.miamiherald.com/news/politics-government/statepolitics/article264196761.html [hereinafter “Nightmare Scenario”] (reporting that Pitts texted FPL vice president 

Daniel Martell that Anderson was an old friend of his and that Pitts was in control of the nonprofits run by 

Anderson).

11 Matrix, LLC, v. Canopy Partners, LLC, et al, 2021 WL 3127729 (Ala. Cir. Ct.).

Attachment 1 

Page 3 of 33

MUR808200284
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 4 of 33

1 unearthed during an internal investigation Matrix launched after its former employees left the 

firm at the end of 2020.”12 2 These internal records included a copy of a November 26, 2019 

3 email sent from former Matrix CEO, Jeff Pitts, to former FPL CEO, Eric Silagy, stating, 

4 “‘Attached is an updated funding memo along with a separate legal memo on federal elections 

support.’”13 5 The “funding memo” noted goals such as making “federal campaign contributions” 

and “‘minimiz[ing] all public reporting of entities and activities.’”14 6 It also included a flowchart

7 depicting money flowing from FPL through a network of conduits before being contributed to 

federal and state political committees, as reproduced below:15 8 

12 Jason Garcia & Annie Martin, Operative Pitched Secretive Political Spending Plan to FPL Exec’s Email 

Alias, Records Reveal, ORLANDO SENTINEL (Jan. 24, 2022), https://www.orlandosentinel.com/politics/os-ne-floridapower-and-light-matrix-dark-money-20211217-v64274eytjeb5hnstdognvqds4-story.html [hereinafter “Secretive 

Political Spending Plan”]. 

13 Id.; see also Compl. ¶¶ 3, 31-38.

14 See Secretive Political Spending Plan, supra note 12; Compl. ¶ 32.

15 See Secretive Political Spending Plan, supra note 12; Compl. ¶ 33 Fig. 1.

Attachment 1 

Page 4 of 33

MUR808200285
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 5 of 33

1 Notably, next to or below the name of each conduit is a parenthetical, which may indicate the 

2 person or entity controlling or associating with that conduit. Specifically, the flowchart 

3 identifies a “LPAD C4 (Tyson),” which appears to refer to LPAD and its executive director Ryan 

Tyson.16 4 The flowchart also identifies “Matrix/Foley” in a parenthetical next to or below the 

16 See Compl. ¶ 35.

Attachment 1 

Page 5 of 33

MUR808200286
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 6 of 33

1 names of the following conduits: “Broken Promises,” “Florida Promise C4,” “US Promise C4,” 

2 and “Fed Promise C4,” suggesting that these conduits are directly associated with and/or 

controlled by Matrix and its legal counsel, Foley and Lardner, LLP (“Foley”).17 3 

4 According to the flowchart, money could flow to a “Florida Promise C4,” which could 

5 “spend 50% of revenues on political activities” due to its tax status as a section 501(c)(4) 

6 corporation, and be used to contribute to Florida state political committees on the basis that 

“Florida PCs are allowed to take unlimited funds from C4s.”18 7 Money could also flow to a “US 

8 Promise C4,” which similarly could “spend 50% of revenues on political activities” due to its tax 

9 status, and be used to contribute to other states’ political committees on the basis that “[e]ach 

state operates under unique state elections.”19 10 Lastly, the flowchart indicates that money could 

11 flow to a “Fed Promise C4,” but because Matrix was “[w]aiting on lawyers,” it could not state

the purpose of this proposed funding.20 12 

13 The legal memo attached to the email, which was drafted by Foley attorney Erika Alba, 

addressed “the legalities of using nonprofits to spend money on federal elections.”21 14 The memo 

15 states that “a nonprofit might have to disclose its donors if it spent money directly supporting a 

16 candidate,” but that “the nonprofit would not have to disclose its donors if it gave money to a 

17 type of political committee known as a “‘Super PAC’” (i.e., an IEOPC) “that then spent money 

supporting the candidate.”22 18 The legal memo then concluded: “‘Thus, it could be strategic for a 

17 See Secretive Political Spending Plan, supra note 12 (noting that Erika Alba of Foley & Lardner LLP 

drafted a legal memo attached to the email); see also Compl. ¶ 38 (alleging the same). 

18 Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 33 Fig. 1, 37.

19 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

20 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

21 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 38.

22 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 38.

Attachment 1 

Page 6 of 33

MUR808200287
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 7 of 33

[nonprofit] who wishes to make Independent Expenditures to do so via a Super PAC.’”23 1 

2 Based on the record of contributions disclosed by the recipient IEOPCs and news articles 

3 reporting that LPAD provided funding to Grow United and Broken Promises, the Complaint 

depicts the implementation of the Matrix plan as taking the following altered form:24 4 

5 

6 The Complaint alleges that Matrix pitched the above-referenced plan to Unknown 

7 Respondent clients, noting that FPL’s spokesperson, David Reuter, stated, “‘We are aware of the 

8 proposed structure as the legal memo was shared with us, and as we understand it, Joe 

23 Secretive Political Spending Plan, supra note 12 (alteration in original); see also Compl. ¶ 38.

24 Compl. ¶¶ 42 Fig. 2, 45, 52.

Attachment 1 

Page 7 of 33

MUR808200288
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 8 of 33

1 Perkins’[s] team at Matrix created a proposal to fund their clients’ communication and outreach 

activities during 2020.’”25 2 

3 B. The Alleged Conduit Corporations Appear to Have Been Controlled by or 

4 Associated with Pitts and/or Matrix 

5 The Complaint alleges that five alleged Conduit Corporations, Florida Promise, CAIJ, 

6 Grow United, Broken Promises, and Stand Up for Justice, permitted their names to effect the 

7 $1.27 million in contributions that they purportedly made to IEOPCs on behalf of Unknown 

Respondents.26 8 Richard Alexander served as a director or officer of the first three alleged 

9 Conduit Corporations, while Sean J. Anderson was a director or officer of the latter two. 

10 According to news reports, both Alexander and Anderson had close ties to Matrix. 

11 Alexander’s sister, April Odom, was a Matrix contractor at the time of the allegations and 

12 reportedly worked on behalf of Matrix regarding CAIJ and Grow United, which were entities 

associated with Alexander.

27 13 Anderson, on the other hand, was a former Matrix employee, and 

reportedly a close friend of Pitts. 28 14 Anderson also has a history of working with Pitts, as Pitts 

15 reportedly texted FPL Vice President Daniel Martell in 2016, four years prior to the alleged 

16 contributions, as follows: “‘Bottom line is we are the ones with the check books and in control 

100 percent’” of the nonprofits purportedly run by Anderson.29 17 The discussion below sets out 

18 the available information about each of the alleged Conduit Corporations and their relationships 

19 with Pitts and/or Matrix.

25 Secretive Political Spending Plan, supra note 12 (emphasis added); Compl. ¶ 40 (emphasis added). 

26 Compl. ¶¶ 5, 43-54.

27 Dark Money Playbook, supra note 7 (reporting that April Odom is Anderson’s sister and was a former 

Matrix employee); see also Compl. ¶¶ 13, 48.

28 Bachelor Party, supra note 10; Nightmare Scenario, supra note 10 (reporting that Pitts texted FPL Vice 

President Martell that Anderson was an old friend of his); see also Compl. ¶ 16.

29 Nightmare Scenario, supra note 10; see also Compl. ¶ 16. 

Attachment 1 

Page 8 of 33

MUR808200289
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 9 of 33

1 1. Florida Promise, Inc. 

2 Florida Promise is a corporation identified in Matrix’s proposal to FPL that could be used 

as a conduit to make contributions to Florida political committees,

30 3 and it was incorporated on 

December 18, 2018.31 4 According to Florida Promise’s 2018 federal tax return, it is a 501(c)(4) 

5 corporation; its mission is to “develop and advocate for legislation, regulations, and government 

6 programs related to policies to benefit Floridians”; Alexander was its chairman; it did not have a 

website; and it did not have any expenses or revenue that year.32 7 

8 On December 8, 2020, Florida Promise made a $1,000,000 contribution to the Senate 

Leadership Fund.33 9 In addition, consistent with Matrix’s proposal to use Florida Promise to

10 make Florida political contributions, Florida Promise also made contributions to Florida political 

committees on June 12, 2019, and January 27, 2021, totaling $230,000.34 11 Other than making the 

12 $1,230,000 in federal and Florida state political contributions, there is no publicly available 

13 information regarding Florida Promise’s activities. 

30 See Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 33 Fig. 1, 50. 

31 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Florida Promise”); see also Compl. ¶ 12.

32 IRS Form 990-EZ, Florida Promise, Inc., 2018 Short Form Return of Organization Exempt from Income 

Tax at 2-3, 6 (Nov. 13, 2019), https://apps.irs.gov/pub/epostcard/cor/832961305_201812_990EO_202006011716

8825.pdf [hereinafter Florida Promise 2018 Tax Return]. 

33 Senate Leadership Fund, Amended 2020 Year End Report at 72 (Mar. 18, 2021), https://docquery.fec.gov/

pdf/807/202103189441299807/202103189441299807.pdf; see also Compl. ¶ 49. 

34 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (searching “all” election years with contributor’s last name 

starting with “Florida Promise”); see also Compl. ¶ 50.

Attachment 1 

Page 9 of 33

MUR808200290
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 10 of 33

1 2. Center for Advancement of Integrity and Justice, Inc. 

CAIJ was incorporated on October 1, 2018,35 2 and shared a mailing address with Stand Up 

for Justice.36 There are no publicly available CAIJ federal tax returns.37 3 Alexander served as 

4 either a director or officer of CAIJ.

On October 27, 2020, CAIJ made a $100,000 contribution to American Valor PAC,38 5 an 

6 IEOPC that made independent expenditures during the 2020 election cycle solely in Florida’s

7 13th Congressional District, which supported Anna Paulina Luna, the Republican nominee, and 

opposed Charlie Joseph Crist, the Democratic nominee.39 8 CAIJ also made contributions to 

9 Florida political committees totaling $307,000, starting in November 2018 and through 

December 2020.

40 10 

35 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Center for Advancement of Integrity and 

Justice”); see also Compl. ¶ 11.

36 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting that CAIJ’s address was at 2020 Pennsylvania Avenue, 

NW, Ste. 449, Washington DC 20006); CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing

(last visited Sept. 25, 2023) (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for 

Justice’s business address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006). 

37 On May 15, 2021, the IRS automatically revoked CAIJ’s 501(c)(4) status for not filing a Form 990s-series 

return for three consecutive years, suggesting that CAIJ has not filed any tax returns. See Tax Exempt Organization 

Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited July 25, 2023) (searching the organization name “center 

for advancement of integrity” which reflect that CAIJ’s federal tax exempt status was automatically revoked on May 

15, 2021for not filing a Form 990-series return or notice for three consecutive years).

38 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf; see also Compl. ¶ 47. 

39 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00757179&is_notice=false&most_recent=true (last visited 

Aug. 18, 2023) (reflecting independent expenditures made by American Valor PAC); November 3, 2020 General 

Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=

11/3/2020&DATAMODE= (last visited Sept. 25, 2023) (selecting “Federal Offices”) (reflecting that Anna Luna 

was the Republican nominee and that Charlie Crist was the Democratic nominee in Florida’s 13th Congressional 

District).

40 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited July 25, 2023) (searching “all” election years with contributor’s last name starting 

with “center for advancement”).

Attachment 1 

Page 10 of 33

MUR808200291
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 11 of 33

1 While CAIJ was not referenced by name in Matrix’s proposal to FPL, news reports 

2 suggest that it was controlled by Matrix. Specifically, Matrix’s internal files reportedly include a 

3 September 23, 2020 text message from Odom, Alexander’s sister and a Matrix contractor at the 

time of the allegations, stating that she procured access to CAIJ’s bank account.41 4 In addition, 

5 on October 16, 2018, just 15 days after CAIJ’s incorporation, CAIJ made a $25,000 contribution 

to House Majority PAC.42 6 According to news reports, FPL directed Matrix to make this 

7 contribution on its behalf to support Lauren Baer, who was seeking election in Florida’s 18th 

8 Congressional District, and asked Matrix to ensure that House Majority PAC “‘do[es]n’t 

triangulate this donation to others we have done.’”43 9 Other than making the $432,000 in federal 

10 and Florida state political contributions, there is no publicly available information regarding 

11 CAIJ’s activities. 

41 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right-hand corner 

of the article’s sixth picture); see also Compl. ¶ 48.

42 House Majority PAC, 2018 Amended 12-Day Pre-Election Report at 655 (Dec. 3, 2018), https://docquery

.fec.gov/pdf/085/201812069135107085/201812069135107085.pdf. 

43 Jason Garcia & Annie Martin, Florida Power & Light Execs Worked Closely with Consultants Behind 

‘Ghost’ Candidate Scheme, Records Reveal, ORLANDO SENTINEL (Apr. 14, 2022), https://www.orlandosentinel.com/

politics/os-ne-florida-power-and-light-senate-ghost-candidates-20211202-szjhv7ox6vcmphm6pgd437y52i-htmlstory

.html [hereinafter “FPL Execs”] (reporting that Silagy forwarded Pitts instructions to make a contribution to House 

Majority PAC to support Lauren Baer and to make sure that “they don’t triangulate this donation to others we have 

done”); November 6, 2018 General Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.my

florida.com/Index.asp?ElectionDate=11/6/2018&DATAMODE= (last visited Sept. 25, 2023) (reflecting that Lauren 

Baer was the democratic nominee in Florida’s 18th Congressional District). 

Attachment 1 

Page 11 of 33

MUR808200292
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 12 of 33

1 3. Grow United, Inc. 

Grow United was incorporated on July 24, 2019.44 2 There are no publicly available Grow 

3 United federal tax records and it did not identify itself as a nonprofit organization to the Internal 

Revenue Service.

45 4 Alexander served either as a director or officer of Grow United. 

On October 27, 2020, Grow United made a $100,000 contribution to Wingman PAC,46 5 

now known as the Conservative Action Fund.47 6 Wingman PAC made independent expenditures 

7 during the 2020 election cycle solely in Florida’s 15th Congressional District, which supported 

8 Scott Franklin, the Republican nominee; opposed Alan Michael Cohn, the Democratic nominee; 

9 and opposed Vincent Spano Ross, who competed against Franklin for the Republican 

44 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Grow United”). 

45 See Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited Sept. 25, 2023)

(reflecting that there are no results when searching Grow United’s name or its EIN number identified in the 

Complaint, 84-2546999). 

46 Wingman PAC, 2020 30-Day Post Election Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/423/

202012039338666423/202012039338666423.pdf (reflecting a $100,000 contribution from Grow United on October 

27, 2020).

47 Id. at 1(reflecting an FEC identification number of C00742296); Conservative Action Fund, Amended 

Statement of Organization at 1 (May 20, 2022), https://docquery.fec.gov/pdf/048/202205209512421048/2022

05209512421048.pdf (reflecting that its name has changed to Conservative Action Fund and its FEC identification 

number is C00742296). 

Attachment 1 

Page 12 of 33

MUR808200293
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 13 of 33

nomination.48 1 Earlier that month, from October 3, 2020, through October 20, 2020, Grow 

United made contributions to Florida state political committees totaling $1,462,500.49 2 

3 Grow United appears to have been created and controlled by Pitts and Matrix. Ryan 

4 Tyson, the executive director of LPAD — which contributed $1,150,000 to Grow United in 

202050 5 — was deposed by the Miami-Dade State Attorney’s Office in a criminal matter 

6 regarding a former LPAD contractor’s creation of fake Florida state senate candidates during the 

7 2020 election cycle. Tyson testified in the deposition that he understood that Jeff Pitts started 

8 and ran Grow United. In addition, FPL reportedly asserted that Grow United was created by 

Matrix.51 9 

10 Matrix’s internal records also reportedly indicate that it had control of Grow United. 

11 According to news reports, Matrix’s internal ledger reflect an August 7, 2019 entry billed to FPL 

12 for “‘Grow United SOS Fees,’” which likely referred to the fees charged by the Delaware 

48 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00742296&is_notice=false&min_date=01%2F01%2F2019&max

_date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting Wingman PAC’s independent expenditures in the 

2020 election cycle); November 3, 2020 General Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results

.elections.myflorida.com/Index.asp?ElectionDate=11/3/2020&DATAMODE= (last visited Sept. 25, 2023) 

(selecting “Federal Offices”) (reflecting that Scott Franklin was the Republican nominee and Alan Cohn was the 

Democratic nominee in Florida’s 15th Congressional District); August 18, 2020 Primary Election Republican 

Primary, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate

=8/18/2020&DATAMODE= (last visited Sept. 25, 2023) (selecting “Federal Offices” in the Republican Primary 

section) (reflecting that both Scott Franklin and Ross Spano were seeking the Republican nomination in Florida’s 

15th Congressional District).

49 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (selecting election year “all” and searching contributor last name 

starting with “grow united”); see also Compl. ¶ 46.

50 See Compl. ¶ 45.

51 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Dec. 10, 2021, updated Sept. 2, 

2022), https://www.jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-citycouncil-member-mysterious-job-offer-dark-money-group-nate-monroe/8850689002/. Joe Perkins, owner of Matrix, 

denies that Matrix created Grow United, and Perkins’s attorney asserts that “[t]o the extent any rogue Matrix 

employees were involved in those activities, they were undertaken in secret, without Dr. Perkins’[s] knowledge or 

consent.” Id.

Attachment 1 

Page 13 of 33

MUR808200294
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 14 of 33

Secretary of State for incorporating Grow United a few weeks prior.

52 1 Matrix’s internal records 

2 also reportedly include a September 23, 2020 message from Odom stating that she procured 

access to Grow United’s bank account.53 3 In addition, as part of her duties at Matrix, Odom 

4 reportedly sent checks from Grow United to make contributions to Florida committees, asked the 

committees to confirm their receipt of the checks,54 5 and emailed a $12,813.54 invoice to Matrix

6 with the subject line, “FPL Expenses for Grow United c4,” for expenses that included traveling 

to Colorado to update the nonprofit’s mailbox at a UPS Store in Denver.55 7 

8 News articles also report that, in the summer of 2019, Matrix used Grow United to offer a 

job to a Jacksonville City Councilmember on behalf of FPL.56 9 Furthermore, Foley attorney 

10 Erika Alba reportedly billed Matrix in the fall of 2020 for her work on IRS submission forms for 

Grow United.57 11 Other than making the $1,562,500 in political contributions, there is no publicly 

12 available information regarding Grow United’s activities.

52 FPL Execs, supra note 43. 

53 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right corner of the 

article’s sixth picture); see also Compl. ¶ 48.

54 Dark Money Playbook, supra note 7. 

55 FPL Execs, supra note 43. 

56 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/. FPL reportedly confirmed that Matrix 

employees came up with an idea to offer the City Council member a job, but that it rejected the idea. Id. 

57 Nate Monroe, Law Firm that Advised on Botched JEA Sale Also Helped Former FPL Consultants On 

Dark-Money Projects, FL TIMES-UNION (Dec. 17, 2021), https://www.jacksonville.com/story/news/columns/natemonroe/2021/12/17/jea-privatization-law-firm-foley-lardner-also-helped-former-fpl-consultants-political-giving/

8850686002/. There are no publicly available tax forms from Grow United, Inc., however. See Tax Exempt 

Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited Sept. 25, 2023) (reflecting that there are no 

results when searching Grow United’s name or its EIN number identified in the Complaint, 84-2546999).

Attachment 1 

Page 14 of 33

MUR808200295
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 15 of 33

1 4. Broken Promises 

2 Broken Promises is referenced by name in Matrix’s proposal to FPL as a middleman that 

3 would receive funds and send them to conduits, including Florida Promise, that would in turn 

make political contributions.58 4 Broken Promises was incorporated on August 29, 2018, along 

with Stand Up for Justice.59 5 According to Broken Promises’s federal tax return for the 2018 

6 calendar year, it is a 501(c)(4) corporation; its purpose is to “develop[] and advocat[e] for 

7 legislation, regulations, and government programs to improve social environmental, economy 

8 and social environment”; Sean J. Anderson is its president and chairman; it did not have a 

website; and it received $200,000 of funding that year.60 9 In addition, according to news reports, 

Broken Promises reportedly received $26,000 from LPAD on July 9, 2020.61 10 

11 On July 14, 2020, five days after reportedly receiving the $26,000 from LPAD, Broken 

Promises made a $20,000 contribution to Concerned Conservatives, Inc., an IEOPC.62 12 During 

13 the 2020 election cycle, Concerned Conservatives, Inc., made independent expenditures only in 

14 Florida’s 19th Congressional District to support Dane Eagle, who unsuccessfully ran for the 

15 Republican nomination, and oppose his competitors, William Matthew Figlesthaler, Byron 

58 See Secretive Political Spending Plan, supra note 12; Compl. ¶¶ 33 Fig. 1, 52. 

59 CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023)

(searching the organization name “Broken Promises” and “Stand Up for Justice”).

60 See IRS Form 990, Broken Promises, 2018 Return of Organization Exempt from Income Tax at 1, 7 

(Nov. 15, 2019), https://apps.irs.gov/pub/epostcard/cor/831745117_201812_990O_2020012317057600.pdf

[hereinafter Broken Promises 2018 Tax Return] (reflecting an unfilled line for the organization’s website).

61 Jeff Weiner & Annie Martin, Bank Records Shed Light on Dark-Money Group in ‘Ghost’ Candidate 

Scandal, ORLANDO SENTINEL (Apr. 18, 2022), https://www.orlandosentinel.com/2022/04/18/bank-records-shedlight-on-dark-money-group-in-ghost-candidate-scandal/; see Compl. ¶ 52.

62 Concerned Conservatives, Inc., 2020 12-Day Pre-Primary Election Report at 6 (Aug. 6, 2020), 

https://docquery.fec.gov/pdf/823/202008069261263823/202008069261263823.pdf; see also Compl. ¶ 51.

Attachment 1 

Page 15 of 33

MUR808200296
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 16 of 33

Donalds, and Casey Askar.63 1 In addition, in 2018, Broken Promises made $160,470 in Florida 

2 state political contributions, and in 2019, it made $21,500 in Florida state political 

contributions.64 3 Thus, it appears that Broken Promises made at least $201,970 in political 

4 contributions during its existence. 

5 According to Broken Promises’s federal tax returns and other information received by the 

6 Commission, it received a total of $226,000 to $300,000 in funding during its existence: 

$200,000 in 2018,65 7 $50,000 or less in 2019, and $26,000 to $50,000 in 2020 before terminating 

later that year.

66 8 Broken Promises’s 2018 federal tax return also indicates that it spent $500 on 

legal expenses and $40 on management and general expenses that year.67 9 Although Broken 

10 Promises characterized spending $45,000 on lobbying and $115,470 on “other” program 

11 expenses in its 2018 federal tax return, this sum of $160,470 corresponds precisely to the dollar 

with its 2018 Florida state political contributions also totaling $160,470.68 12 Thus, Broken 

13 Promises spent at least 67% to 89% of its total funding on making political contributions.

63 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data type=processed&q spender=C00728402&is notice=false&min date=01%2F01%2F2019&max

date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting Concerned Conservatives, Inc.’s, independent 

expenditures during the 2020 election cycle); August 18, 2020 Primary Election Republican Primary, FL DEP’T OF 

STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=8/18/2020&DATA

MODE= (last visited Sept. 25, 2023) (selecting “Federal Offices” in the Republican Primary section) (reflecting that 

Dane Eagle, William Figlesthaler, Byron Donalds, and Casey Askgar were seeking the Republican nomination in 

Florida’s 19th Congressional District).

64 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and contributor last name “Broken 

Promises”).

65 Broken Promises 2018 Tax Return at 1, supra note 60. 

66 For 2019 and 2020, Broken Promises filed an IRS Form 990-N, indicating that its gross receipts were 

$50,000 or less in those years. Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited 

Sept. 25, 2023) (searching organization name “Broken Promises”). 

67 Broken Promises 2018 Tax Return at 10, supra note 60. 

68 Id.; see also Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/

campaign-finance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and contributor last name 

“Broken Promises”) (reflecting that Broken Promises made $160,470 in Florida state political contributions in 2018, 

Attachment 1 

Page 16 of 33

MUR808200297
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 17 of 33

1 According to the Miami Herald, Broken Promises’s entire $200,000 of funding in 2018 

was from FPL.69 2 Specifically, the Miami Herald claims it received an internal Matrix ledger 

3 showing how, in 2018, Matrix distributed $200,000 of funds labeled as coming from FPL to 

Broken Promises.70 4 The ledger reportedly shows that Matrix sent $100,000 of FPL funds to 

Broken Promises on September 26, 2018, and again on October 16, 2018, totaling $200,000.71 5 

6 This money was likely transmitted through other Matrix-controlled corporations before coming 

7 to Broken Promises, because federal tax records show that the Alliance for Consumer Protection 

Inc., donated $100,000 to Broken Promises in 2018.72 8 According to a news report regarding a 

9 text message between Pitts and FPL Vice President Martell, the director of the Alliance for 

Consumer Protection Inc., David Calvert, is Pitts’s former college roommate.

73 10 

11 5. Stand Up for Justice 

As discussed above, Stand Up for Justice was incorporated on August 29, 2018,74 12 the 

same day as Broken Promises, and it shared a mailing address with CAIJ.

75 13 According to its 

of which $45,000 were cash contributions and $115,470 were in-kind contributions in the forms of direct mail and 

advertising). 

69 Nicholas Nehamas & Mary Ellen Klas, DeSantis ’18 Campaign Got $25,000 From Nonprofit Secretly 

Funded by FPL Cash, Records Show, MIAMI HERALD (Sept. 9, 2022), https://www.miamiherald.com/news/politicsgovernment/state-politics/article265213541.html. 

70 Id. FPL spokesperson Reuter called the ledger “fake” and stated, “We have no record of FPL, or any 

NextEra Energy entity for that matter, ever having paid Broken Promises.” Id

71 Nightmare Scenario, supra note 10; see also Nicholas Nehamas & Mary Ellen Klas, DeSantis ’18 

Campaign Got $25,000 From Nonprofit Secretly Funded by FPL Cash, Records Show, MIAMI HERALD (Sept. 9, 

2022), https://www.miamiherald.com/news/politics-government/state-politics/article265213541.html. 

72 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095 201812 990O 20211020

19109756.pdf. 

73 Nightmare Scenario, supra note 10. 

74 CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023) 

(searching the organization names “Stand Up for Justice” and “Broken Promises”). 

75 Id. (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for Justice’s business 

address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006); American Valor PAC, 2020 

Attachment 1 

Page 17 of 33

MUR808200298
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 18 of 33

1 2018 federal tax return, Stand Up for Justice is a 501(c)(4) corporation; its purpose is to 

2 “develop[] and advocat[e] for legistlation [sic], regulations and government programs to improve 

3 social environment, economy & society”; Anderson was a director and its president; it did not 

have a website; and it received $350,000 in funding that year.76 4 

5 On March 31, 2020, Stand Up for Justice made a $50,000 contribution to South Florida 

Residents First,

77 6 an IEOPC that made independent expenditures during the 2020 election cycle 

7 only in Florida’s 26th Congressional District, which supported Republican nominee Carlos 

Gimenez and opposed Democratic nominee Debbie Mucarsel-Powell.78 8 In addition, just two 

9 months after it was incorporated, Stand Up for Justice made contributions to a Florida political 

committee in October 2018, totaling $300,000,79 10 which Stand Up for Justice characterized as 

“lobbying” on its 2018 federal tax return.80 11 Thus, it appears that Stand Up for Justice made at 

12 least $350,000 in political contributions during its existence. 

Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/202012039337569242/20201203

9337569242.pdf (reflecting that CAIJ’s address is at 2020 Pennsylvania Avenue, NW, Ste. 449, Washington DC 

20006). 

76 IRS Form 990, Stand Up for Justice, 2018 Return of Organization Exempt from Income Tax at 1-2, 7 

(Nov. 15, 2019), https://apps.irs.gov/pub/epostcard/cor/831749759_201812_990O_2020021317141891.pdf

[hereinafter Stand Up for Justice 2018 Tax Return]. 

77 South Florida Residents First, 2020 April Quarterly Report at 11 (April 13, 2020), https://docquery.fec

.gov/pdf/294/202004159216942294/202004159216942294.pdf; see also Compl. ¶ 53.

78 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00733402&is_notice=false&min_date=01%2F01%2F2019&max

_date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting South Florida Residents First’s independent 

expenditures in the 2020 election cycle); November 3, 2020 General Election, FL DEP’T OF STATE DIV. OF 

ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=11/3/2020&DATAMODE= (last visited 

Sept. 25, 2023) (selecting “Federal Offices”) (reflecting that Carlos Gimenez was the Republican nominee and 

Debbie Mucarsel-Powell was the Democratic nominee in Florida’s 26th Congressional District); see Compl. ¶ 53. 

79 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited July 25, 2023) (searching election year “all” and contributor last name starting 

with “Stand Up for Justice”).

80 Stand Up for Justice 2018 Tax Return at 10, supra note 76. 

Attachment 1 

Page 18 of 33

MUR808200299
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 19 of 33

1 According to Stand Up for Justice’s federal tax returns, it received $350,000 to $450,000 

during its existence: $350,000 in 2018,81 2 and $50,000 or less per year in each of 2019 and 2020 

before terminating.82 3 Stand Up for Justice’s federal tax returns also state that it spent $20,577 on 

legal fees and $100 on bank service charges in 2018,83 4 indicating that its total funding was at 

5 least $370,677 to cover its lifetime spending. Thus, Stand Up for Justice spent at least 78% to 

6 94% of its total funding on making political contributions.

7 Federal tax records show that Alliance for Consumer Protection Inc., contributed 

$150,000 to Stand Up for Justice in 2018.84 8 As indicated above, the Alliance for Consumer 

9 Protection Inc. also contributed $100,000 to Broken Promises in 2018, and its executive director 

is reportedly Pitts’s former college roommate.

85 10 

11 C. Let’s Preserve the American Dream, Inc., was Associated with Pitts and 

12 Matrix

13 Relying on news reports of Matrix’s proposal to FPL, which reference LPAD as a higher14 level Matrix-associated conduit that would receive funds and transmit them to other entities in 

15 Matrix’s network, and news reports indicating that LPAD made donations to Grow United and 

16 Broken Promises, the Complaint alleges that Unknown Respondents used LPAD as a middleman 

to make contributions using the names of Grow United and Broken Promises.86 17 

81 Id. at 1.

82 For 2019 and 2020, Stand Up for Justice filed an IRS Form 990-N, and indicated that its gross receipts 

were not greater than $50,000 in those years. Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/

eos/ (last visited Sept. 25, 2023) (searching organization name “Stand Up for Justice”).

83 Stand Up for Justice 2018 Tax Return at 10, supra note 76. 

84 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095_201812_990O_20211020

19109756.pdf. 

85 Id.; Nightmare Scenario, supra note 10. 

86 Compl. ¶¶ 33 Fig. 1, 35, 37, 42 Fig. 2, 45, 52; see also Secretive Political Spending Plan, supra note 12. 

Attachment 1 

Page 19 of 33

MUR808200300
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 20 of 33

1 In a deposition conducted by the Miami-Dade State Attorney’s Office regarding a former 

2 LPAD contractor’s creation of fake Florida state senate candidates, Tyson stated that he 

3 discussed LPAD’s donation to Grow United with Matrix’s former CEO, Jeff Pitts, and that it was 

4 actually Pitts who proposed for LPAD to make that donation. Specifically, Tyson testified: 

5 Well, as best as I can recall, I called [Pitts] up and I said, “Do you 

6 have any social welfare groups that are interested in working on 

7 issues that are amenable to my organizational narrative? Are they 

8 interested in supporting other interests in other committees around 

9 the country, in Florida specifically too, that would focus purely on 

the center left spectrum and on issues that are center left?”87 10 

11 According to Tyson, Pitts “said he did,” referring to Grow United, and so Tyson “said we’d be 

12 happy to support them.” 

13 In the same above-referenced deposition, Tyson also testified that he spoke with Pitts 

14 about how Grow United should use LPAD’s donation. Specifically, in response to whether 

15 Tyson knew that Alex Alvarado’s Florida state political committees received their funding from 

16 Grow United, Tyson stated, “I told you earlier I knew it came from Grow United. There was a 

17 story about it. And I knew, I actually told Grow United that Alvarado would probably call them 

and ask, raise money.”88 18 Tyson further explained that the person he spoke with was Jeff Pitts. 

19 According to text messages obtained by the Orlando Sentinel, on September 24, 2020, just five 

20 days prior to LPAD making its first $600,000 donation to Grow United on September 29, 2020, 

21 Tyson communicated with Pitts and Abigail MacIver, another former Matrix employee, 

regarding the Florida state senate races that the Alvarado committees were seeking to impact.89 22 

87 Tyson testified in response to the question, “So give me your best recollection of the content of the 

conversation that you had with Jeff Pitts that caused you to want to send the money to Grow United.”

88 Emphasis was added to the original transcription.

89 FPL Execs, supra note 43. 

Attachment 1 

Page 20 of 33

MUR808200301
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 21 of 33

1 When further queried as to whether Tyson “did not authorize the money, the $600,000 

2 [from LPAD], to go to Grow United so they can then turn around and send it to Alex Alvarado’s 

3 two political campaigns,” Tyson testified that he “can’t tell [Grow United] how to spend their 

4 money” and that he “do[es]n’t have the ability to restrain how they spend their funds.” However, 

5 when asked, “Did you know when this $600,000 [from LPAD] was sent to Grow United, that it 

6 was going to [⸺] that 550,000 of it was going to go to Alex Alvarado’s two political 

7 committees,” Tyson testified that he “had a hunch” that Grow United would be supportive of the 

8 Alvarado committees and that he was “not testifying it’s a coincidence.” Tyson further stated, “I 

9 knew [Grow United] would likely be supportive, but I also didn’t know when, I mean, we made 

10 other contributions to them as well. We were supporting a lot of what they were doing.” Tyson 

11 then testified that he “assume[d] [Grow United would] probably be supported [sic] if Alex 

12 called, but I had no way to know if they actually would. Because once I make a contribution to 

13 an entity, I lose control of how they spend that money.” 

14 D. SUN Marketing & Advertising LLC Appears to be Associated with Matrix

15 SUN Marketing & Advertising LLC is another conduit identified in Matrix’s proposal to 

FPL,

90 16 and it appears to have been created by Matrix after the memo was circulated. 

17 Specifically, SUN was formed on December 13, 2019, about two weeks after Pitts reportedly 

emailed the above-referenced proposal to Silagy on November 26, 2019.91 18 FPL spokesman 

19 Reuter reportedly confirmed that FPL gave $250,000 to SUN in December 2019, but stated that 

20 the purpose was to purchase advertising related to a proposed constitutional amendment that FPL 

90 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 32 Fig. 1.

91 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “SUN Marketing & Advertising”). 

Attachment 1 

Page 21 of 33

MUR808200302
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 22 of 33

opposed.92 According to Reuter, FPL believes that SUN is owned by Matrix.93 1 News reports 

indicate that SUN was used to create favorable press for FPL.94 2 SUN’s former sole member, 

Tim Fitzpatrick, was a former FPL officer.95 3 

4 III. LEGAL ANALYSIS

5 A. The Commission Finds Reason to Believe that the 2020 Contributions 

6 Reported as Having Been Made By the Alleged Conduit Corporations Were 

7 Contributions Made In the Name of Another

8 The Act and the Commission’s regulations prohibit a person from (1) making a 

9 contribution in the name of another person, (2) knowingly permitting his or her name to be used 

to effect such a contribution, and (3) knowingly accepting such a contribution.96 10 The term 

11 “person” in this context includes partnerships, corporations, and “any other organization or group 

of persons.”97 12 In its regulations, the Commission has illustrated examples of activities that 

13 constitute making a contribution in the name of another, as follows: 

14 (i) Giving money or anything of value, all or part of which was 

15 provided to the contributor by another person (the true contributor) 

16 without disclosing the source of money or the thing of value to the 

17 recipient candidate or committee at the time the contribution is 

18 made; or

92 Secretive Political Spending Plan, supra note 12. 

93 Id.

94 Sarah Blaskey, Powerbrokers: How FPL Secretly Took Over a Florida News Site and Used It to Bash 

Critics, MIAMI HERALD (Aug. 13, 2022), https://www.miamiherald.com/article263757423.html. 

95 PG&E Names Tim Fitzpatrick As Vice President And Chief Communications Officer, CISION PR

NEWSWIRE (Mar. 11, 2013), https://www.prnewswire.com/news-releases/pge-names-tim-fitzpatrick-as-vicepresident-and-chief-communications-officer-197098061.html (“Fitzpatrick joined NextEra Energy in January 2008, 

serving as Vice President of Marketing and Corporate Communications and as an officer of Florida Power & Light 

Company (FPL).”).

96 52 U.S.C. § 30122; see also 11 C.F.R. § 110.4(b).

97 52 U.S.C. § 30101(11); 11 C.F.R. § 100.10.

Attachment 1 

Page 22 of 33

MUR808200303
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 23 of 33

1 (ii) Making a contribution of money or anything of value and 

2 attributing as the source of the money or thing of value another 

person when in fact the contributor is the source.98 3 

4 Because a primary purpose of the Act’s disclosure provisions is to reveal the true source from 

5 which a contribution to a candidate or committee originates, regardless of the mechanism by 

which the funds are transmitted,99 6 the Commission examines the structure of the transaction 

7 itself and the arrangement between the parties to determine who in fact “made” a given 

contribution.100 8 

9 In prior matters, the Commission has found reason to believe that a contribution was 

10 made in the name of another where the available information indicates that another person 

11 provided the funds for the purpose of making the contribution and his or her identity was not 

disclosed to the recipient committee or candidate at the time of the contribution.

101 12 Absent direct 

13 evidence as to the purpose of providing the funds, the Commission considers the overall record

14 to determine its purpose. In the context of contributions made by limited liability companies 

15 (“LLCs”), the Commission has addressed whether the LLC “had the means to make the 

16 contribution absent an infusion of funds provided for that purpose,” the “temporal proximity 

98 11 C.F.R. § 110.4(b)(2)(i)-(ii).

99 See Campaign Legal Ctr. v. FEC, 952 F.3d 352, 354 (D.C. Cir. 2020) (“As the Supreme Court has 

repeatedly declared, the electorate has an interest in knowing where political campaign money comes from and how 

it is spent by the candidate. To that end, the [Act] imposes disclosure requirements on those who give and spend 

money to influence elections. The straw donor provision, 52 U.S.C. § 30122, is designed to ensure accurate 

disclosure of contributor information.”) (internal citations and quotation marks omitted). 

100 Cf. 11 C.F.R. § 110.6(a) (“All contributions by a person made on behalf of or to a candidate, including 

contributions which are in any way earmarked or otherwise directed to the candidate through an intermediary or 

conduit, are contributions from the person to the candidate.”).

101 See, e.g., Factual and Legal Analysis (“F&LA”) at 5, MUR 7903 (Tomfoolery, LLC, et al.) (“[T]he 

contributions made in Tomfoolery’s name were, in fact, actually made by Thomas A. Chavez, when Chavez 

furnished Tomfoolery with funds for the purpose of having the LLC make the contributions.”); F&LA at 1-2, 

MUR 6920 (American Conservative Union) (finding reason to believe that the contribution was made in the name of 

another where the organization who was reported as the contributor later indicated that it was not the true source of 

the contribution, and instead merely delivered the contribution upon receipt of the funds from another person); see 

also 11 C.F.R. § 110.4(b)(2)(i)-(ii).

Attachment 1 

Page 23 of 33

MUR808200304
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 24 of 33

1 between the LLC’s formation date and the contribution,” “the amount of the contribution relative 

2 to [the LLC’s] other activities, the LLC’s known activities prior to making the contribution, and 

3 whether any other information suggests an attempt to circumvent the Act’s disclosure 

4 requirements.” 

5 Here, the available information indicates that the five 2020 political contributions 

6 purportedly made by the alleged Conduit Corporations — Florida Promise, Broken Promises, 

7 Grow United, CAIJ, and Stand Up for Justice — were actually made on behalf of Unknown 

8 Respondents. The overall record indicates that there was plan whose purpose was “to 

9 circumvent the Act’s disclosure requirements” by using the names of the Conduit Corporations 

10 to make contributions and that this plan was implemented in largely the way the blueprint set 

11 out. In addition, the overall record of the Conduit Corporations’ known activities indicate that 

12 they may have been formed for the purpose of making conduit contributions. 

13 Specifically, news articles indicate that, during the 2020 election cycle, Matrix invited 

14 FPL to anonymize its political activities by funneling money through several layers of conduits, 

15 including Florida Promise and Broken Promises, and then using those funds to make federal and 

state political contributions.

102 16 The articles report that Jeff Pitts, former CEO of Matrix, emailed

17 Eric Silagy, former CEO of FPL, a “‘funding memo’” with goals such as making “federal 

18 campaign contributions” and “‘minimiz[ing] all public reporting of entities and activities,’” and a 

“‘legal memo on federal elections support.’”103 19 According to the Orlando Sentinel, the funding 

20 memo included a flowchart depicting FPL’s funds flowing through several layers of conduits 

21 controlled by Pitts and Matrix, including Florida Promise and Broken Promises, before being 

102 Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 3, 31-38. 

103 Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 3, 31-32. 

Attachment 1 

Page 24 of 33

MUR808200305
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 25 of 33

contributed to federal and state political committees.104 1 While the specific plan reported by the 

2 news articles did not directly identify CAIJ, Grow United, or Stand Up for Justice, the proposal 

3 establishes the preexisting idea of making conduit contributions with entities just like these, 

4 which as discussed below, was ultimately carried out using the five alleged Conduit 

5 Corporations. 

6 News articles stated that the sources of the documents were from Matrix itself, noting 

that the documents were internal Matrix documents.105 7 FPL’s spokesperson, David Reuter, 

8 reportedly confirmed that the proposal as reported was indeed shared with its CEO, stating, “‘We 

9 are aware of the proposed structure as the legal memo was shared with us, and as we understand 

10 it, Joe Perkins’[s] team at Matrix created a proposal to fund their clients’ communication and 

outreach activities during 2020.’”106 11 Thus, there is no available information indicating that the 

12 news articles’ report that Pitts and Matrix created and shared a proposal to anonymize political 

13 contributions was inaccurate or not credible. 

14 Moreover, the available information does not indicate that the proposal was limited to 

15 acting solely within the legal bounds of minimizing public reporting of political activities. 

16 Specifically, the proposal did not indicate that Pitts and Matrix were soliciting funds from FPL 

17 on behalf of nonprofit corporations that would independently decide to make political 

18 contributions. Rather, the proposal indicated that funds would flow from FPL, through several 

19 layers of conduits controlled or associated with Matrix, before landing at “Florida Promise C4,” 

104 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

105 See Secretive Political Spending Plan, supra note 12 (stating that the Orlando Sentinel received records 

“includ[ing] checks, bank statements, emails, text messages, invoices, internal ledgers and more, all apparently 

unearthed during an internal investigation Matrix launched after its former employees left the firm at the end of 

2020.”).

106 Id.

Attachment 1 

Page 25 of 33

MUR808200306
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 26 of 33

1 “US Promise C4” and “Fed Promise C4,” which would also be controlled by Matrix, to make 

contributions to state and federal political committees.107 2 

3 Notably, there is no available information indicating that Pitts or Matrix presented the 

4 purposes or goals of the conduits referenced in its flowchart, besides being able to making 

5 political contributions, to explain why FPL’s funds would be expected to flow from one 

corporation to another.108 6 There is also no available information indicating that Pitts and Matrix 

7 presented any information as to why “Florida Promise C4,” “US Promise C4” and “Fed Promise 

8 C4,” would be expected to engage in political activity that FPL would support. Instead, Pitts’s 

9 and Matrix’s flowchart simply noted “Matrix” in a parenthetical below the names of “Broken 

10 Promises,” “Florida Promise C4,” “US Promise C4” and “Fed Promise C4,” similar to how 

11 Tyson, the executive director of LPAD, was included in a parenthetical under LPAD, suggesting 

that these entities are controlled by “Matrix,” similar to how Tyson controlled LPAD.109 12 

13 Moreover, the conduits depicted on the flowchart appear to have been in fact controlled 

14 by or associated with Matrix. Of the conduits mentioned, only Florida Promise, Broken 

15 Promises, LPAD, and SUN existed or eventually came into existence, and they all have ties to 

16 Pitts and/or Matrix. As explained above, Richard Alexander was the chairman of Florida 

Promise, and his sister, April Odom, was a Matrix contractor at the time of the allegations.110 17 

107 Id.; see also Compl. ¶¶ 33 Fig. 1, 36-37. 

108 See Secretive Political Spending Plan, supra note 12 (noting that, for example, “Florida Promise C4” would 

“allowed to spend 50% of revenues on political activities” and that “Florida PCs are allowed to take unlimited funds 

from C4s”); see also Compl. ¶ 33 Fig. 1 (same).

109 See Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1. While the term “person” 

appears in the parenthetical next to SUN, SUN had not yet been formed when Pitts sent the memo, and thus this

denotation appears to suggest that they were looking for a “person” to be in control of SUN at that time. See 

Secretive Political Spending Plan, supra note 12 (reporting that Pitts sent the memo to Silagy on November 26, 

2019).

110 Florida Promise 2018 Tax Return at 3, supra note 32; Dark Money Playbook, supra note 7 (reporting that 

April Odom is Anderson’s sister and was a former Matrix employee).

Attachment 1 

Page 26 of 33

MUR808200307
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 27 of 33

1 Sean J. Anderson, who was the president and chairman of Broken Promises, was also a former 

2 Matrix employee, a close friend of Pitts, and has a history of allowing Pitts to control the 

nonprofits that he purportedly ran.

111 3 Tyson, the executive director of LPAD, reportedly 

4 associated with Pitts and Abigail MacIver, another former Matrix employee, as they 

communicated via text messages regarding Florida state senate races.112 5 Finally, as for SUN ⸺

6 FPL, which reportedly gave $250,000 to SUN in December 2019, states that it believes that SUN 

is owned by Matrix.113 7 Thus, the layers of corporations depicted on the flowchart appear to be 

8 linked together because they are controlled by persons associated with Pitts or Matrix.

9 The available information also indicates that Pitts’s and Matrix’s proposal included the 

10 making of federal political contributions. According to news articles, Pitts’s email to Silagy 

11 included a “‘funding memo’” noting making “federal campaign contributions” as one of its 

goals.114 12 Pitts’s email to Silagy also included “‘a separate legal memo on federal elections 

13 support’” explaining that “a nonprofit might have to disclose its donors if it spent money directly 

14 supporting a candidate” but that “the nonprofit would not have to disclose its donors if it gave 

money to a type of political action committee known as a ‘Super PAC,’”115 15 which is a colloquial 

reference to federal independent expenditure-only committees.116 16 Moreover, this legal memo 

111 Broken Promises, 2018 Tax Return at 1, 7, supra note 60; Bachelor Party, supra note 10 (reporting Pitts as 

having attended Anderson’s bachelor party); Nightmare Scenario, supra note 10 (reporting that Pitts texted FPL 

Vice President Martell that Anderson was an old friend of his and that he was “‘in control 100 percent’” of the 

nonprofits purportedly run by Mr. Anderson).

112 FPL Execs, supra note 43. 

113 Secretive Political Spending Plan, supra note 12. 

114 Id.; see also Compl. ¶ 32.

115 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 38.

116 See McCutcheon v. FEC, 572 U.S. 185, 193 (2014) (“A so-called ‘Super PAC’ is a PAC that makes only 

independent expenditures and cannot contribute to candidates. The base and aggregate limits govern contributions 

to traditional PACs, but not to independent expenditure PACs.”).

Attachment 1 

Page 27 of 33

MUR808200308
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 28 of 33

1 appears to provide the missing explanation as to the purpose of providing funds to the “Fed 

2 Promise C4” entity in the funding memo’s flowchart, indicating that this purpose would be to 

make federal political contributions.117 3 The name, “Fed Promise C4,” also suggests that this 

4 conduit would be used to make federal political contributions, as this would be consistent with 

5 and parallel to the flowchart’s statements that “Florida Promise C4” would be used to fund 

6 “Florida PCs” and that “US Promise C4” would be used to fund other state-level political 

activities.118 7 Thus, the available information indicates that the Pitts/Matrix proposal included 

8 making federal political contributions. 

9 The available information also indicates that the alleged Conduit Corporations received 

10 funds with the direction that they be used for federal contribution purposes as federal courts have 

11 stated that a donor’s intent can be inferred from the donee’s solicitations. Specifically, in the 

12 context of interpreting 52 U.S.C. § 30104(c)(1) of the Act, which courts have held to require notpolitical committees to disclose donations received for political purposes,119 13 a district court in 

14 Wisconsin observed that “whether a contribution is earmarked for political purposes and tied to 

15 an election can depend on whether the contribution is received in response to a solicitation and 

the way the solicitation is worded.”120 16 As explained above, Pitts’s and Matrix’s proposal clearly 

17 implicated the making of federal contributions, and the alleged Conduit Corporations appear to 

18 have received donations in response to that proposal.

19 In addition to conceiving of and sharing the plan, Pitts and Matrix were also in a position 

117 See Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1 (noting that it was 

“[w]aiting on lawyers” to explain the purpose of Fed Promise C4).

118 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

119 Citizens for Resp. & Ethics in Washington v. FEC, 316 F. Supp. 3d 349, 389 (D.D.C. 2018), aff’d, 971 F.3d 

340 (D.C. Cir. 2020).

120 Wisconsin Fam. Action v. FEC, No. 21-C-1373, 2022 WL 844436, at *11 (E.D. Wis. Mar. 22, 2022). 

Attachment 1 

Page 28 of 33

MUR808200309
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 29 of 33

1 to carry it out using the names of alleged Conduit Corporations to make the contributions. As 

2 discussed above, the persons nominally in charge of the alleged Conduit Corporations, 

3 Alexander and Anderson, had close relationships with Pitts and Matrix. Alexander, who served 

4 as a director or officer of Florida Promise, CAIJ, and Grow United, is apparently the brother of 

5 April Odom, who was a Matrix contractor at the time of the contributions and worked on matters 

relating to CAIJ and Grow United on behalf of Matrix.121 6 Anderson, who was the chairman and 

7 president of Broken Promises and a director and president of Stand Up for Justice, was also 

former Matrix employee, and a close friend of Pitts.122 8 Pitts and Matrix also has a history of 

9 working with Anderson’s nonprofit corporations, as Pitts reportedly texted FPL Vice President 

10 Daniel Martell in 2016, four years prior to the contributions at issue here, “‘Bottom line is we are 

11 the ones with the check books and in control 100 percent’” of the nonprofits purportedly run by 

Anderson.123 12 

13 Pitts and Matrix also reportedly used the names of CAIJ and Grow United in other 

operations,124 and had access to CAIJ’s and Grow United’s bank accounts,125 14 further indicating 

15 that they had control over these corporations. Specifically, news reports indicate that, in October 

121 Dark Money Playbook, supra note 7 (reporting that April Odom is Anderson’s sister and was a former 

Matrix contractor); see also Compl. ¶¶ 13, 48.

122 Bachelor Party, supra note 10 (reporting Pitts as having attended Anderson’s bachelor party); Nightmare 

Scenario, supra note 10 (reporting that Pitts texted FPL Vice President Martell that Anderson was an old friend of 

his); see also Compl. ¶¶ 16, 52.

123 Nightmare Scenario, supra note 10; see also Compl. ¶¶ 16, 52. 

124 FPL Execs, supra note 43 (reporting that Matrix made a conduit contribution using CAIJ’s name on behalf 

of FPL); Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/ (reporting that Matrix offered a city councilman 

a job on behalf of FPL using Grow United’s name).

125 Dark Money Playbook, supra note 7 (reporting that internal Matrix records included a text message from

Odom stating that she procured access to the bank accounts of CAIJ and Grow United). 

Attachment 1 

Page 29 of 33

MUR808200310
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 30 of 33

2018, Pitts used CAIJ to make a contribution to House Majority PAC on behalf of Matrix.126 1 

2 News reports also indicate that in the summer of 2019, Matrix used Grow United to offer a job to 

a Jacksonville City Council member on behalf of FPL.127 3 In addition, according to the Orlando 

4 Sentinel, it received internal Matrix documents reflecting a September 23, 2020 text message 

from Odom stating that she procured access to CAIJ’s and Grow United’s bank accounts.128 5 

6 Finally, Tyson, the executive director of LPAD who donated $1,150,000 of LPAD funds to 

7 Grow United, testified that he understood that Pitts created and ran Grow United. Therefore, not 

8 only did Pitts and Matrix conceive of a plan for the making of conduit contributions, they also 

9 had sufficient control over the alleged Conduit Corporations to cause them to permit their names 

10 to be used to make contributions on behalf of Unknown Respondents. 

11 Although all five of the alleged Conduit Corporations were formed more than a year prior 

12 to making the contributions, the overall record of their known activities indicate that they were 

13 formed for the purpose of making conduit contributions. The only available information as to 

14 the five alleged Conduit Corporations’ activities was that they made federal and Florida state 

political contributions.129 15 Broken Promises and Stand Up for Justice spent at least 67% to 89% 

126 FPL Execs, see supra note 43 (reporting that Silagy, former CEO of FPL, emailed Pitts, former CEO of 

Matrix, to make a contribution to House Majority PAC to support Lauren Baer, and to make sure that “they don’t 

triangulate this donation to others we have done”); see also House Majority PAC, 2018 Amended 12-Day PreElection Report at 655 (Dec. 3, 2018), https://docquery.fec.gov/pdf/085/201812069135107085/20181206913510

7085.pdf (reflecting CAIJ’s contribution to House Majority PAC on October 16, 2018).

127 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/. FPL reportedly confirmed that Matrix 

employees came up with an idea to offer the City Council member a job, but that it rejected the idea. Id. 

128 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right-hand corner 

of the article’s sixth picture); see also Compl. ¶ 48.

129 Although Matrix reportedly used Grow United to offer a job to a Jacksonville council member, that never 

came to fruition as the council member rejected the offer. Nate Monroe, Amid JEA Privatization Controversy, a 

City Council Member Received a Mysterious Job Offer. A Dark-Money Group May Have Been Behind It, THE FL

Attachment 1 

Page 30 of 33

MUR808200311
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 31 of 33

1 and 78% to 94%, respectively, of their total funding on making federal and Florida state political 

2 contributions, indicating that they were created for the primary purpose of making political 

contributions.130 3 Moreover, consistent with the Pitts’s and Matrix’s proposal, federal tax records 

4 show that their funding was first transmitted through another Matrix-associated conduit, the 

5 Alliance for Consumer Protection Inc., which was reportedly controlled by Pitts’s former college 

roommate.131 6 While the available information does not indicate the total funding received by 

7 Florida Promise, CAIJ, or Grow United, the only known activities by these corporations are that 

they made an aggregate of $3,224,500 in federal and Florida state political contributions.132 8 

9 In addition, only Florida Promise, Broken Promises, and Stand Up for Justice appeared to 

10 have filed federal tax returns, and these returns do not indicate that they engaged in any activity 

other than making political contributions, including through lobbying.133 11 The purpose 

12 statements in these tax returns indicate that Florida Promise, Broken Promises, and Stand Up for 

13 Justice were formed for political purposes, further suggesting they only engaged in political 

TIMES-UNION (Sept. 2, 2022), https://www.jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-salejacksonville-city-council-member-mysterious-job-offer-dark-money-group-nate-monroe/8850689002/. 

130 See supra pages 15-16, 18-19.

131 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095_201812_990O_20211020

19109756.pdf; Nightmare Scenario, supra note 10. 

132 See supra notes 33-34 and accompanying text (reflecting that Florida Promise made $1,230,000 in federal 

and Florida state contributions); supra notes 38, 40, 38 and accompanying text (reflecting that CAIJ made $432,000 

in federal and Florida state contributions); supra notes 46, 49 and accompanying text (reflecting that Grow United 

made $1,562,500 in federal and Florida state contributions).

133 See generally Florida Promise 2018 Tax Return, supra note 32; Broken Promises 2018 Tax Return, supra

note 60; Stand Up for Justice 2018 Tax Return, supra note 76. As indicated above, while Broken Promises and 

Stand Up for Justice indicated in their 2018 federal tax returns that they spent funding on “lobbying” and “other”

program expenses in 2018, the amounts they reportedly spent correspond to the same amounts that they spent on 

making Florida state political contributions. See supra pages 16, 18. 

Attachment 1 

Page 31 of 33

MUR808200312
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 32 of 33

activities.

134 1 

2 Furthermore, there are various organizational aspects of the alleged Conduit Corporations 

3 that suggest they were formed to serve as conduits. Specifically, despite the fact that CAIJ and 

4 Stand Up for Justice were incorporated in different states and do not share any officers, both 

entities reported having the same mailing address in Washington, D.C.135 5 In addition, despite 

6 both Broken Promises and Stand Up for Justice having the same three officers and nearly 

7 identical mission statements, both entities were incorporated on the same day in the same 

state.136 8 Finally, Broken Promises’s federal tax return suggests that it was trying to conceal that 

9 it made political contributions. Specifically, Broken Promises characterized on its 2018 federal 

10 tax return that it spent $115,470 on “other” program service expenses, when that amount was 

actually used to make in-kind contributions to Florida state committees.137 11 Thus, the available 

12 information as to the activities, stated purpose, and creation of the Conduit Corporations suggests 

13 that they were created for making conduit contributions. 

134 Florida Promise 2018 Tax Return at 6, supra note 32 (stating that its purpose is to “develop and advocate 

for legislation, regulations, and government programs related to policies to benefit Floridians”); Broken Promises 

2018 Tax Return at 2, supra note 60 (stating that its purpose is to “develop[] and advocat[e] for legislation, 

regulations, and government programs to improve social environmental, economy and social environment”); Stand 

Up for Justice 2018 Tax Return at 2, supra note 76 (stating that its purpose is to “develop[] and advocat[e] for 

legistlation [sic], regulations, and government programs to improve social environment, economy & society”).

135 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting that CAIJ’s address was at 2020 Pennsylvania Avenue, 

NW, Ste. 449, Washington DC 20006); CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing

(last visited Sept. 25, 2023) (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for 

Justice’s business address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006). 

136 See CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023) 

(searching the organization names “Broken Promises” and “Stand Up For Justice”) (reflecting that both Broken 

Promises and Stand Up for Justice were incorporated on August 29, 2018); Broken Promises 2018 Tax Return at 1,

7, supra note 60; Stand Up for Justice 2018 Tax Return at 1, 7, supra note 76. 

137 Compare Broken Promises 2018 Tax Return at 10, supra note 60 (stating that it spent $115,470 in “other” 

program service expenses), with Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.

myflorida.com/campaign-finance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and 

contributor last name “Broken Promises”) (reflecting that Broken Promises Broken Promises made $115,470 in inkind Florida state political contributions in 2018).

Attachment 1 

Page 32 of 33

MUR808200313
MUR 8082 (Unknown Respondents) 

Factual and Legal Analysis

Page 33 of 33

1 In sum, the available information indicates that there was a plan to illegally disguise or 

2 withhold public reporting of political activities, and that this plan included making contributions 

3 through conduits and in a manner that closely matches what the available information shows had 

4 subsequently occurred. In addition, pursuant to this plan, the alleged Conduit Corporations 

5 permitted their names to be used to make federal political contributions on behalf of Unknown 

6 Respondents. Finally, the only known activities of the alleged Conduit Corporations were that 

7 they made federal and Florida state political contributions, indicating that their purpose was to 

8 serve as conduits. Thus, the Commission finds reason to believe that Unknown Respondents, 

9 which are likely Pitts and/or Matrix clients, violated 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b) 

10 by making contributions in the name of another. 

Attachment 1 

Page 33 of 33

MUR808200314
1 FEDERAL ELECTION COMMISSION

2 FACTUAL AND LEGAL ANALYSIS

3 RESPONDENT: Florida Promise, Inc. MUR 8082 

4 I. INTRODUCTION

5 The Complaint alleges that Unknown Respondents made contributions in the name of 

6 another through a network of conduits associated with a political consulting firm called Matrix 

LLC (“Matrix”), to five federal independent expenditure-only political committees (“IEOPCs”).

1 7 

8 The specific contributions identified in the Complaint are as follows: 

9 • a $1,000,000 contribution reportedly from Florida Promise, Inc. (“Florida Promise”)

to Senate Leadership Fund, dated December 8, 2020;2 10 

11 • a $100,000 contribution reportedly from the Center for Advancement of Integrity and

Justice, Inc. (“CAIJ”) to American Valor PAC, dated October 27, 2020;3 12 

13 • a $100,000 contribution reportedly from Grow United, Inc. (“Grow United”) to

Conservative Action Fund (f/k/a Wingman PAC), also dated October 27, 2020;4 14 

15 • a $20,000 contribution reportedly from Broken Promises to Concerned

Conservatives, Inc., dated July 14, 2020;5 16 and

17 • a $50,000 contribution reportedly from Stand Up for Justice to South Florida

Residents First, dated March 31, 2020.6 18 

1 Compl. ¶¶ 2, 5, 27, 42, 89-93 (Oct. 27, 2022).

2 Senate Leadership Fund, Amended 2020 Year End Report at 72 (Mar. 18, 2021), https://docquery.fec.gov/

pdf/807/202103189441299807/202103189441299807.pdf; see also Compl. ¶¶ 49-50.

3

 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/2020

12039337569242/202012039337569242.pdf; see also Compl. ¶¶ 47-48.

4

 Wingman PAC, 2020 30-Day Post Election Report at 1, 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting a $100,000 contribution from Grow United, Inc., on 

October 27, 2020, and the committee’s FEC identification number of C00742296); Conservative Action Fund, 

Amended Statement of Organization at 1 (May 20, 2022), https://docquery.fec.gov/pdf/048/202205209512421048/

202205209512421048.pdf (reflecting that its name has changed to Conservative Action Fund and that its FEC 

identification number is C00742296); see also Compl. ¶¶ 43-44.

5 Concerned Conservatives, Inc., 2020 12-Day Pre-Primary Election Report at 6 (Aug. 6, 2020), https://doc

query.fec.gov/pdf/823/202008069261263823/202008069261263823.pdf; see also Compl. ¶¶ 51-52.

6

 South Florida Residents First, 2020 April Quarterly Report at 11 (Apr. 13, 2020), https://docquery.fec.gov/

pdf/294/202004159216942294/202004159216942294.pdf; see also Compl. ¶¶ 53-54.

Attachment 2 

Page 1 of 33

MUR808200315
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 2 of 33

1 The Complaint relies on news articles regarding a 2019 email and two accompanying 

2 memoranda sent from Jeff Pitts, Matrix’s former CEO, to Eric Silagy, Florida Power & Light 

3 Company’s (FPL) former CEO, reportedly proposing a method for FPL to make anonymous 

4 contributions to federal and state political committees by transferring funds through multiple 

levels of conduits.7 5 The proposal called for funds to be first sent to and passed through higher6 level Matrix-associated conduits, including SUN Marketing & Advertising LLC (“SUN”) and 

7 Let’s Preserve the American Dream, Inc. (“LPAD”), before being sent to various lower-level 

8 Matrix-controlled conduits, including Florida Promise, that would be reported as the source of 

9 the contributions. Thus, the Complaint alleges that each of the five alleged lower-level Matrix10 controlled conduits (referred to herein as the “Conduit Corporations”) permitted their names to 

11 be used to effect contributions in the name of another pursuant to Pitts’s and Matrix’s proposal. 

12 To support its central allegation, the Complaint alleges that all five of the alleged Conduit 

13 Corporations had ties to Pitts or Matrix through having either Richard Alexander or Sean J. 

Anderson as a director or officer.

8 14 Citing news articles, the Complaint alleges that Alexander’s 

sister was a Matrix contractor at the time of the allegations9 15 and that Anderson was a former 

Matrix employee and a good friend of Pitts.10 16 

7

 Compl. ¶¶ 3-4, 28-41; see, e.g., Jason Garcia & Annie Martin, Florida’s Dark Money Playbook: How 

‘Ghost’ Candidate Scheme Revealed Secretive Political Tactics, ORLANDO SENTINEL (Dec. 30, 2021), 

https://www.orlandosentinel.com/news/os-ne-dark-money-ghost-candidates-tactics-20211230-7zelkoadffclde3z

76ax3cgx3m-htmlstory.html [hereinafter Dark Money Playbook].

8

 Compl. ¶¶ 13, 16. 

9

 Id. ¶ 13; see Dark Money Playbook, supra note 7 (reporting that Alexander’s sister, April Odom, was a 

Matrix employee at the time of the allegations, and that she worked on matters relating to Grow United and CAIJ).

10 Compl ¶ 16; see John Archibald, Archibald: ‘Bachelor party’ Makes For Strange Bedfellows, AL.COM

(Nov. 14, 2010), https://www.al.com/archiblog/2010/11/archibald bachelor party makes.html [hereinafter 

“Bachelor Party”] (reporting that Pitts attended Anderson’s bachelor party and that they were both employed by 

Matrix at the time); Mary Ellen Klas, et al., ‘Nightmare Scenario’: How FPL Secretly Manipulated a Florida State 

Senate Election, MIAMI HERALD (Aug. 29, 2022), https://www.miamiherald.com/news/politics-government/statepolitics/article264196761.html [hereinafter “Nightmare Scenario”] (reporting that Pitts texted FPL vice president 

Attachment 2 

Page 2 of 33

MUR808200316
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 3 of 33

1 As discussed below, the five contributions purportedly made by the alleged Conduit 

2 Corporations as identified by the Complaint appear to be consistent with the conduit 

3 contributions proposed by Pitts and Matrix to FPL to anonymize its political contributions. In 

4 addition, all five of the alleged Conduit Corporations appear to be controlled by or associated 

5 with Pitts and Matrix. Accordingly, the Commission finds reason to believe that Florida 

6 Promise, Inc., violated 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b) by knowingly permitting its 

7 name to be used to effect contributions in the name of another. 

8 II. FACTUAL BACKGROUND

9 A. Jeff Pitts of Matrix Appears to Have Created a Plan to Anonymize Federal 

10 Political Contributions Using a Network of Conduits Controlled by or 

11 Associated with Pitts or Matrix 

Matrix is a “strategic communications firm” based in Alabama.11 12 According to the 

13 Orlando Sentinel, it received a cache of internal documents from Matrix, “includ[ing] checks, 

14 bank statements, emails, text messages, invoices, internal ledgers and more, all apparently 

15 unearthed during an internal investigation Matrix launched after its former employees left the 

firm at the end of 2020.”12 16 These internal records included a copy of a November 26, 2019 

17 email sent from former Matrix CEO, Jeff Pitts, to former FPL CEO, Eric Silagy, stating, 

18 “‘Attached is an updated funding memo along with a separate legal memo on federal elections 

support.’”13 19 The “funding memo” noted goals such as making “federal campaign contributions” 

Daniel Martell that Anderson was an old friend of his and that Pitts was in control of the nonprofits run by 

Anderson).

11 Matrix, LLC, v. Canopy Partners, LLC, et al, 2021 WL 3127729 (Ala. Cir. Ct.).

12 Jason Garcia & Annie Martin, Operative Pitched Secretive Political Spending Plan to FPL Exec’s Email 

Alias, Records Reveal, ORLANDO SENTINEL (Jan. 24, 2022), https://www.orlandosentinel.com/politics/os-ne-floridapower-and-light-matrix-dark-money-20211217-v64274eytjeb5hnstdognvqds4-story.html [hereinafter “Secretive 

Political Spending Plan”]. 

13 Id.; see also Compl. ¶¶ 3, 31-38.

Attachment 2 

Page 3 of 33

MUR808200317
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 4 of 33

and “‘minimiz[ing] all public reporting of entities and activities.’”14 1 It also included a flowchart

2 depicting money flowing from FPL through a network of conduits before being contributed to 

federal and state political committees, as reproduced below:15 3 

14 See Secretive Political Spending Plan, supra note 12; Compl. ¶ 32.

15 See Secretive Political Spending Plan, supra note 12; Compl. ¶ 33 Fig. 1.

Attachment 2 

Page 4 of 33

MUR808200318
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 5 of 33

1 Notably, next to or below the name of each conduit is a parenthetical, which may indicate the 

2 person or entity controlling or associating with that conduit. Specifically, the flowchart 

3 identifies a “LPAD C4 (Tyson),” which appears to refer to LPAD and its executive director Ryan 

Tyson.16 4 The flowchart also identifies “Matrix/Foley” in a parenthetical next to or below the 

16 See Compl. ¶ 35.

Attachment 2 

Page 5 of 33

MUR808200319
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 6 of 33

1 names of the following conduits: “Broken Promises,” “Florida Promise C4,” “US Promise C4,” 

2 and “Fed Promise C4,” suggesting that these conduits are directly associated with and/or 

controlled by Matrix and its legal counsel, Foley and Lardner, LLP (“Foley”).17 3 

4 According to the flowchart, money could flow to a “Florida Promise C4,” which could 

5 “spend 50% of revenues on political activities” due to its tax status as a section 501(c)(4) 

6 corporation, and be used to contribute to Florida state political committees on the basis that 

“Florida PCs are allowed to take unlimited funds from C4s.”18 7 Money could also flow to a “US 

8 Promise C4,” which similarly could “spend 50% of revenues on political activities” due to its tax 

9 status, and be used to contribute to other states’ political committees on the basis that “[e]ach 

state operates under unique state elections.”19 10 Lastly, the flowchart indicates that money could 

11 flow to a “Fed Promise C4,” but because Matrix was “[w]aiting on lawyers,” it could not state

the purpose of this proposed funding.20 12 

13 The legal memo attached to the email, which was drafted by Foley attorney Erika Alba, 

addressed “the legalities of using nonprofits to spend money on federal elections.”21 14 The memo 

15 states that “a nonprofit might have to disclose its donors if it spent money directly supporting a 

16 candidate,” but that “the nonprofit would not have to disclose its donors if it gave money to a 

17 type of political committee known as a “‘Super PAC’” (i.e., an IEOPC) “that then spent money 

supporting the candidate.”22 18 The legal memo then concluded: “‘Thus, it could be strategic for a 

17 See Secretive Political Spending Plan, supra note 12 (noting that Erika Alba of Foley & Lardner LLP 

drafted a legal memo attached to the email); see also Compl. ¶ 38 (alleging the same). 

18 Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 33 Fig. 1, 37.

19 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

20 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

21 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 38.

22 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 38.

Attachment 2 

Page 6 of 33

MUR808200320
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 7 of 33

[nonprofit] who wishes to make Independent Expenditures to do so via a Super PAC.’”23 1 

2 Based on the record of contributions disclosed by the recipient IEOPCs and news articles 

3 reporting that LPAD provided funding to Grow United and Broken Promises, the Complaint 

depicts the implementation of the Matrix plan as taking the following altered form:24 4 

5 

6 The Complaint alleges that Matrix pitched the above-referenced plan to Unknown 

7 Respondent clients, noting that FPL’s spokesperson, David Reuter, stated, “‘We are aware of the 

8 proposed structure as the legal memo was shared with us, and as we understand it, Joe 

23 Secretive Political Spending Plan, supra note 12 (alteration in original); see also Compl. ¶ 38.

24 Compl. ¶¶ 42 Fig. 2, 45, 52.

Attachment 2 

Page 7 of 33

MUR808200321
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 8 of 33

1 Perkins’[s] team at Matrix created a proposal to fund their clients’ communication and outreach 

activities during 2020.’”25 2 

3 B. The Alleged Conduit Corporations Appear to Have Been Controlled by or 

4 Associated with Pitts and/or Matrix 

5 The Complaint alleges that five alleged Conduit Corporations, Florida Promise, CAIJ, 

6 Grow United, Broken Promises, and Stand Up for Justice, permitted their names to effect the 

7 $1.27 million in contributions that they purportedly made to IEOPCs on behalf of Unknown 

Respondents.26 8 Richard Alexander served as a director or officer of the first three alleged 

9 Conduit Corporations, while Sean J. Anderson was a director or officer of the latter two. 

10 According to news reports, both Alexander and Anderson had close ties to Matrix. 

11 Alexander’s sister, April Odom, was a Matrix contractor at the time of the allegations and 

12 reportedly worked on behalf of Matrix regarding CAIJ and Grow United, which were entities 

associated with Alexander.

27 13 Anderson, on the other hand, was a former Matrix employee, and 

reportedly a close friend of Pitts. 28 14 Anderson also has a history of working with Pitts, as Pitts 

15 reportedly texted FPL Vice President Daniel Martell in 2016, four years prior to the alleged 

16 contributions, as follows: “‘Bottom line is we are the ones with the check books and in control 

100 percent’” of the nonprofits purportedly run by Anderson.29 17 The discussion below sets out 

18 the available information about each of the alleged Conduit Corporations and their relationships 

19 with Pitts and/or Matrix.

25 Secretive Political Spending Plan, supra note 12 (emphasis added); Compl. ¶ 40 (emphasis added). 

26 Compl. ¶¶ 5, 43-54.

27 Dark Money Playbook, supra note 7 (reporting that April Odom is Anderson’s sister and was a former 

Matrix employee); see also Compl. ¶¶ 13, 48.

28 Bachelor Party, supra note 10; Nightmare Scenario, supra note 10 (reporting that Pitts texted FPL Vice 

President Martell that Anderson was an old friend of his); see also Compl. ¶ 16.

29 Nightmare Scenario, supra note 10; see also Compl. ¶ 16. 

Attachment 2 

Page 8 of 33

MUR808200322
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 9 of 33

1 1. Florida Promise, Inc. 

2 Florida Promise is a corporation identified in Matrix’s proposal to FPL that could be used 

as a conduit to make contributions to Florida political committees,

30 3 and it was incorporated on 

December 18, 2018.31 4 According to Florida Promise’s 2018 federal tax return, it is a 501(c)(4) 

5 corporation; its mission is to “develop and advocate for legislation, regulations, and government 

6 programs related to policies to benefit Floridians”; Alexander was its chairman; it did not have a 

website; and it did not have any expenses or revenue that year.32 7 

8 On December 8, 2020, Florida Promise made a $1,000,000 contribution to the Senate 

Leadership Fund.33 9 In addition, consistent with Matrix’s proposal to use Florida Promise to

10 make Florida political contributions, Florida Promise also made contributions to Florida political 

committees on June 12, 2019, and January 27, 2021, totaling $230,000.34 11 Other than making the 

12 $1,230,000 in federal and Florida state political contributions, there is no publicly available 

13 information regarding Florida Promise’s activities. 

30 See Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 33 Fig. 1, 50. 

31 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Florida Promise”); see also Compl. ¶ 12.

32 IRS Form 990-EZ, Florida Promise, Inc., 2018 Short Form Return of Organization Exempt from Income 

Tax at 2-3, 6 (Nov. 13, 2019), https://apps.irs.gov/pub/epostcard/cor/832961305_201812_990EO_202006011716

8825.pdf [hereinafter Florida Promise 2018 Tax Return]. 

33 Senate Leadership Fund, Amended 2020 Year End Report at 72 (Mar. 18, 2021), https://docquery.fec.gov/

pdf/807/202103189441299807/202103189441299807.pdf; see also Compl. ¶ 49. 

34 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (searching “all” election years with contributor’s last name 

starting with “Florida Promise”); see also Compl. ¶ 50.

Attachment 2 

Page 9 of 33

MUR808200323
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 10 of 33

1 2. Center for Advancement of Integrity and Justice, Inc. 

CAIJ was incorporated on October 1, 2018,35 2 and shared a mailing address with Stand Up 

for Justice.36 There are no publicly available CAIJ federal tax returns.37 3 Alexander served as 

4 either a director or officer of CAIJ.

On October 27, 2020, CAIJ made a $100,000 contribution to American Valor PAC,38 5 an 

6 IEOPC that made independent expenditures during the 2020 election cycle solely in Florida’s

7 13th Congressional District, which supported Anna Paulina Luna, the Republican nominee, and 

opposed Charlie Joseph Crist, the Democratic nominee.39 8 CAIJ also made contributions to 

9 Florida political committees totaling $307,000, starting in November 2018 and through 

December 2020.

40 10 

35 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Center for Advancement of Integrity and 

Justice”); see also Compl. ¶ 11.

36 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting that CAIJ’s address was at 2020 Pennsylvania Avenue, 

NW, Ste. 449, Washington DC 20006); CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing

(last visited Sept. 25, 2023) (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for 

Justice’s business address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006). 

37 On May 15, 2021, the IRS automatically revoked CAIJ’s 501(c)(4) status for not filing a Form 990s-series 

return for three consecutive years, suggesting that CAIJ has not filed any tax returns. See Tax Exempt Organization 

Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited July 25, 2023) (searching the organization name “center 

for advancement of integrity” which reflect that CAIJ’s federal tax exempt status was automatically revoked on May 

15, 2021for not filing a Form 990-series return or notice for three consecutive years).

38 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf; see also Compl. ¶ 47. 

39 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00757179&is_notice=false&most_recent=true (last visited 

Aug. 18, 2023) (reflecting independent expenditures made by American Valor PAC); November 3, 2020 General 

Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=

11/3/2020&DATAMODE= (last visited Sept. 25, 2023) (selecting “Federal Offices”) (reflecting that Anna Luna 

was the Republican nominee and that Charlie Crist was the Democratic nominee in Florida’s 13th Congressional 

District).

40 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited July 25, 2023) (searching “all” election years with contributor’s last name starting 

with “center for advancement”).

Attachment 2 

Page 10 of 33

MUR808200324
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 11 of 33

1 While CAIJ was not referenced by name in Matrix’s proposal to FPL, news reports 

2 suggest that it was controlled by Matrix. Specifically, Matrix’s internal files reportedly include a 

3 September 23, 2020 text message from Odom, Alexander’s sister and a Matrix contractor at the 

time of the allegations, stating that she procured access to CAIJ’s bank account.41 4 In addition, 

5 on October 16, 2018, just 15 days after CAIJ’s incorporation, CAIJ made a $25,000 contribution 

to House Majority PAC.42 6 According to news reports, FPL directed Matrix to make this 

7 contribution on its behalf to support Lauren Baer, who was seeking election in Florida’s 18th 

8 Congressional District, and asked Matrix to ensure that House Majority PAC “‘do[es]n’t 

triangulate this donation to others we have done.’”43 9 Other than making the $432,000 in federal 

10 and Florida state political contributions, there is no publicly available information regarding 

11 CAIJ’s activities. 

41 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right-hand corner 

of the article’s sixth picture); see also Compl. ¶ 48.

42 House Majority PAC, 2018 Amended 12-Day Pre-Election Report at 655 (Dec. 3, 2018), https://docquery

.fec.gov/pdf/085/201812069135107085/201812069135107085.pdf. 

43 Jason Garcia & Annie Martin, Florida Power & Light Execs Worked Closely with Consultants Behind 

‘Ghost’ Candidate Scheme, Records Reveal, ORLANDO SENTINEL (Apr. 14, 2022), https://www.orlandosentinel.com/

politics/os-ne-florida-power-and-light-senate-ghost-candidates-20211202-szjhv7ox6vcmphm6pgd437y52i-htmlstory

.html [hereinafter “FPL Execs”] (reporting that Silagy forwarded Pitts instructions to make a contribution to House 

Majority PAC to support Lauren Baer and to make sure that “they don’t triangulate this donation to others we have 

done”); November 6, 2018 General Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.my

florida.com/Index.asp?ElectionDate=11/6/2018&DATAMODE= (last visited Sept. 25, 2023) (reflecting that Lauren 

Baer was the democratic nominee in Florida’s 18th Congressional District). 

Attachment 2 

Page 11 of 33

MUR808200325
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 12 of 33

1 3. Grow United, Inc. 

Grow United was incorporated on July 24, 2019.44 2 There are no publicly available Grow 

3 United federal tax records and it did not identify itself as a nonprofit organization to the Internal 

Revenue Service.

45 4 Alexander served either as a director or officer of Grow United. 

On October 27, 2020, Grow United made a $100,000 contribution to Wingman PAC,46 5 

now known as the Conservative Action Fund.47 6 Wingman PAC made independent expenditures 

7 during the 2020 election cycle solely in Florida’s 15th Congressional District, which supported 

8 Scott Franklin, the Republican nominee; opposed Alan Michael Cohn, the Democratic nominee; 

9 and opposed Vincent Spano Ross, who competed against Franklin for the Republican 

44 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Grow United”). 

45 See Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited Sept. 25, 2023)

(reflecting that there are no results when searching Grow United’s name or its EIN number identified in the 

Complaint, 84-2546999). 

46 Wingman PAC, 2020 30-Day Post Election Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/423/

202012039338666423/202012039338666423.pdf (reflecting a $100,000 contribution from Grow United on October 

27, 2020).

47 Id. at 1(reflecting an FEC identification number of C00742296); Conservative Action Fund, Amended 

Statement of Organization at 1 (May 20, 2022), https://docquery.fec.gov/pdf/048/202205209512421048/2022

05209512421048.pdf (reflecting that its name has changed to Conservative Action Fund and its FEC identification 

number is C00742296). 

Attachment 2 

Page 12 of 33

MUR808200326
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 13 of 33

nomination.48 1 Earlier that month, from October 3, 2020, through October 20, 2020, Grow 

United made contributions to Florida state political committees totaling $1,462,500.49 2 

3 Grow United appears to have been created and controlled by Pitts and Matrix. Ryan 

4 Tyson, the executive director of LPAD — which contributed $1,150,000 to Grow United in 

202050 5 — was deposed by the Miami-Dade State Attorney’s Office in a criminal matter 

6 regarding a former LPAD contractor’s creation of fake Florida state senate candidates during the 

7 2020 election cycle. Tyson testified in the deposition that he understood that Jeff Pitts started 

8 and ran Grow United. In addition, FPL reportedly asserted that Grow United was created by 

Matrix.51 9 

10 Matrix’s internal records also reportedly indicate that it had control of Grow United. 

11 According to news reports, Matrix’s internal ledger reflect an August 7, 2019 entry billed to FPL 

12 for “‘Grow United SOS Fees,’” which likely referred to the fees charged by the Delaware 

48 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00742296&is_notice=false&min_date=01%2F01%2F2019&max

_date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting Wingman PAC’s independent expenditures in the 

2020 election cycle); November 3, 2020 General Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results

.elections.myflorida.com/Index.asp?ElectionDate=11/3/2020&DATAMODE= (last visited Sept. 25, 2023) 

(selecting “Federal Offices”) (reflecting that Scott Franklin was the Republican nominee and Alan Cohn was the 

Democratic nominee in Florida’s 15th Congressional District); August 18, 2020 Primary Election Republican 

Primary, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate

=8/18/2020&DATAMODE= (last visited Sept. 25, 2023) (selecting “Federal Offices” in the Republican Primary 

section) (reflecting that both Scott Franklin and Ross Spano were seeking the Republican nomination in Florida’s 

15th Congressional District).

49 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (selecting election year “all” and searching contributor last name 

starting with “grow united”); see also Compl. ¶ 46.

50 See Compl. ¶ 45.

51 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Dec. 10, 2021, updated Sept. 2, 

2022), https://www.jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-citycouncil-member-mysterious-job-offer-dark-money-group-nate-monroe/8850689002/. Joe Perkins, owner of Matrix, 

denies that Matrix created Grow United, and Perkins’s attorney asserts that “[t]o the extent any rogue Matrix 

employees were involved in those activities, they were undertaken in secret, without Dr. Perkins’[s] knowledge or 

consent.” Id.

Attachment 2 

Page 13 of 33

MUR808200327
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 14 of 33

Secretary of State for incorporating Grow United a few weeks prior.

52 1 Matrix’s internal records 

2 also reportedly include a September 23, 2020 message from Odom stating that she procured 

access to Grow United’s bank account.53 3 In addition, as part of her duties at Matrix, Odom 

4 reportedly sent checks from Grow United to make contributions to Florida committees, asked the 

committees to confirm their receipt of the checks,54 5 and emailed a $12,813.54 invoice to Matrix

6 with the subject line, “FPL Expenses for Grow United c4,” for expenses that included traveling 

to Colorado to update the nonprofit’s mailbox at a UPS Store in Denver.55 7 

8 News articles also report that, in the summer of 2019, Matrix used Grow United to offer a 

job to a Jacksonville City Councilmember on behalf of FPL.56 9 Furthermore, Foley attorney 

10 Erika Alba reportedly billed Matrix in the fall of 2020 for her work on IRS submission forms for 

Grow United.57 11 Other than making the $1,562,500 in political contributions, there is no publicly 

12 available information regarding Grow United’s activities.

52 FPL Execs, supra note 43. 

53 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right corner of the 

article’s sixth picture); see also Compl. ¶ 48.

54 Dark Money Playbook, supra note 7. 

55 FPL Execs, supra note 43. 

56 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/. FPL reportedly confirmed that Matrix 

employees came up with an idea to offer the City Council member a job, but that it rejected the idea. Id. 

57 Nate Monroe, Law Firm that Advised on Botched JEA Sale Also Helped Former FPL Consultants On 

Dark-Money Projects, FL TIMES-UNION (Dec. 17, 2021), https://www.jacksonville.com/story/news/columns/natemonroe/2021/12/17/jea-privatization-law-firm-foley-lardner-also-helped-former-fpl-consultants-political-giving/

8850686002/. There are no publicly available tax forms from Grow United, Inc., however. See Tax Exempt 

Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited Sept. 25, 2023) (reflecting that there are no 

results when searching Grow United’s name or its EIN number identified in the Complaint, 84-2546999).

Attachment 2 

Page 14 of 33

MUR808200328
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 15 of 33

1 4. Broken Promises 

2 Broken Promises is referenced by name in Matrix’s proposal to FPL as a middleman that 

3 would receive funds and send them to conduits, including Florida Promise, that would in turn 

make political contributions.58 4 Broken Promises was incorporated on August 29, 2018, along 

with Stand Up for Justice.59 5 According to Broken Promises’s federal tax return for the 2018 

6 calendar year, it is a 501(c)(4) corporation; its purpose is to “develop[] and advocat[e] for 

7 legislation, regulations, and government programs to improve social environmental, economy 

8 and social environment”; Sean J. Anderson is its president and chairman; it did not have a 

website; and it received $200,000 of funding that year.60 9 In addition, according to news reports, 

Broken Promises reportedly received $26,000 from LPAD on July 9, 2020.61 10 

11 On July 14, 2020, five days after reportedly receiving the $26,000 from LPAD, Broken 

Promises made a $20,000 contribution to Concerned Conservatives, Inc., an IEOPC.62 12 During 

13 the 2020 election cycle, Concerned Conservatives, Inc., made independent expenditures only in 

14 Florida’s 19th Congressional District to support Dane Eagle, who unsuccessfully ran for the 

15 Republican nomination, and oppose his competitors, William Matthew Figlesthaler, Byron 

58 See Secretive Political Spending Plan, supra note 12; Compl. ¶¶ 33 Fig. 1, 52. 

59 CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023)

(searching the organization name “Broken Promises” and “Stand Up for Justice”).

60 See IRS Form 990, Broken Promises, 2018 Return of Organization Exempt from Income Tax at 1, 7 

(Nov. 15, 2019), https://apps.irs.gov/pub/epostcard/cor/831745117_201812_990O_2020012317057600.pdf

[hereinafter Broken Promises 2018 Tax Return] (reflecting an unfilled line for the organization’s website).

61 Jeff Weiner & Annie Martin, Bank Records Shed Light on Dark-Money Group in ‘Ghost’ Candidate 

Scandal, ORLANDO SENTINEL (Apr. 18, 2022), https://www.orlandosentinel.com/2022/04/18/bank-records-shedlight-on-dark-money-group-in-ghost-candidate-scandal/; see Compl. ¶ 52.

62 Concerned Conservatives, Inc., 2020 12-Day Pre-Primary Election Report at 6 (Aug. 6, 2020), 

https://docquery.fec.gov/pdf/823/202008069261263823/202008069261263823.pdf; see also Compl. ¶ 51.

Attachment 2 

Page 15 of 33

MUR808200329
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 16 of 33

Donalds, and Casey Askar.63 1 In addition, in 2018, Broken Promises made $160,470 in Florida 

2 state political contributions, and in 2019, it made $21,500 in Florida state political 

contributions.64 3 Thus, it appears that Broken Promises made at least $201,970 in political 

4 contributions during its existence. 

5 According to Broken Promises’s federal tax returns and other information received by the 

6 Commission, it received a total of $226,000 to $300,000 in funding during its existence: 

$200,000 in 2018,65 7 $50,000 or less in 2019, and $26,000 to $50,000 in 2020 before terminating 

later that year.

66 8 Broken Promises’s 2018 federal tax return also indicates that it spent $500 on 

legal expenses and $40 on management and general expenses that year.67 9 Although Broken 

10 Promises characterized spending $45,000 on lobbying and $115,470 on “other” program 

11 expenses in its 2018 federal tax return, this sum of $160,470 corresponds precisely to the dollar 

with its 2018 Florida state political contributions also totaling $160,470.68 12 Thus, Broken 

13 Promises spent at least 67% to 89% of its total funding on making political contributions.

63 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data type=processed&q spender=C00728402&is notice=false&min date=01%2F01%2F2019&max

date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting Concerned Conservatives, Inc.’s, independent 

expenditures during the 2020 election cycle); August 18, 2020 Primary Election Republican Primary, FL DEP’T OF 

STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=8/18/2020&DATA

MODE= (last visited Sept. 25, 2023) (selecting “Federal Offices” in the Republican Primary section) (reflecting that 

Dane Eagle, William Figlesthaler, Byron Donalds, and Casey Askgar were seeking the Republican nomination in 

Florida’s 19th Congressional District).

64 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and contributor last name “Broken 

Promises”).

65 Broken Promises 2018 Tax Return at 1, supra note 60. 

66 For 2019 and 2020, Broken Promises filed an IRS Form 990-N, indicating that its gross receipts were 

$50,000 or less in those years. Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited 

Sept. 25, 2023) (searching organization name “Broken Promises”). 

67 Broken Promises 2018 Tax Return at 10, supra note 60. 

68 Id.; see also Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/

campaign-finance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and contributor last name 

“Broken Promises”) (reflecting that Broken Promises made $160,470 in Florida state political contributions in 2018, 

Attachment 2 

Page 16 of 33

MUR808200330
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 17 of 33

1 According to the Miami Herald, Broken Promises’s entire $200,000 of funding in 2018 

was from FPL.69 2 Specifically, the Miami Herald claims it received an internal Matrix ledger 

3 showing how, in 2018, Matrix distributed $200,000 of funds labeled as coming from FPL to 

Broken Promises.70 4 The ledger reportedly shows that Matrix sent $100,000 of FPL funds to 

Broken Promises on September 26, 2018, and again on October 16, 2018, totaling $200,000.71 5 

6 This money was likely transmitted through other Matrix-controlled corporations before coming 

7 to Broken Promises, because federal tax records show that the Alliance for Consumer Protection 

Inc., donated $100,000 to Broken Promises in 2018.72 8 According to a news report regarding a 

9 text message between Pitts and FPL Vice President Martell, the director of the Alliance for 

Consumer Protection Inc., David Calvert, is Pitts’s former college roommate.

73 10 

11 5. Stand Up for Justice 

As discussed above, Stand Up for Justice was incorporated on August 29, 2018,74 12 the 

same day as Broken Promises, and it shared a mailing address with CAIJ.

75 13 According to its 

of which $45,000 were cash contributions and $115,470 were in-kind contributions in the forms of direct mail and 

advertising).

69 Nicholas Nehamas & Mary Ellen Klas, DeSantis ’18 Campaign Got $25,000 From Nonprofit Secretly 

Funded by FPL Cash, Records Show, MIAMI HERALD (Sept. 9, 2022), https://www.miamiherald.com/news/politicsgovernment/state-politics/article265213541.html. 

70 Id. FPL spokesperson Reuter called the ledger “fake” and stated, “We have no record of FPL, or any 

NextEra Energy entity for that matter, ever having paid Broken Promises.” Id

71 Nightmare Scenario, supra note 10; see also Nicholas Nehamas & Mary Ellen Klas, DeSantis ’18 

Campaign Got $25,000 From Nonprofit Secretly Funded by FPL Cash, Records Show, MIAMI HERALD (Sept. 9, 

2022), https://www.miamiherald.com/news/politics-government/state-politics/article265213541.html. 

72 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095 201812 990O 20211020

19109756.pdf. 

73 Nightmare Scenario, supra note 10. 

74 CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023) 

(searching the organization names “Stand Up for Justice” and “Broken Promises”). 

75 Id. (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for Justice’s business 

address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006); American Valor PAC, 2020 

Attachment 2 

Page 17 of 33

MUR808200331
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 18 of 33

1 2018 federal tax return, Stand Up for Justice is a 501(c)(4) corporation; its purpose is to 

2 “develop[] and advocat[e] for legistlation [sic], regulations and government programs to improve 

3 social environment, economy & society”; Anderson was a director and its president; it did not 

have a website; and it received $350,000 in funding that year.76 4 

5 On March 31, 2020, Stand Up for Justice made a $50,000 contribution to South Florida 

Residents First,

77 6 an IEOPC that made independent expenditures during the 2020 election cycle 

7 only in Florida’s 26th Congressional District, which supported Republican nominee Carlos 

Gimenez and opposed Democratic nominee Debbie Mucarsel-Powell.78 8 In addition, just two 

9 months after it was incorporated, Stand Up for Justice made contributions to a Florida political 

committee in October 2018, totaling $300,000,79 10 which Stand Up for Justice characterized as 

“lobbying” on its 2018 federal tax return.80 11 Thus, it appears that Stand Up for Justice made at 

12 least $350,000 in political contributions during its existence. 

Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/202012039337569242/20201203

9337569242.pdf (reflecting that CAIJ’s address is at 2020 Pennsylvania Avenue, NW, Ste. 449, Washington DC 

20006). 

76 IRS Form 990, Stand Up for Justice, 2018 Return of Organization Exempt from Income Tax at 1-2, 7 

(Nov. 15, 2019), https://apps.irs.gov/pub/epostcard/cor/831749759_201812_990O_2020021317141891.pdf

[hereinafter Stand Up for Justice 2018 Tax Return]. 

77 South Florida Residents First, 2020 April Quarterly Report at 11 (April 13, 2020), https://docquery.fec

.gov/pdf/294/202004159216942294/202004159216942294.pdf; see also Compl. ¶ 53.

78 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00733402&is_notice=false&min_date=01%2F01%2F2019&max

_date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting South Florida Residents First’s independent 

expenditures in the 2020 election cycle); November 3, 2020 General Election, FL DEP’T OF STATE DIV. OF 

ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=11/3/2020&DATAMODE= (last visited 

Sept. 25, 2023) (selecting “Federal Offices”) (reflecting that Carlos Gimenez was the Republican nominee and

Debbie Mucarsel-Powell was the Democratic nominee in Florida’s 26th Congressional District); see Compl. ¶ 53. 

79 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited July 25, 2023) (searching election year “all” and contributor last name starting 

with “Stand Up for Justice”).

80 Stand Up for Justice 2018 Tax Return at 10, supra note 76. 

Attachment 2 

Page 18 of 33

MUR808200332
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 19 of 33

1 According to Stand Up for Justice’s federal tax returns, it received $350,000 to $450,000 

during its existence: $350,000 in 2018,81 2 and $50,000 or less per year in each of 2019 and 2020 

before terminating.82 3 Stand Up for Justice’s federal tax returns also state that it spent $20,577 on 

legal fees and $100 on bank service charges in 2018,83 4 indicating that its total funding was at 

5 least $370,677 to cover its lifetime spending. Thus, Stand Up for Justice spent at least 78% to 

6 94% of its total funding on making political contributions.

7 Federal tax records show that Alliance for Consumer Protection Inc., contributed 

$150,000 to Stand Up for Justice in 2018.84 8 As indicated above, the Alliance for Consumer 

9 Protection Inc. also contributed $100,000 to Broken Promises in 2018, and its executive director 

is reportedly Pitts’s former college roommate.

85 10 

11 C. Let’s Preserve the American Dream, Inc., was Associated with Pitts and 

12 Matrix

13 Relying on news reports of Matrix’s proposal to FPL, which reference LPAD as a higher14 level Matrix-associated conduit that would receive funds and transmit them to other entities in 

15 Matrix’s network, and news reports indicating that LPAD made donations to Grow United and 

16 Broken Promises, the Complaint alleges that Unknown Respondents used LPAD as a middleman 

to make contributions using the names of Grow United and Broken Promises.86 17 

81 Id. at 1.

82 For 2019 and 2020, Stand Up for Justice filed an IRS Form 990-N, and indicated that its gross receipts 

were not greater than $50,000 in those years. Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/

eos/ (last visited Sept. 25, 2023) (searching organization name “Stand Up for Justice”).

83 Stand Up for Justice 2018 Tax Return at 10, supra note 76. 

84 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095_201812_990O_20211020

19109756.pdf. 

85 Id.; Nightmare Scenario, supra note 10. 

86 Compl. ¶¶ 33 Fig. 1, 35, 37, 42 Fig. 2, 45, 52; see also Secretive Political Spending Plan, supra note 12. 

Attachment 2 

Page 19 of 33

MUR808200333
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 20 of 33

1 In a deposition conducted by the Miami-Dade State Attorney’s Office regarding a former 

2 LPAD contractor’s creation of fake Florida state senate candidates, Tyson stated that he 

3 discussed LPAD’s donation to Grow United with Matrix’s former CEO, Jeff Pitts, and that it was 

4 actually Pitts who proposed for LPAD to make that donation. Specifically, Tyson testified: 

5 Well, as best as I can recall, I called [Pitts] up and I said, “Do you 

6 have any social welfare groups that are interested in working on 

7 issues that are amenable to my organizational narrative? Are they 

8 interested in supporting other interests in other committees around 

9 the country, in Florida specifically too, that would focus purely on 

the center left spectrum and on issues that are center left?”87 10 

11 According to Tyson, Pitts “said he did,” referring to Grow United, and so Tyson “said we’d be 

12 happy to support them.” 

13 In the same above-referenced deposition, Tyson also testified that he spoke with Pitts 

14 about how Grow United should use LPAD’s donation. Specifically, in response to whether 

15 Tyson knew that Alex Alvarado’s Florida state political committees received their funding from 

16 Grow United, Tyson stated, “I told you earlier I knew it came from Grow United. There was a 

17 story about it. And I knew, I actually told Grow United that Alvarado would probably call them 

and ask, raise money.”88 18 Tyson further explained that the person he spoke with was Jeff Pitts. 

19 According to text messages obtained by the Orlando Sentinel, on September 24, 2020, just five 

20 days prior to LPAD making its first $600,000 donation to Grow United on September 29, 2020, 

21 Tyson communicated with Pitts and Abigail MacIver, another former Matrix employee, 

regarding the Florida state senate races that the Alvarado committees were seeking to impact.89 22 

87 Tyson testified in response to the question, “So give me your best recollection of the content of the 

conversation that you had with Jeff Pitts that caused you to want to send the money to Grow United.”

88 Emphasis was added to the original transcription.

89 FPL Execs, supra note 43. 

Attachment 2 

Page 20 of 33

MUR808200334
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 21 of 33

1 When further queried as to whether Tyson “did not authorize the money, the $600,000 

2 [from LPAD], to go to Grow United so they can then turn around and send it to Alex Alvarado’s 

3 two political campaigns,” Tyson testified that he “can’t tell [Grow United] how to spend their 

4 money” and that he “do[es]n’t have the ability to restrain how they spend their funds.” However, 

5 when asked, “Did you know when this $600,000 [from LPAD] was sent to Grow United, that it 

6 was going to [⸺] that 550,000 of it was going to go to Alex Alvarado’s two political 

7 committees,” Tyson testified that he “had a hunch” that Grow United would be supportive of the 

8 Alvarado committees and that he was “not testifying it’s a coincidence.” Tyson further stated, “I 

9 knew [Grow United] would likely be supportive, but I also didn’t know when, I mean, we made 

10 other contributions to them as well. We were supporting a lot of what they were doing.” Tyson 

11 then testified that he “assume[d] [Grow United would] probably be supported [sic] if Alex 

12 called, but I had no way to know if they actually would. Because once I make a contribution to 

13 an entity, I lose control of how they spend that money.” 

14 D. SUN Marketing & Advertising LLC Appears to be Associated with Matrix

15 SUN Marketing & Advertising LLC is another conduit identified in Matrix’s proposal to 

FPL,

90 16 and it appears to have been created by Matrix after the memo was circulated. 

17 Specifically, SUN was formed on December 13, 2019, about two weeks after Pitts reportedly 

emailed the above-referenced proposal to Silagy on November 26, 2019.91 18 FPL spokesman 

19 Reuter reportedly confirmed that FPL gave $250,000 to SUN in December 2019, but stated that 

20 the purpose was to purchase advertising related to a proposed constitutional amendment that FPL 

90 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 32 Fig. 1.

91 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “SUN Marketing & Advertising”). 

Attachment 2 

Page 21 of 33

MUR808200335
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 22 of 33

opposed.92 According to Reuter, FPL believes that SUN is owned by Matrix.93 1 News reports 

indicate that SUN was used to create favorable press for FPL.94 2 SUN’s former sole member, 

Tim Fitzpatrick, was a former FPL officer.95 3 

4 III. LEGAL ANALYSIS

5 A. The Commission Finds Reason to Believe that the $1,000,000 Contribution 

6 Reported as Having Been Made by Florida Promise, Inc., Was a 

7 Contribution Made In the Name of Another

8 The Act and the Commission’s regulations prohibit a person from (1) making a 

9 contribution in the name of another person, (2) knowingly permitting his or her name to be used 

to effect such a contribution, and (3) knowingly accepting such a contribution.96 10 The term 

11 “person” in this context includes partnerships, corporations, and “any other organization or group 

of persons.”97 12 In its regulations, the Commission has illustrated examples of activities that 

13 constitute making a contribution in the name of another, as follows: 

14 (i) Giving money or anything of value, all or part of which was 

15 provided to the contributor by another person (the true contributor) 

16 without disclosing the source of money or the thing of value to the 

17 recipient candidate or committee at the time the contribution is 

18 made; or

92 Secretive Political Spending Plan, supra note 12. 

93 Id.

94 Sarah Blaskey, Powerbrokers: How FPL Secretly Took Over a Florida News Site and Used It to Bash 

Critics, MIAMI HERALD (Aug. 13, 2022), https://www.miamiherald.com/article263757423.html. 

95 PG&E Names Tim Fitzpatrick As Vice President And Chief Communications Officer, CISION PR

NEWSWIRE (Mar. 11, 2013), https://www.prnewswire.com/news-releases/pge-names-tim-fitzpatrick-as-vicepresident-and-chief-communications-officer-197098061.html (“Fitzpatrick joined NextEra Energy in January 2008, 

serving as Vice President of Marketing and Corporate Communications and as an officer of Florida Power & Light 

Company (FPL).”).

96 52 U.S.C. § 30122; see also 11 C.F.R. § 110.4(b).

97 52 U.S.C. § 30101(11); 11 C.F.R. § 100.10.

Attachment 2 

Page 22 of 33

MUR808200336
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 23 of 33

1 (ii) Making a contribution of money or anything of value and 

2 attributing as the source of the money or thing of value another 

person when in fact the contributor is the source.98 3 

4 Because a primary purpose of the Act’s disclosure provisions is to reveal the true source from 

5 which a contribution to a candidate or committee originates, regardless of the mechanism by 

which the funds are transmitted,99 6 the Commission examines the structure of the transaction 

7 itself and the arrangement between the parties to determine who in fact “made” a given 

contribution.100 8 

9 In prior matters, the Commission has found reason to believe that a contribution was 

10 made in the name of another where the available information indicates that another person 

11 provided the funds for the purpose of making the contribution and his or her identity was not 

disclosed to the recipient committee or candidate at the time of the contribution.

101 12 Absent direct 

13 evidence as to the purpose of providing the funds, the Commission considers the overall record

14 to determine its purpose. In the context of contributions made by limited liability companies 

15 (“LLCs”), the Commission has addressed whether the LLC “had the means to make the 

16 contribution absent an infusion of funds provided for that purpose,” the “temporal proximity 

98 11 C.F.R. § 110.4(b)(2)(i)-(ii).

99 See Campaign Legal Ctr. v. FEC, 952 F.3d 352, 354 (D.C. Cir. 2020) (“As the Supreme Court has 

repeatedly declared, the electorate has an interest in knowing where political campaign money comes from and how 

it is spent by the candidate. To that end, the [Act] imposes disclosure requirements on those who give and spend 

money to influence elections. The straw donor provision, 52 U.S.C. § 30122, is designed to ensure accurate 

disclosure of contributor information.”) (internal citations and quotation marks omitted). 

100 Cf. 11 C.F.R. § 110.6(a) (“All contributions by a person made on behalf of or to a candidate, including 

contributions which are in any way earmarked or otherwise directed to the candidate through an intermediary or 

conduit, are contributions from the person to the candidate.”).

101 See, e.g., Factual and Legal Analysis (“F&LA”) at 5, MUR 7903 (Tomfoolery, LLC, et al.) (“[T]he 

contributions made in Tomfoolery’s name were, in fact, actually made by Thomas A. Chavez, when Chavez 

furnished Tomfoolery with funds for the purpose of having the LLC make the contributions.”); F&LA at 1-2, 

MUR 6920 (American Conservative Union) (finding reason to believe that the contribution was made in the name of 

another where the organization who was reported as the contributor later indicated that it was not the true source of 

the contribution, and instead merely delivered the contribution upon receipt of the funds from another person); see 

also 11 C.F.R. § 110.4(b)(2)(i)-(ii).

Attachment 2 

Page 23 of 33

MUR808200337
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 24 of 33

1 between the LLC’s formation date and the contribution,” “the amount of the contribution relative 

2 to [the LLC’s] other activities, the LLC’s known activities prior to making the contribution, and 

3 whether any other information suggests an attempt to circumvent the Act’s disclosure 

4 requirements.” 

5 Here, the available information indicates that the five 2020 political contributions 

6 purportedly made by the alleged Conduit Corporations — Florida Promise, Broken Promises, 

7 Grow United, CAIJ, and Stand Up for Justice — were actually made on behalf of Unknown 

8 Respondents. The overall record indicates that there was plan whose purpose was “to 

9 circumvent the Act’s disclosure requirements” by using the names of the Conduit Corporations 

10 to make contributions and that this plan was implemented in largely the way the blueprint set 

11 out. In addition, the overall record of the Conduit Corporations’ known activities indicate that 

12 they may have been formed for the purpose of making conduit contributions. 

13 Specifically, news articles indicate that, during the 2020 election cycle, Matrix invited 

14 FPL to anonymize its political activities by funneling money through several layers of conduits, 

15 including Florida Promise and Broken Promises, and then using those funds to make federal and 

state political contributions.

102 16 The articles report that Jeff Pitts, former CEO of Matrix, emailed

17 Eric Silagy, former CEO of FPL, a “‘funding memo’” with goals such as making “federal 

18 campaign contributions” and “‘minimiz[ing] all public reporting of entities and activities,’” and a 

“‘legal memo on federal elections support.’”103 19 According to the Orlando Sentinel, the funding 

20 memo included a flowchart depicting FPL’s funds flowing through several layers of conduits 

21 controlled by Pitts and Matrix, including Florida Promise and Broken Promises, before being 

102 Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 3, 31-38. 

103 Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 3, 31-32. 

Attachment 2 

Page 24 of 33

MUR808200338
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 25 of 33

contributed to federal and state political committees.104 1 While the specific plan reported by the 

2 news articles did not directly identify CAIJ, Grow United, or Stand Up for Justice, the proposal 

3 establishes the preexisting idea of making conduit contributions with entities just like these, 

4 which as discussed below, was ultimately carried out using the five alleged Conduit 

5 Corporations. 

6 News articles stated that the sources of the documents were from Matrix itself, noting 

that the documents were internal Matrix documents.105 7 FPL’s spokesperson, David Reuter, 

8 reportedly confirmed that the proposal as reported was indeed shared with its CEO, stating, “‘We 

9 are aware of the proposed structure as the legal memo was shared with us, and as we understand 

10 it, Joe Perkins’[s] team at Matrix created a proposal to fund their clients’ communication and 

outreach activities during 2020.’”106 11 Thus, there is no available information indicating that the 

12 news articles’ report that Pitts and Matrix created and shared a proposal to anonymize political 

13 contributions was inaccurate or not credible. 

14 Moreover, the available information does not indicate that the proposal was limited to 

15 acting solely within the legal bounds of minimizing public reporting of political activities. 

16 Specifically, the proposal did not indicate that Pitts and Matrix were soliciting funds from FPL 

17 on behalf of nonprofit corporations that would independently decide to make political 

18 contributions. Rather, the proposal indicated that funds would flow from FPL, through several 

19 layers of conduits controlled or associated with Matrix, before landing at “Florida Promise C4,” 

104 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

105 See Secretive Political Spending Plan, supra note 12 (stating that the Orlando Sentinel received records 

“includ[ing] checks, bank statements, emails, text messages, invoices, internal ledgers and more, all apparently 

unearthed during an internal investigation Matrix launched after its former employees left the firm at the end of 

2020.”).

106 Id.

Attachment 2 

Page 25 of 33

MUR808200339
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 26 of 33

1 “US Promise C4” and “Fed Promise C4,” which would also be controlled by Matrix, to make 

contributions to state and federal political committees.107 2 

3 Notably, there is no available information indicating that Pitts or Matrix presented the 

4 purposes or goals of the conduits referenced in its flowchart, besides being able to making 

5 political contributions, to explain why FPL’s funds would be expected to flow from one 

corporation to another.108 6 There is also no available information indicating that Pitts and Matrix 

7 presented any information as to why “Florida Promise C4,” “US Promise C4” and “Fed Promise 

8 C4,” would be expected to engage in political activity that FPL would support. Instead, Pitts’s 

9 and Matrix’s flowchart simply noted “Matrix” in a parenthetical below the names of “Broken 

10 Promises,” “Florida Promise C4,” “US Promise C4” and “Fed Promise C4,” similar to how 

11 Tyson, the executive director of LPAD, was included in a parenthetical under LPAD, suggesting 

that these entities are controlled by “Matrix,” similar to how Tyson controlled LPAD.109 12 

13 Moreover, the conduits depicted on the flowchart appear to have been in fact controlled 

14 by or associated with Matrix. Of the conduits mentioned, only Florida Promise, Broken 

15 Promises, LPAD, and SUN existed or eventually came into existence, and they all have ties to 

16 Pitts and/or Matrix. As explained above, Richard Alexander was the chairman of Florida 

Promise, and his sister, April Odom, was a Matrix contractor at the time of the allegations.110 17 

107 Id.; see also Compl. ¶¶ 33 Fig. 1, 36-37. 

108 See Secretive Political Spending Plan, supra note 12 (noting that, for example, “Florida Promise C4” would 

“allowed to spend 50% of revenues on political activities” and that “Florida PCs are allowed to take unlimited funds 

from C4s”); see also Compl. ¶ 33 Fig. 1 (same).

109 See Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1. While the term “person” 

appears in the parenthetical next to SUN, SUN had not yet been formed when Pitts sent the memo, and thus this

denotation appears to suggest that they were looking for a “person” to be in control of SUN at that time. See 

Secretive Political Spending Plan, supra note 12 (reporting that Pitts sent the memo to Silagy on November 26, 

2019).

110 Florida Promise 2018 Tax Return at 3, supra note 32; Dark Money Playbook, supra note 7 (reporting that 

April Odom is Anderson’s sister and was a former Matrix employee).

Attachment 2 

Page 26 of 33

MUR808200340
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 27 of 33

1 Sean J. Anderson, who was the president and chairman of Broken Promises, was also a former 

2 Matrix employee, a close friend of Pitts, and has a history of allowing Pitts to control the 

nonprofits that he purportedly ran.111 3 Tyson, the executive director of LPAD, reportedly 

4 associated with Pitts and Abigail MacIver, another former Matrix employee, as they 

communicated via text messages regarding Florida state senate races.112 5 Finally, as for SUN ⸺

6 FPL, which reportedly gave $250,000 to SUN in December 2019, states that it believes that SUN 

is owned by Matrix.113 7 Thus, the layers of corporations depicted on the flowchart appear to be 

8 linked together because they are controlled by persons associated with Pitts or Matrix.

9 The available information also indicates that Pitts’s and Matrix’s proposal included the 

10 making of federal political contributions. According to news articles, Pitts’s email to Silagy 

11 included a “‘funding memo’” noting making “federal campaign contributions” as one of its 

goals.114 12 Pitts’s email to Silagy also included “‘a separate legal memo on federal elections 

13 support’” explaining that “a nonprofit might have to disclose its donors if it spent money directly 

14 supporting a candidate” but that “the nonprofit would not have to disclose its donors if it gave 

money to a type of political action committee known as a ‘Super PAC,’”115 15 which is a colloquial 

reference to federal independent expenditure-only committees.116 16 Moreover, this legal memo 

111 Broken Promises, 2018 Tax Return at 1, 7, supra note 60; Bachelor Party, supra note 10 (reporting Pitts as 

having attended Anderson’s bachelor party); Nightmare Scenario, supra note 10 (reporting that Pitts texted FPL 

Vice President Martell that Anderson was an old friend of his and that he was “‘in control 100 percent’” of the 

nonprofits purportedly run by Mr. Anderson).

112 FPL Execs, supra note 43. 

113 Secretive Political Spending Plan, supra note 12. 

114 Id.; see also Compl. ¶ 32.

115 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 38.

116 See McCutcheon v. FEC, 572 U.S. 185, 193 (2014) (“A so-called ‘Super PAC’ is a PAC that makes only 

independent expenditures and cannot contribute to candidates. The base and aggregate limits govern contributions 

to traditional PACs, but not to independent expenditure PACs.”).

Attachment 2 

Page 27 of 33

MUR808200341
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 28 of 33

1 appears to provide the missing explanation as to the purpose of providing funds to the “Fed 

2 Promise C4” entity in the funding memo’s flowchart, indicating that this purpose would be to 

make federal political contributions.117 3 The name, “Fed Promise C4,” also suggests that this 

4 conduit would be used to make federal political contributions, as this would be consistent with 

5 and parallel to the flowchart’s statements that “Florida Promise C4” would be used to fund 

6 “Florida PCs” and that “US Promise C4” would be used to fund other state-level political 

activities.118 7 Thus, the available information indicates that the Pitts/Matrix proposal included 

8 making federal political contributions. 

9 The available information also indicates that the alleged Conduit Corporations received 

10 funds with the direction that they be used for federal contribution purposes as federal courts have 

11 stated that a donor’s intent can be inferred from the donee’s solicitations. Specifically, in the 

12 context of interpreting 52 U.S.C. § 30104(c)(1) of the Act, which courts have held to require notpolitical committees to disclose donations received for political purposes,119 13 a district court in 

14 Wisconsin observed that “whether a contribution is earmarked for political purposes and tied to 

15 an election can depend on whether the contribution is received in response to a solicitation and 

the way the solicitation is worded.”120 16 As explained above, Pitts’s and Matrix’s proposal clearly 

17 implicated the making of federal contributions, and the alleged Conduit Corporations appear to 

18 have received donations in response to that proposal.

19 In addition to conceiving of and sharing the plan, Pitts and Matrix were also in a position 

117 See Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1 (noting that it was 

“[w]aiting on lawyers” to explain the purpose of Fed Promise C4).

118 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

119 Citizens for Resp. & Ethics in Washington v. FEC, 316 F. Supp. 3d 349, 389 (D.D.C. 2018), aff’d, 971 F.3d 

340 (D.C. Cir. 2020).

120 Wisconsin Fam. Action v. FEC, No. 21-C-1373, 2022 WL 844436, at *11 (E.D. Wis. Mar. 22, 2022). 

Attachment 2 

Page 28 of 33

MUR808200342
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 29 of 33

1 to carry it out using the names of alleged Conduit Corporations to make the contributions. As 

2 discussed above, the persons nominally in charge of the alleged Conduit Corporations, 

3 Alexander and Anderson, had close relationships with Pitts and Matrix. Alexander, who served 

4 as a director or officer of Florida Promise, CAIJ, and Grow United, is apparently the brother of 

5 April Odom, who was a Matrix contractor at the time of the contributions and worked on matters 

relating to CAIJ and Grow United on behalf of Matrix.

121 6 Anderson, who was the chairman and 

7 president of Broken Promises and a director and president of Stand Up for Justice, was also 

former Matrix employee, and a close friend of Pitts.122 8 Pitts and Matrix also has a history of 

9 working with Anderson’s nonprofit corporations, as Pitts reportedly texted FPL Vice President 

10 Daniel Martell in 2016, four years prior to the contributions at issue here, “‘Bottom line is we are 

11 the ones with the check books and in control 100 percent’” of the nonprofits purportedly run by 

Anderson.123 12 

13 Pitts and Matrix also reportedly used the names of CAIJ and Grow United in other 

operations,124 and had access to CAIJ’s and Grow United’s bank accounts,125 14 further indicating 

15 that they had control over these corporations. Specifically, news reports indicate that, in October 

121 Dark Money Playbook, supra note 7 (reporting that April Odom is Anderson’s sister and was a former 

Matrix contractor); see also Compl. ¶¶ 13, 48.

122 Bachelor Party, supra note 10 (reporting Pitts as having attended Anderson’s bachelor party); Nightmare 

Scenario, supra note 10 (reporting that Pitts texted FPL Vice President Martell that Anderson was an old friend of 

his); see also Compl. ¶¶ 16, 52.

123 Nightmare Scenario, supra note 10; see also Compl. ¶¶ 16, 52. 

124 FPL Execs, supra note 43 (reporting that Matrix made a conduit contribution using CAIJ’s name on behalf 

of FPL); Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/ (reporting that Matrix offered a city councilman 

a job on behalf of FPL using Grow United’s name).

125 Dark Money Playbook, supra note 7 (reporting that internal Matrix records included a text message from

Odom stating that she procured access to the bank accounts of CAIJ and Grow United). 

Attachment 2 

Page 29 of 33

MUR808200343
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 30 of 33

2018, Pitts used CAIJ to make a contribution to House Majority PAC on behalf of Matrix.126 1 

2 News reports also indicate that in the summer of 2019, Matrix used Grow United to offer a job to 

a Jacksonville City Council member on behalf of FPL.127 3 In addition, according to the Orlando 

4 Sentinel, it received internal Matrix documents reflecting a September 23, 2020 text message 

from Odom stating that she procured access to CAIJ’s and Grow United’s bank accounts.128 5 

6 Finally, Tyson, the executive director of LPAD who donated $1,150,000 of LPAD funds to 

7 Grow United, testified that he understood that Pitts created and ran Grow United. Therefore, not 

8 only did Pitts and Matrix conceive of a plan for the making of conduit contributions, they also 

9 had sufficient control over the alleged Conduit Corporations to cause them to permit their names 

10 to be used to make contributions on behalf of Unknown Respondents. 

11 Although all five of the alleged Conduit Corporations were formed more than a year prior 

12 to making the contributions, the overall record of their known activities indicate that they were 

13 formed for the purpose of making conduit contributions. The only available information as to 

14 the five alleged Conduit Corporations’ activities was that they made federal and Florida state 

political contributions.129 15 Broken Promises and Stand Up for Justice spent at least 67% to 89% 

126 FPL Execs, see supra note 43 (reporting that Silagy, former CEO of FPL, emailed Pitts, former CEO of 

Matrix, to make a contribution to House Majority PAC to support Lauren Baer, and to make sure that “they don’t 

triangulate this donation to others we have done”); see also House Majority PAC, 2018 Amended 12-Day PreElection Report at 655 (Dec. 3, 2018), https://docquery.fec.gov/pdf/085/201812069135107085/20181206913510

7085.pdf (reflecting CAIJ’s contribution to House Majority PAC on October 16, 2018).

127 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/. FPL reportedly confirmed that Matrix 

employees came up with an idea to offer the City Council member a job, but that it rejected the idea. Id. 

128 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right-hand corner 

of the article’s sixth picture); see also Compl. ¶ 48.

129 Although Matrix reportedly used Grow United to offer a job to a Jacksonville council member, that never 

came to fruition as the council member rejected the offer. Nate Monroe, Amid JEA Privatization Controversy, a 

City Council Member Received a Mysterious Job Offer. A Dark-Money Group May Have Been Behind It, THE FL

Attachment 2 

Page 30 of 33

MUR808200344
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 31 of 33

1 and 78% to 94%, respectively, of their total funding on making federal and Florida state political 

2 contributions, indicating that they were created for the primary purpose of making political 

contributions.130 3 Moreover, consistent with the Pitts’s and Matrix’s proposal, federal tax records 

4 show that their funding was first transmitted through another Matrix-associated conduit, the 

5 Alliance for Consumer Protection Inc., which was reportedly controlled by Pitts’s former college 

roommate.131 6 While the available information does not indicate the total funding received by 

7 Florida Promise, CAIJ, or Grow United, the only known activities by these corporations are that 

they made an aggregate of $3,224,500 in federal and Florida state political contributions.

132 8 

9 In addition, only Florida Promise, Broken Promises, and Stand Up for Justice appeared to 

10 have filed federal tax returns, and these returns do not indicate that they engaged in any activity 

other than making political contributions, including through lobbying.133 11 The purpose 

12 statements in these tax returns indicate that Florida Promise, Broken Promises, and Stand Up for 

13 Justice were formed for political purposes, further suggesting they only engaged in political 

TIMES-UNION (Sept. 2, 2022), https://www.jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-salejacksonville-city-council-member-mysterious-job-offer-dark-money-group-nate-monroe/8850689002/. 

130 See supra pages 15-16, 18-19.

131 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095_201812_990O_20211020

19109756.pdf; Nightmare Scenario, supra note 10. 

132 See supra notes 33-34 and accompanying text (reflecting that Florida Promise made $1,230,000 in federal 

and Florida state contributions); supra notes 38, 40, 38 and accompanying text (reflecting that CAIJ made $432,000 

in federal and Florida state contributions); supra notes 46, 49 and accompanying text (reflecting that Grow United 

made $1,562,500 in federal and Florida state contributions).

133 See generally Florida Promise 2018 Tax Return, supra note 32; Broken Promises 2018 Tax Return, supra

note 60; Stand Up for Justice 2018 Tax Return, supra note 76. As indicated above, while Broken Promises and 

Stand Up for Justice indicated in their 2018 federal tax returns that they spent funding on “lobbying” and “other”

program expenses in 2018, the amounts they reportedly spent correspond to the same amounts that they spent on 

making Florida state political contributions. See supra pages 16, 18. 

Attachment 2 

Page 31 of 33

MUR808200345
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 32 of 33

activities.

134 1 

2 Furthermore, there are various organizational aspects of the alleged Conduit Corporations 

3 that suggest they were formed to serve as conduits. Specifically, despite the fact that CAIJ and 

4 Stand Up for Justice were incorporated in different states and do not share any officers, both 

entities reported having the same mailing address in Washington, D.C.135 5 In addition, despite 

6 both Broken Promises and Stand Up for Justice having the same three officers and nearly 

7 identical mission statements, both entities were incorporated on the same day in the same 

state.

136 8 Finally, Broken Promises’s federal tax return suggests that it was trying to conceal that 

9 it made political contributions. Specifically, Broken Promises characterized on its 2018 federal 

10 tax return that it spent $115,470 on “other” program service expenses, when that amount was 

actually used to make in-kind contributions to Florida state committees.137 11 Thus, the available 

12 information as to the activities, stated purpose, and creation of the Conduit Corporations suggests 

13 that they were created for making conduit contributions. 

134 Florida Promise 2018 Tax Return at 6, supra note 32 (stating that its purpose is to “develop and advocate 

for legislation, regulations, and government programs related to policies to benefit Floridians”); Broken Promises 

2018 Tax Return at 2, supra note 60 (stating that its purpose is to “develop[] and advocat[e] for legislation, 

regulations, and government programs to improve social environmental, economy and social environment”); Stand 

Up for Justice 2018 Tax Return at 2, supra note 76 (stating that its purpose is to “develop[] and advocat[e] for 

legistlation [sic], regulations, and government programs to improve social environment, economy & society”).

135 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting that CAIJ’s address was at 2020 Pennsylvania Avenue, 

NW, Ste. 449, Washington DC 20006); CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing

(last visited Sept. 25, 2023) (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for 

Justice’s business address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006). 

136 See CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023) 

(searching the organization names “Broken Promises” and “Stand Up For Justice”) (reflecting that both Broken 

Promises and Stand Up for Justice were incorporated on August 29, 2018); Broken Promises 2018 Tax Return at 1, 

7, supra note 60; Stand Up for Justice 2018 Tax Return at 1, 7, supra note 76. 

137 Compare Broken Promises 2018 Tax Return at 10, supra note 60 (stating that it spent $115,470 in “other” 

program service expenses), with Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.

myflorida.com/campaign-finance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and 

contributor last name “Broken Promises”) (reflecting that Broken Promises Broken Promises made $115,470 in inkind Florida state political contributions in 2018).

Attachment 2 

Page 32 of 33

MUR808200346
MUR 8082 (Florida Promise, Inc.) 

Factual and Legal Analysis

Page 33 of 33

1 In sum, the available information indicates that there was a plan to illegally disguise or 

2 withhold public reporting of political activities, and that this plan included making contributions 

3 through conduits and in a manner that closely matches what the available information shows had 

4 subsequently occurred. In addition, pursuant to this plan, the alleged Conduit Corporations 

5 permitted their names to be used to make federal political contributions on behalf of Unknown 

6 Respondents. Finally, the only known activities of the alleged Conduit Corporations were that 

7 they made federal and Florida state political contributions, indicating that their purpose was to 

8 serve as conduits. Thus, the Commission finds reason to believe that Florida Promise, Inc., 

9 violated 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b) by knowingly permitting its name to be 

10 used to effect contributions in the name of another. 

Attachment 2 

Page 33 of 33

MUR808200347
1 FEDERAL ELECTION COMMISSION

2 FACTUAL AND LEGAL ANALYSIS

3 RESPONDENT: Center for Advancement of Integrity and Justice, Inc. MUR 8082 

4 I. INTRODUCTION

5 The Complaint alleges that Unknown Respondents made contributions in the name of 

6 another through a network of conduits associated with a political consulting firm called Matrix 

LLC (“Matrix”), to five federal independent expenditure-only political committees (“IEOPCs”).

1 7 

8 The specific contributions identified in the Complaint are as follows: 

9 • a $1,000,000 contribution reportedly from Florida Promise, Inc. (“Florida Promise”)

to Senate Leadership Fund, dated December 8, 2020;2 10 

11 • a $100,000 contribution reportedly from the Center for Advancement of Integrity and

Justice, Inc. (“CAIJ”) to American Valor PAC, dated October 27, 2020;3 12 

13 • a $100,000 contribution reportedly from Grow United, Inc. (“Grow United”) to

Conservative Action Fund (f/k/a Wingman PAC), also dated October 27, 2020;4 14 

15 • a $20,000 contribution reportedly from Broken Promises to Concerned

Conservatives, Inc., dated July 14, 2020;5 16 and

17 • a $50,000 contribution reportedly from Stand Up for Justice to South Florida

Residents First, dated March 31, 2020.6 18 

1 Compl. ¶¶ 2, 5, 27, 42, 89-93 (Oct. 27, 2022).

2 Senate Leadership Fund, Amended 2020 Year End Report at 72 (Mar. 18, 2021), https://docquery.fec.gov/

pdf/807/202103189441299807/202103189441299807.pdf; see also Compl. ¶¶ 49-50.

3

 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/2020

12039337569242/202012039337569242.pdf; see also Compl. ¶¶ 47-48.

4

 Wingman PAC, 2020 30-Day Post Election Report at 1, 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting a $100,000 contribution from Grow United, Inc., on 

October 27, 2020, and the committee’s FEC identification number of C00742296); Conservative Action Fund, 

Amended Statement of Organization at 1 (May 20, 2022), https://docquery.fec.gov/pdf/048/202205209512421048/

202205209512421048.pdf (reflecting that its name has changed to Conservative Action Fund and that its FEC 

identification number is C00742296); see also Compl. ¶¶ 43-44.

5 Concerned Conservatives, Inc., 2020 12-Day Pre-Primary Election Report at 6 (Aug. 6, 2020), https://doc

query.fec.gov/pdf/823/202008069261263823/202008069261263823.pdf; see also Compl. ¶¶ 51-52.

6

 South Florida Residents First, 2020 April Quarterly Report at 11 (Apr. 13, 2020), https://docquery.fec.gov/

pdf/294/202004159216942294/202004159216942294.pdf; see also Compl. ¶¶ 53-54.

Attachment 3 

Page 1 of 33

MUR808200348
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 2 of 33

1 The Complaint relies on news articles regarding a 2019 email and two accompanying 

2 memoranda sent from Jeff Pitts, Matrix’s former CEO, to Eric Silagy, Florida Power & Light 

3 Company’s (FPL) former CEO, reportedly proposing a method for FPL to make anonymous 

4 contributions to federal and state political committees by transferring funds through multiple 

levels of conduits.7 5 The proposal called for funds to be first sent to and passed through higher6 level Matrix-associated conduits, including SUN Marketing & Advertising LLC (“SUN”) and 

7 Let’s Preserve the American Dream, Inc. (“LPAD”), before being sent to various lower-level 

8 Matrix-controlled conduits, including Florida Promise, that would be reported as the source of 

9 the contributions. Thus, the Complaint alleges that each of the five alleged lower-level Matrix10 controlled conduits (referred to herein as the “Conduit Corporations”) permitted their names to 

11 be used to effect contributions in the name of another pursuant to Pitts’s and Matrix’s proposal. 

12 To support its central allegation, the Complaint alleges that all five of the alleged Conduit 

13 Corporations had ties to Pitts or Matrix through having either Richard Alexander or Sean J. 

Anderson as a director or officer.

8 14 Citing news articles, the Complaint alleges that Alexander’s 

sister was a Matrix contractor at the time of the allegations9 15 and that Anderson was a former 

Matrix employee and a good friend of Pitts.10 16 

7

 Compl. ¶¶ 3-4, 28-41; see, e.g., Jason Garcia & Annie Martin, Florida’s Dark Money Playbook: How 

‘Ghost’ Candidate Scheme Revealed Secretive Political Tactics, ORLANDO SENTINEL (Dec. 30, 2021), 

https://www.orlandosentinel.com/news/os-ne-dark-money-ghost-candidates-tactics-20211230-7zelkoadffclde3z

76ax3cgx3m-htmlstory.html [hereinafter Dark Money Playbook].

8

 Compl. ¶¶ 13, 16. 

9

 Id. ¶ 13; see Dark Money Playbook, supra note 7 (reporting that Alexander’s sister, April Odom, was a 

Matrix employee at the time of the allegations, and that she worked on matters relating to Grow United and CAIJ).

10 Compl ¶ 16; see John Archibald, Archibald: ‘Bachelor party’ Makes For Strange Bedfellows, AL.COM

(Nov. 14, 2010), https://www.al.com/archiblog/2010/11/archibald bachelor party makes.html [hereinafter 

“Bachelor Party”] (reporting that Pitts attended Anderson’s bachelor party and that they were both employed by 

Matrix at the time); Mary Ellen Klas, et al., ‘Nightmare Scenario’: How FPL Secretly Manipulated a Florida State 

Senate Election, MIAMI HERALD (Aug. 29, 2022), https://www.miamiherald.com/news/politics-government/statepolitics/article264196761.html [hereinafter “Nightmare Scenario”] (reporting that Pitts texted FPL vice president 

Attachment 3 

Page 2 of 33

MUR808200349
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 3 of 33

1 As discussed below, the five contributions purportedly made by the alleged Conduit 

2 Corporations as identified by the Complaint appear to be consistent with the conduit 

3 contributions proposed by Pitts and Matrix to FPL to anonymize its political contributions. In 

4 addition, all five of the alleged Conduit Corporations appear to be controlled by or associated 

5 with Pitts and Matrix. Accordingly, the Commission finds reason to believe that the Center for 

6 Advancement of Integrity and Justice, Inc., violated 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b) 

7 by knowingly permitting its name to be used to effect contributions in the name of another. 

8 II. FACTUAL BACKGROUND

9 A. Jeff Pitts of Matrix Appears to Have Created a Plan to Anonymize Federal 

10 Political Contributions Using a Network of Conduits Controlled by or 

11 Associated with Pitts or Matrix 

Matrix is a “strategic communications firm” based in Alabama.11 12 According to the 

13 Orlando Sentinel, it received a cache of internal documents from Matrix, “includ[ing] checks, 

14 bank statements, emails, text messages, invoices, internal ledgers and more, all apparently 

15 unearthed during an internal investigation Matrix launched after its former employees left the 

firm at the end of 2020.”12 16 These internal records included a copy of a November 26, 2019 

17 email sent from former Matrix CEO, Jeff Pitts, to former FPL CEO, Eric Silagy, stating, 

18 “‘Attached is an updated funding memo along with a separate legal memo on federal elections 

support.’”13 19 The “funding memo” noted goals such as making “federal campaign contributions” 

Daniel Martell that Anderson was an old friend of his and that Pitts was in control of the nonprofits run by 

Anderson).

11 Matrix, LLC, v. Canopy Partners, LLC, et al, 2021 WL 3127729 (Ala. Cir. Ct.).

12 Jason Garcia & Annie Martin, Operative Pitched Secretive Political Spending Plan to FPL Exec’s Email 

Alias, Records Reveal, ORLANDO SENTINEL (Jan. 24, 2022), https://www.orlandosentinel.com/politics/os-ne-floridapower-and-light-matrix-dark-money-20211217-v64274eytjeb5hnstdognvqds4-story.html [hereinafter “Secretive 

Political Spending Plan”]. 

13 Id.; see also Compl. ¶¶ 3, 31-38.

Attachment 3 

Page 3 of 33

MUR808200350
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 4 of 33

and “‘minimiz[ing] all public reporting of entities and activities.’”14 1 It also included a flowchart

2 depicting money flowing from FPL through a network of conduits before being contributed to 

federal and state political committees, as reproduced below:15 3 

14 See Secretive Political Spending Plan, supra note 12; Compl. ¶ 32.

15 See Secretive Political Spending Plan, supra note 12; Compl. ¶ 33 Fig. 1.

Attachment 3 

Page 4 of 33

MUR808200351
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 5 of 33

1 Notably, next to or below the name of each conduit is a parenthetical, which may indicate the 

2 person or entity controlling or associating with that conduit. Specifically, the flowchart 

3 identifies a “LPAD C4 (Tyson),” which appears to refer to LPAD and its executive director Ryan 

Tyson.16 4 The flowchart also identifies “Matrix/Foley” in a parenthetical next to or below the 

16 See Compl. ¶ 35.

Attachment 3 

Page 5 of 33

MUR808200352
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 6 of 33

1 names of the following conduits: “Broken Promises,” “Florida Promise C4,” “US Promise C4,” 

2 and “Fed Promise C4,” suggesting that these conduits are directly associated with and/or 

controlled by Matrix and its legal counsel, Foley and Lardner, LLP (“Foley”).17 3 

4 According to the flowchart, money could flow to a “Florida Promise C4,” which could 

5 “spend 50% of revenues on political activities” due to its tax status as a section 501(c)(4) 

6 corporation, and be used to contribute to Florida state political committees on the basis that 

“Florida PCs are allowed to take unlimited funds from C4s.”18 7 Money could also flow to a “US 

8 Promise C4,” which similarly could “spend 50% of revenues on political activities” due to its tax 

9 status, and be used to contribute to other states’ political committees on the basis that “[e]ach 

state operates under unique state elections.”19 10 Lastly, the flowchart indicates that money could 

11 flow to a “Fed Promise C4,” but because Matrix was “[w]aiting on lawyers,” it could not state

the purpose of this proposed funding.20 12 

13 The legal memo attached to the email, which was drafted by Foley attorney Erika Alba, 

addressed “the legalities of using nonprofits to spend money on federal elections.”21 14 The memo 

15 states that “a nonprofit might have to disclose its donors if it spent money directly supporting a 

16 candidate,” but that “the nonprofit would not have to disclose its donors if it gave money to a 

17 type of political committee known as a “‘Super PAC’” (i.e., an IEOPC) “that then spent money 

supporting the candidate.”22 18 The legal memo then concluded: “‘Thus, it could be strategic for a 

17 See Secretive Political Spending Plan, supra note 12 (noting that Erika Alba of Foley & Lardner LLP 

drafted a legal memo attached to the email); see also Compl. ¶ 38 (alleging the same). 

18 Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 33 Fig. 1, 37.

19 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

20 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

21 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 38.

22 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 38.

Attachment 3 

Page 6 of 33

MUR808200353
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 7 of 33

[nonprofit] who wishes to make Independent Expenditures to do so via a Super PAC.’”23 1 

2 Based on the record of contributions disclosed by the recipient IEOPCs and news articles 

3 reporting that LPAD provided funding to Grow United and Broken Promises, the Complaint 

depicts the implementation of the Matrix plan as taking the following altered form:24 4 

5 

6 The Complaint alleges that Matrix pitched the above-referenced plan to Unknown 

7 Respondent clients, noting that FPL’s spokesperson, David Reuter, stated, “‘We are aware of the 

8 proposed structure as the legal memo was shared with us, and as we understand it, Joe 

23 Secretive Political Spending Plan, supra note 12 (alteration in original); see also Compl. ¶ 38.

24 Compl. ¶¶ 42 Fig. 2, 45, 52.

Attachment 3 

Page 7 of 33

MUR808200354
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 8 of 33

1 Perkins’[s] team at Matrix created a proposal to fund their clients’ communication and outreach 

activities during 2020.’”25 2 

3 B. The Alleged Conduit Corporations Appear to Have Been Controlled by or 

4 Associated with Pitts and/or Matrix 

5 The Complaint alleges that five alleged Conduit Corporations, Florida Promise, CAIJ, 

6 Grow United, Broken Promises, and Stand Up for Justice, permitted their names to effect the 

7 $1.27 million in contributions that they purportedly made to IEOPCs on behalf of Unknown 

Respondents.26 8 Richard Alexander served as a director or officer of the first three alleged 

9 Conduit Corporations, while Sean J. Anderson was a director or officer of the latter two. 

10 According to news reports, both Alexander and Anderson had close ties to Matrix. 

11 Alexander’s sister, April Odom, was a Matrix contractor at the time of the allegations and 

12 reportedly worked on behalf of Matrix regarding CAIJ and Grow United, which were entities 

associated with Alexander.

27 13 Anderson, on the other hand, was a former Matrix employee, and 

reportedly a close friend of Pitts. 28 14 Anderson also has a history of working with Pitts, as Pitts 

15 reportedly texted FPL Vice President Daniel Martell in 2016, four years prior to the alleged 

16 contributions, as follows: “‘Bottom line is we are the ones with the check books and in control 

100 percent’” of the nonprofits purportedly run by Anderson.29 17 The discussion below sets out 

18 the available information about each of the alleged Conduit Corporations and their relationships 

19 with Pitts and/or Matrix.

25 Secretive Political Spending Plan, supra note 12 (emphasis added); Compl. ¶ 40 (emphasis added). 

26 Compl. ¶¶ 5, 43-54.

27 Dark Money Playbook, supra note 7 (reporting that April Odom is Anderson’s sister and was a former 

Matrix employee); see also Compl. ¶¶ 13, 48.

28 Bachelor Party, supra note 10; Nightmare Scenario, supra note 10 (reporting that Pitts texted FPL Vice 

President Martell that Anderson was an old friend of his); see also Compl. ¶ 16.

29 Nightmare Scenario, supra note 10; see also Compl. ¶ 16. 

Attachment 3 

Page 8 of 33

MUR808200355
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 9 of 33

1 1. Florida Promise, Inc. 

2 Florida Promise is a corporation identified in Matrix’s proposal to FPL that could be used 

as a conduit to make contributions to Florida political committees,

30 3 and it was incorporated on 

December 18, 2018.31 4 According to Florida Promise’s 2018 federal tax return, it is a 501(c)(4) 

5 corporation; its mission is to “develop and advocate for legislation, regulations, and government 

6 programs related to policies to benefit Floridians”; Alexander was its chairman; it did not have a 

website; and it did not have any expenses or revenue that year.32 7 

8 On December 8, 2020, Florida Promise made a $1,000,000 contribution to the Senate 

Leadership Fund.33 9 In addition, consistent with Matrix’s proposal to use Florida Promise to

10 make Florida political contributions, Florida Promise also made contributions to Florida political 

committees on June 12, 2019, and January 27, 2021, totaling $230,000.34 11 Other than making the 

12 $1,230,000 in federal and Florida state political contributions, there is no publicly available 

13 information regarding Florida Promise’s activities. 

30 See Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 33 Fig. 1, 50. 

31 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Florida Promise”); see also Compl. ¶ 12.

32 IRS Form 990-EZ, Florida Promise, Inc., 2018 Short Form Return of Organization Exempt from Income 

Tax at 2-3, 6 (Nov. 13, 2019), https://apps.irs.gov/pub/epostcard/cor/832961305_201812_990EO_202006011716

8825.pdf [hereinafter Florida Promise 2018 Tax Return]. 

33 Senate Leadership Fund, Amended 2020 Year End Report at 72 (Mar. 18, 2021), https://docquery.fec.gov/

pdf/807/202103189441299807/202103189441299807.pdf; see also Compl. ¶ 49. 

34 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (searching “all” election years with contributor’s last name 

starting with “Florida Promise”); see also Compl. ¶ 50.

Attachment 3 

Page 9 of 33

MUR808200356
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 10 of 33

1 2. Center for Advancement of Integrity and Justice, Inc. 

CAIJ was incorporated on October 1, 2018,35 2 and shared a mailing address with Stand Up 

for Justice.36 There are no publicly available CAIJ federal tax returns.37 3 Alexander served as 

4 either a director or officer of CAIJ.

On October 27, 2020, CAIJ made a $100,000 contribution to American Valor PAC,38 5 an 

6 IEOPC that made independent expenditures during the 2020 election cycle solely in Florida’s

7 13th Congressional District, which supported Anna Paulina Luna, the Republican nominee, and 

opposed Charlie Joseph Crist, the Democratic nominee.39 8 CAIJ also made contributions to 

9 Florida political committees totaling $307,000, starting in November 2018 and through 

December 2020.

40 10 

35 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Center for Advancement of Integrity and 

Justice”); see also Compl. ¶ 11.

36 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting that CAIJ’s address was at 2020 Pennsylvania Avenue, 

NW, Ste. 449, Washington DC 20006); CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing

(last visited Sept. 25, 2023) (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for 

Justice’s business address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006). 

37 On May 15, 2021, the IRS automatically revoked CAIJ’s 501(c)(4) status for not filing a Form 990s-series 

return for three consecutive years, suggesting that CAIJ has not filed any tax returns. See Tax Exempt Organization 

Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited July 25, 2023) (searching the organization name “center 

for advancement of integrity” which reflect that CAIJ’s federal tax exempt status was automatically revoked on May 

15, 2021for not filing a Form 990-series return or notice for three consecutive years).

38 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf; see also Compl. ¶ 47. 

39 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00757179&is_notice=false&most_recent=true (last visited 

Aug. 18, 2023) (reflecting independent expenditures made by American Valor PAC); November 3, 2020 General 

Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=

11/3/2020&DATAMODE= (last visited Sept. 25, 2023) (selecting “Federal Offices”) (reflecting that Anna Luna 

was the Republican nominee and that Charlie Crist was the Democratic nominee in Florida’s 13th Congressional 

District).

40 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited July 25, 2023) (searching “all” election years with contributor’s last name starting 

with “center for advancement”).

Attachment 3 

Page 10 of 33

MUR808200357
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 11 of 33

1 While CAIJ was not referenced by name in Matrix’s proposal to FPL, news reports 

2 suggest that it was controlled by Matrix. Specifically, Matrix’s internal files reportedly include a 

3 September 23, 2020 text message from Odom, Alexander’s sister and a Matrix contractor at the 

time of the allegations, stating that she procured access to CAIJ’s bank account.41 4 In addition, 

5 on October 16, 2018, just 15 days after CAIJ’s incorporation, CAIJ made a $25,000 contribution 

to House Majority PAC.42 6 According to news reports, FPL directed Matrix to make this 

7 contribution on its behalf to support Lauren Baer, who was seeking election in Florida’s 18th 

8 Congressional District, and asked Matrix to ensure that House Majority PAC “‘do[es]n’t 

triangulate this donation to others we have done.’”43 9 Other than making the $432,000 in federal 

10 and Florida state political contributions, there is no publicly available information regarding 

11 CAIJ’s activities. 

41 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right-hand corner 

of the article’s sixth picture); see also Compl. ¶ 48.

42 House Majority PAC, 2018 Amended 12-Day Pre-Election Report at 655 (Dec. 3, 2018), https://docquery

.fec.gov/pdf/085/201812069135107085/201812069135107085.pdf. 

43 Jason Garcia & Annie Martin, Florida Power & Light Execs Worked Closely with Consultants Behind 

‘Ghost’ Candidate Scheme, Records Reveal, ORLANDO SENTINEL (Apr. 14, 2022), https://www.orlandosentinel.com/

politics/os-ne-florida-power-and-light-senate-ghost-candidates-20211202-szjhv7ox6vcmphm6pgd437y52i-htmlstory

.html [hereinafter “FPL Execs”] (reporting that Silagy forwarded Pitts instructions to make a contribution to House 

Majority PAC to support Lauren Baer and to make sure that “they don’t triangulate this donation to others we have 

done”); November 6, 2018 General Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.my

florida.com/Index.asp?ElectionDate=11/6/2018&DATAMODE= (last visited Sept. 25, 2023) (reflecting that Lauren 

Baer was the democratic nominee in Florida’s 18th Congressional District). 

Attachment 3 

Page 11 of 33

MUR808200358
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 12 of 33

1 3. Grow United, Inc. 

Grow United was incorporated on July 24, 2019.44 2 There are no publicly available Grow 

3 United federal tax records and it did not identify itself as a nonprofit organization to the Internal 

Revenue Service.

45 4 Alexander served either as a director or officer of Grow United. 

On October 27, 2020, Grow United made a $100,000 contribution to Wingman PAC,46 5 

now known as the Conservative Action Fund.47 6 Wingman PAC made independent expenditures 

7 during the 2020 election cycle solely in Florida’s 15th Congressional District, which supported 

8 Scott Franklin, the Republican nominee; opposed Alan Michael Cohn, the Democratic nominee; 

9 and opposed Vincent Spano Ross, who competed against Franklin for the Republican 

44 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Grow United”). 

45 See Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited Sept. 25, 2023)

(reflecting that there are no results when searching Grow United’s name or its EIN number identified in the 

Complaint, 84-2546999). 

46 Wingman PAC, 2020 30-Day Post Election Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/423/

202012039338666423/202012039338666423.pdf (reflecting a $100,000 contribution from Grow United on October 

27, 2020).

47 Id. at 1(reflecting an FEC identification number of C00742296); Conservative Action Fund, Amended 

Statement of Organization at 1 (May 20, 2022), https://docquery.fec.gov/pdf/048/202205209512421048/2022

05209512421048.pdf (reflecting that its name has changed to Conservative Action Fund and its FEC identification 

number is C00742296). 

Attachment 3 

Page 12 of 33

MUR808200359
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 13 of 33

nomination.48 1 Earlier that month, from October 3, 2020, through October 20, 2020, Grow 

United made contributions to Florida state political committees totaling $1,462,500.49 2 

3 Grow United appears to have been created and controlled by Pitts and Matrix. Ryan 

4 Tyson, the executive director of LPAD — which contributed $1,150,000 to Grow United in 

202050 5 — was deposed by the Miami-Dade State Attorney’s Office in a criminal matter 

6 regarding a former LPAD contractor’s creation of fake Florida state senate candidates during the 

7 2020 election cycle. Tyson testified in the deposition that he understood that Jeff Pitts started 

8 and ran Grow United. In addition, FPL reportedly asserted that Grow United was created by 

Matrix.51 9 

10 Matrix’s internal records also reportedly indicate that it had control of Grow United. 

11 According to news reports, Matrix’s internal ledger reflect an August 7, 2019 entry billed to FPL 

12 for “‘Grow United SOS Fees,’” which likely referred to the fees charged by the Delaware 

48 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00742296&is_notice=false&min_date=01%2F01%2F2019&max

_date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting Wingman PAC’s independent expenditures in the 

2020 election cycle); November 3, 2020 General Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results

.elections.myflorida.com/Index.asp?ElectionDate=11/3/2020&DATAMODE= (last visited Sept. 25, 2023) 

(selecting “Federal Offices”) (reflecting that Scott Franklin was the Republican nominee and Alan Cohn was the 

Democratic nominee in Florida’s 15th Congressional District); August 18, 2020 Primary Election Republican 

Primary, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate

=8/18/2020&DATAMODE= (last visited Sept. 25, 2023) (selecting “Federal Offices” in the Republican Primary 

section) (reflecting that both Scott Franklin and Ross Spano were seeking the Republican nomination in Florida’s 

15th Congressional District).

49 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (selecting election year “all” and searching contributor last name 

starting with “grow united”); see also Compl. ¶ 46.

50 See Compl. ¶ 45.

51 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Dec. 10, 2021, updated Sept. 2, 

2022), https://www.jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-citycouncil-member-mysterious-job-offer-dark-money-group-nate-monroe/8850689002/. Joe Perkins, owner of Matrix, 

denies that Matrix created Grow United, and Perkins’s attorney asserts that “[t]o the extent any rogue Matrix 

employees were involved in those activities, they were undertaken in secret, without Dr. Perkins’[s] knowledge or 

consent.” Id.

Attachment 3 

Page 13 of 33

MUR808200360
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 14 of 33

Secretary of State for incorporating Grow United a few weeks prior.

52 1 Matrix’s internal records 

2 also reportedly include a September 23, 2020 message from Odom stating that she procured 

access to Grow United’s bank account.53 3 In addition, as part of her duties at Matrix, Odom 

4 reportedly sent checks from Grow United to make contributions to Florida committees, asked the 

committees to confirm their receipt of the checks,54 5 and emailed a $12,813.54 invoice to Matrix

6 with the subject line, “FPL Expenses for Grow United c4,” for expenses that included traveling 

to Colorado to update the nonprofit’s mailbox at a UPS Store in Denver.55 7 

8 News articles also report that, in the summer of 2019, Matrix used Grow United to offer a 

job to a Jacksonville City Councilmember on behalf of FPL.56 9 Furthermore, Foley attorney 

10 Erika Alba reportedly billed Matrix in the fall of 2020 for her work on IRS submission forms for 

Grow United.57 11 Other than making the $1,562,500 in political contributions, there is no publicly 

12 available information regarding Grow United’s activities.

52 FPL Execs, supra note 43. 

53 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right corner of the 

article’s sixth picture); see also Compl. ¶ 48.

54 Dark Money Playbook, supra note 7. 

55 FPL Execs, supra note 43. 

56 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/. FPL reportedly confirmed that Matrix 

employees came up with an idea to offer the City Council member a job, but that it rejected the idea. Id. 

57 Nate Monroe, Law Firm that Advised on Botched JEA Sale Also Helped Former FPL Consultants On 

Dark-Money Projects, FL TIMES-UNION (Dec. 17, 2021), https://www.jacksonville.com/story/news/columns/natemonroe/2021/12/17/jea-privatization-law-firm-foley-lardner-also-helped-former-fpl-consultants-political-giving/

8850686002/. There are no publicly available tax forms from Grow United, Inc., however. See Tax Exempt 

Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited Sept. 25, 2023) (reflecting that there are no 

results when searching Grow United’s name or its EIN number identified in the Complaint, 84-2546999).

Attachment 3 

Page 14 of 33

MUR808200361
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 15 of 33

1 4. Broken Promises 

2 Broken Promises is referenced by name in Matrix’s proposal to FPL as a middleman that 

3 would receive funds and send them to conduits, including Florida Promise, that would in turn 

make political contributions.58 4 Broken Promises was incorporated on August 29, 2018, along 

with Stand Up for Justice.59 5 According to Broken Promises’s federal tax return for the 2018 

6 calendar year, it is a 501(c)(4) corporation; its purpose is to “develop[] and advocat[e] for 

7 legislation, regulations, and government programs to improve social environmental, economy 

8 and social environment”; Sean J. Anderson is its president and chairman; it did not have a 

website; and it received $200,000 of funding that year.60 9 In addition, according to news reports, 

Broken Promises reportedly received $26,000 from LPAD on July 9, 2020.61 10 

11 On July 14, 2020, five days after reportedly receiving the $26,000 from LPAD, Broken 

Promises made a $20,000 contribution to Concerned Conservatives, Inc., an IEOPC.62 12 During 

13 the 2020 election cycle, Concerned Conservatives, Inc., made independent expenditures only in 

14 Florida’s 19th Congressional District to support Dane Eagle, who unsuccessfully ran for the 

15 Republican nomination, and oppose his competitors, William Matthew Figlesthaler, Byron 

58 See Secretive Political Spending Plan, supra note 12; Compl. ¶¶ 33 Fig. 1, 52. 

59 CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023)

(searching the organization name “Broken Promises” and “Stand Up for Justice”).

60 See IRS Form 990, Broken Promises, 2018 Return of Organization Exempt from Income Tax at 1, 7 

(Nov. 15, 2019), https://apps.irs.gov/pub/epostcard/cor/831745117_201812_990O_2020012317057600.pdf

[hereinafter Broken Promises 2018 Tax Return] (reflecting an unfilled line for the organization’s website).

61 Jeff Weiner & Annie Martin, Bank Records Shed Light on Dark-Money Group in ‘Ghost’ Candidate 

Scandal, ORLANDO SENTINEL (Apr. 18, 2022), https://www.orlandosentinel.com/2022/04/18/bank-records-shedlight-on-dark-money-group-in-ghost-candidate-scandal/; see Compl. ¶ 52.

62 Concerned Conservatives, Inc., 2020 12-Day Pre-Primary Election Report at 6 (Aug. 6, 2020), 

https://docquery.fec.gov/pdf/823/202008069261263823/202008069261263823.pdf; see also Compl. ¶ 51.

Attachment 3 

Page 15 of 33

MUR808200362
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 16 of 33

Donalds, and Casey Askar.63 1 In addition, in 2018, Broken Promises made $160,470 in Florida 

2 state political contributions, and in 2019, it made $21,500 in Florida state political 

contributions.64 3 Thus, it appears that Broken Promises made at least $201,970 in political 

4 contributions during its existence. 

5 According to Broken Promises’s federal tax returns and other information received by the 

6 Commission, it received a total of $226,000 to $300,000 in funding during its existence: 

$200,000 in 2018,65 7 $50,000 or less in 2019, and $26,000 to $50,000 in 2020 before terminating 

later that year.

66 8 Broken Promises’s 2018 federal tax return also indicates that it spent $500 on 

legal expenses and $40 on management and general expenses that year.67 9 Although Broken 

10 Promises characterized spending $45,000 on lobbying and $115,470 on “other” program 

11 expenses in its 2018 federal tax return, this sum of $160,470 corresponds precisely to the dollar 

with its 2018 Florida state political contributions also totaling $160,470.68 12 Thus, Broken 

13 Promises spent at least 67% to 89% of its total funding on making political contributions.

63 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data type=processed&q spender=C00728402&is notice=false&min date=01%2F01%2F2019&max

date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting Concerned Conservatives, Inc.’s, independent 

expenditures during the 2020 election cycle); August 18, 2020 Primary Election Republican Primary, FL DEP’T OF 

STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=8/18/2020&DATA

MODE= (last visited Sept. 25, 2023) (selecting “Federal Offices” in the Republican Primary section) (reflecting that 

Dane Eagle, William Figlesthaler, Byron Donalds, and Casey Askgar were seeking the Republican nomination in 

Florida’s 19th Congressional District).

64 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and contributor last name “Broken 

Promises”).

65 Broken Promises 2018 Tax Return at 1, supra note 60. 

66 For 2019 and 2020, Broken Promises filed an IRS Form 990-N, indicating that its gross receipts were 

$50,000 or less in those years. Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited 

Sept. 25, 2023) (searching organization name “Broken Promises”). 

67 Broken Promises 2018 Tax Return at 10, supra note 60. 

68 Id.; see also Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/

campaign-finance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and contributor last name 

“Broken Promises”) (reflecting that Broken Promises made $160,470 in Florida state political contributions in 2018, 

Attachment 3 

Page 16 of 33

MUR808200363
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 17 of 33

1 According to the Miami Herald, Broken Promises’s entire $200,000 of funding in 2018 

was from FPL.69 2 Specifically, the Miami Herald claims it received an internal Matrix ledger 

3 showing how, in 2018, Matrix distributed $200,000 of funds labeled as coming from FPL to 

Broken Promises.70 4 The ledger reportedly shows that Matrix sent $100,000 of FPL funds to 

Broken Promises on September 26, 2018, and again on October 16, 2018, totaling $200,000.71 5 

6 This money was likely transmitted through other Matrix-controlled corporations before coming 

7 to Broken Promises, because federal tax records show that the Alliance for Consumer Protection 

Inc., donated $100,000 to Broken Promises in 2018.72 8 According to a news report regarding a 

9 text message between Pitts and FPL Vice President Martell, the director of the Alliance for 

Consumer Protection Inc., David Calvert, is Pitts’s former college roommate.

73 10 

11 5. Stand Up for Justice 

As discussed above, Stand Up for Justice was incorporated on August 29, 2018,74 12 the 

same day as Broken Promises, and it shared a mailing address with CAIJ.

75 13 According to its 

of which $45,000 were cash contributions and $115,470 were in-kind contributions in the forms of direct mail and 

advertising).

69 Nicholas Nehamas & Mary Ellen Klas, DeSantis ’18 Campaign Got $25,000 From Nonprofit Secretly 

Funded by FPL Cash, Records Show, MIAMI HERALD (Sept. 9, 2022), https://www.miamiherald.com/news/politicsgovernment/state-politics/article265213541.html. 

70 Id. FPL spokesperson Reuter called the ledger “fake” and stated, “We have no record of FPL, or any 

NextEra Energy entity for that matter, ever having paid Broken Promises.” Id

71 Nightmare Scenario, supra note 10; see also Nicholas Nehamas & Mary Ellen Klas, DeSantis ’18 

Campaign Got $25,000 From Nonprofit Secretly Funded by FPL Cash, Records Show, MIAMI HERALD (Sept. 9, 

2022), https://www.miamiherald.com/news/politics-government/state-politics/article265213541.html. 

72 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095 201812 990O 20211020

19109756.pdf. 

73 Nightmare Scenario, supra note 10. 

74 CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023) 

(searching the organization names “Stand Up for Justice” and “Broken Promises”). 

75 Id. (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for Justice’s business 

address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006); American Valor PAC, 2020 

Attachment 3 

Page 17 of 33

MUR808200364
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 18 of 33

1 2018 federal tax return, Stand Up for Justice is a 501(c)(4) corporation; its purpose is to 

2 “develop[] and advocat[e] for legistlation [sic], regulations and government programs to improve 

3 social environment, economy & society”; Anderson was a director and its president; it did not 

have a website; and it received $350,000 in funding that year.76 4 

5 On March 31, 2020, Stand Up for Justice made a $50,000 contribution to South Florida 

Residents First,

77 6 an IEOPC that made independent expenditures during the 2020 election cycle 

7 only in Florida’s 26th Congressional District, which supported Republican nominee Carlos 

Gimenez and opposed Democratic nominee Debbie Mucarsel-Powell.78 8 In addition, just two 

9 months after it was incorporated, Stand Up for Justice made contributions to a Florida political 

committee in October 2018, totaling $300,000,79 10 which Stand Up for Justice characterized as 

“lobbying” on its 2018 federal tax return.80 11 Thus, it appears that Stand Up for Justice made at 

12 least $350,000 in political contributions during its existence. 

Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/202012039337569242/20201203

9337569242.pdf (reflecting that CAIJ’s address is at 2020 Pennsylvania Avenue, NW, Ste. 449, Washington DC 

20006). 

76 IRS Form 990, Stand Up for Justice, 2018 Return of Organization Exempt from Income Tax at 1-2, 7 

(Nov. 15, 2019), https://apps.irs.gov/pub/epostcard/cor/831749759_201812_990O_2020021317141891.pdf

[hereinafter Stand Up for Justice 2018 Tax Return]. 

77 South Florida Residents First, 2020 April Quarterly Report at 11 (April 13, 2020), https://docquery.fec

.gov/pdf/294/202004159216942294/202004159216942294.pdf; see also Compl. ¶ 53.

78 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00733402&is_notice=false&min_date=01%2F01%2F2019&max

_date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting South Florida Residents First’s independent 

expenditures in the 2020 election cycle); November 3, 2020 General Election, FL DEP’T OF STATE DIV. OF 

ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=11/3/2020&DATAMODE= (last visited 

Sept. 25, 2023) (selecting “Federal Offices”) (reflecting that Carlos Gimenez was the Republican nominee and

Debbie Mucarsel-Powell was the Democratic nominee in Florida’s 26th Congressional District); see Compl. ¶ 53. 

79 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited July 25, 2023) (searching election year “all” and contributor last name starting 

with “Stand Up for Justice”).

80 Stand Up for Justice 2018 Tax Return at 10, supra note 76. 

Attachment 3 

Page 18 of 33

MUR808200365
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 19 of 33

1 According to Stand Up for Justice’s federal tax returns, it received $350,000 to $450,000 

during its existence: $350,000 in 2018,81 2 and $50,000 or less per year in each of 2019 and 2020 

before terminating.82 3 Stand Up for Justice’s federal tax returns also state that it spent $20,577 on 

legal fees and $100 on bank service charges in 2018,83 4 indicating that its total funding was at 

5 least $370,677 to cover its lifetime spending. Thus, Stand Up for Justice spent at least 78% to 

6 94% of its total funding on making political contributions.

7 Federal tax records show that Alliance for Consumer Protection Inc., contributed 

$150,000 to Stand Up for Justice in 2018.84 8 As indicated above, the Alliance for Consumer 

9 Protection Inc. also contributed $100,000 to Broken Promises in 2018, and its executive director 

is reportedly Pitts’s former college roommate.

85 10 

11 C. Let’s Preserve the American Dream, Inc., was Associated with Pitts and 

12 Matrix

13 Relying on news reports of Matrix’s proposal to FPL, which reference LPAD as a higher14 level Matrix-associated conduit that would receive funds and transmit them to other entities in 

15 Matrix’s network, and news reports indicating that LPAD made donations to Grow United and 

16 Broken Promises, the Complaint alleges that Unknown Respondents used LPAD as a middleman 

to make contributions using the names of Grow United and Broken Promises.86 17 

81 Id. at 1.

82 For 2019 and 2020, Stand Up for Justice filed an IRS Form 990-N, and indicated that its gross receipts 

were not greater than $50,000 in those years. Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/

eos/ (last visited Sept. 25, 2023) (searching organization name “Stand Up for Justice”).

83 Stand Up for Justice 2018 Tax Return at 10, supra note 76. 

84 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095_201812_990O_20211020

19109756.pdf. 

85 Id.; Nightmare Scenario, supra note 10. 

86 Compl. ¶¶ 33 Fig. 1, 35, 37, 42 Fig. 2, 45, 52; see also Secretive Political Spending Plan, supra note 12. 

Attachment 3 

Page 19 of 33

MUR808200366
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 20 of 33

1 In a deposition conducted by the Miami-Dade State Attorney’s Office regarding a former 

2 LPAD contractor’s creation of fake Florida state senate candidates, Tyson stated that he 

3 discussed LPAD’s donation to Grow United with Matrix’s former CEO, Jeff Pitts, and that it was 

4 actually Pitts who proposed for LPAD to make that donation. Specifically, Tyson testified: 

5 Well, as best as I can recall, I called [Pitts] up and I said, “Do you 

6 have any social welfare groups that are interested in working on 

7 issues that are amenable to my organizational narrative? Are they 

8 interested in supporting other interests in other committees around 

9 the country, in Florida specifically too, that would focus purely on 

the center left spectrum and on issues that are center left?”87 10 

11 According to Tyson, Pitts “said he did,” referring to Grow United, and so Tyson “said we’d be 

12 happy to support them.” 

13 In the same above-referenced deposition, Tyson also testified that he spoke with Pitts 

14 about how Grow United should use LPAD’s donation. Specifically, in response to whether 

15 Tyson knew that Alex Alvarado’s Florida state political committees received their funding from 

16 Grow United, Tyson stated, “I told you earlier I knew it came from Grow United. There was a 

17 story about it. And I knew, I actually told Grow United that Alvarado would probably call them 

and ask, raise money.”88 18 Tyson further explained that the person he spoke with was Jeff Pitts. 

19 According to text messages obtained by the Orlando Sentinel, on September 24, 2020, just five 

20 days prior to LPAD making its first $600,000 donation to Grow United on September 29, 2020, 

21 Tyson communicated with Pitts and Abigail MacIver, another former Matrix employee, 

regarding the Florida state senate races that the Alvarado committees were seeking to impact.89 22 

87 Tyson testified in response to the question, “So give me your best recollection of the content of the 

conversation that you had with Jeff Pitts that caused you to want to send the money to Grow United.”

88 Emphasis was added to the original transcription.

89 FPL Execs, supra note 43. 

Attachment 3 

Page 20 of 33

MUR808200367
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 21 of 33

1 When further queried as to whether Tyson “did not authorize the money, the $600,000 

2 [from LPAD], to go to Grow United so they can then turn around and send it to Alex Alvarado’s 

3 two political campaigns,” Tyson testified that he “can’t tell [Grow United] how to spend their 

4 money” and that he “do[es]n’t have the ability to restrain how they spend their funds.” However, 

5 when asked, “Did you know when this $600,000 [from LPAD] was sent to Grow United, that it 

6 was going to [⸺] that 550,000 of it was going to go to Alex Alvarado’s two political 

7 committees,” Tyson testified that he “had a hunch” that Grow United would be supportive of the 

8 Alvarado committees and that he was “not testifying it’s a coincidence.” Tyson further stated, “I 

9 knew [Grow United] would likely be supportive, but I also didn’t know when, I mean, we made 

10 other contributions to them as well. We were supporting a lot of what they were doing.” Tyson 

11 then testified that he “assume[d] [Grow United would] probably be supported [sic] if Alex 

12 called, but I had no way to know if they actually would. Because once I make a contribution to 

13 an entity, I lose control of how they spend that money.” 

14 D. SUN Marketing & Advertising LLC Appears to be Associated with Matrix

15 SUN Marketing & Advertising LLC is another conduit identified in Matrix’s proposal to 

FPL,

90 16 and it appears to have been created by Matrix after the memo was circulated. 

17 Specifically, SUN was formed on December 13, 2019, about two weeks after Pitts reportedly 

emailed the above-referenced proposal to Silagy on November 26, 2019.91 18 FPL spokesman 

19 Reuter reportedly confirmed that FPL gave $250,000 to SUN in December 2019, but stated that 

20 the purpose was to purchase advertising related to a proposed constitutional amendment that FPL 

90 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 32 Fig. 1.

91 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “SUN Marketing & Advertising”). 

Attachment 3 

Page 21 of 33

MUR808200368
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 22 of 33

opposed.92 According to Reuter, FPL believes that SUN is owned by Matrix.93 1 News reports 

indicate that SUN was used to create favorable press for FPL.94 2 SUN’s former sole member, 

Tim Fitzpatrick, was a former FPL officer.95 3 

4 III. LEGAL ANALYSIS

5 A. The Commission Finds Reason to Believe that the $100,000 Contribution 

6 Reported as Having Been Made by the Center for Advancement of Integrity 

7 and Justice, Inc., Was a Contribution Made In the Name of Another

8 The Act and the Commission’s regulations prohibit a person from (1) making a 

9 contribution in the name of another person, (2) knowingly permitting his or her name to be used 

to effect such a contribution, and (3) knowingly accepting such a contribution.96 10 The term 

11 “person” in this context includes partnerships, corporations, and “any other organization or group 

of persons.”97 12 In its regulations, the Commission has illustrated examples of activities that 

13 constitute making a contribution in the name of another, as follows: 

14 (i) Giving money or anything of value, all or part of which was 

15 provided to the contributor by another person (the true contributor) 

16 without disclosing the source of money or the thing of value to the 

17 recipient candidate or committee at the time the contribution is 

18 made; or

92 Secretive Political Spending Plan, supra note 12. 

93 Id.

94 Sarah Blaskey, Powerbrokers: How FPL Secretly Took Over a Florida News Site and Used It to Bash 

Critics, MIAMI HERALD (Aug. 13, 2022), https://www.miamiherald.com/article263757423.html. 

95 PG&E Names Tim Fitzpatrick As Vice President And Chief Communications Officer, CISION PR

NEWSWIRE (Mar. 11, 2013), https://www.prnewswire.com/news-releases/pge-names-tim-fitzpatrick-as-vicepresident-and-chief-communications-officer-197098061.html (“Fitzpatrick joined NextEra Energy in January 2008, 

serving as Vice President of Marketing and Corporate Communications and as an officer of Florida Power & Light 

Company (FPL).”).

96 52 U.S.C. § 30122; see also 11 C.F.R. § 110.4(b).

97 52 U.S.C. § 30101(11); 11 C.F.R. § 100.10.

Attachment 3 

Page 22 of 33

MUR808200369
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 23 of 33

1 (ii) Making a contribution of money or anything of value and 

2 attributing as the source of the money or thing of value another 

person when in fact the contributor is the source.98 3 

4 Because a primary purpose of the Act’s disclosure provisions is to reveal the true source from 

5 which a contribution to a candidate or committee originates, regardless of the mechanism by 

which the funds are transmitted,99 6 the Commission examines the structure of the transaction 

7 itself and the arrangement between the parties to determine who in fact “made” a given 

contribution.100 8 

9 In prior matters, the Commission has found reason to believe that a contribution was 

10 made in the name of another where the available information indicates that another person 

11 provided the funds for the purpose of making the contribution and his or her identity was not 

disclosed to the recipient committee or candidate at the time of the contribution.

101 12 Absent direct 

13 evidence as to the purpose of providing the funds, the Commission considers the overall record

14 to determine its purpose. In the context of contributions made by limited liability companies 

15 (“LLCs”), the Commission has addressed whether the LLC “had the means to make the 

16 contribution absent an infusion of funds provided for that purpose,” the “temporal proximity 

98 11 C.F.R. § 110.4(b)(2)(i)-(ii).

99 See Campaign Legal Ctr. v. FEC, 952 F.3d 352, 354 (D.C. Cir. 2020) (“As the Supreme Court has 

repeatedly declared, the electorate has an interest in knowing where political campaign money comes from and how 

it is spent by the candidate. To that end, the [Act] imposes disclosure requirements on those who give and spend 

money to influence elections. The straw donor provision, 52 U.S.C. § 30122, is designed to ensure accurate 

disclosure of contributor information.”) (internal citations and quotation marks omitted). 

100 Cf. 11 C.F.R. § 110.6(a) (“All contributions by a person made on behalf of or to a candidate, including 

contributions which are in any way earmarked or otherwise directed to the candidate through an intermediary or 

conduit, are contributions from the person to the candidate.”).

101 See, e.g., Factual and Legal Analysis (“F&LA”) at 5, MUR 7903 (Tomfoolery, LLC, et al.) (“[T]he 

contributions made in Tomfoolery’s name were, in fact, actually made by Thomas A. Chavez, when Chavez 

furnished Tomfoolery with funds for the purpose of having the LLC make the contributions.”); F&LA at 1-2, 

MUR 6920 (American Conservative Union) (finding reason to believe that the contribution was made in the name of 

another where the organization who was reported as the contributor later indicated that it was not the true source of 

the contribution, and instead merely delivered the contribution upon receipt of the funds from another person); see 

also 11 C.F.R. § 110.4(b)(2)(i)-(ii).

Attachment 3 

Page 23 of 33

MUR808200370
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 24 of 33

1 between the LLC’s formation date and the contribution,” “the amount of the contribution relative 

2 to [the LLC’s] other activities, the LLC’s known activities prior to making the contribution, and 

3 whether any other information suggests an attempt to circumvent the Act’s disclosure 

4 requirements.” 

5 Here, the available information indicates that the five 2020 political contributions 

6 purportedly made by the alleged Conduit Corporations — Florida Promise, Broken Promises, 

7 Grow United, CAIJ, and Stand Up for Justice — were actually made on behalf of Unknown 

8 Respondents. The overall record indicates that there was plan whose purpose was “to 

9 circumvent the Act’s disclosure requirements” by using the names of the Conduit Corporations 

10 to make contributions and that this plan was implemented in largely the way the blueprint set 

11 out. In addition, the overall record of the Conduit Corporations’ known activities indicate that 

12 they may have been formed for the purpose of making conduit contributions. 

13 Specifically, news articles indicate that, during the 2020 election cycle, Matrix invited 

14 FPL to anonymize its political activities by funneling money through several layers of conduits, 

15 including Florida Promise and Broken Promises, and then using those funds to make federal and 

state political contributions.

102 16 The articles report that Jeff Pitts, former CEO of Matrix, emailed

17 Eric Silagy, former CEO of FPL, a “‘funding memo’” with goals such as making “federal 

18 campaign contributions” and “‘minimiz[ing] all public reporting of entities and activities,’” and a 

“‘legal memo on federal elections support.’”103 19 According to the Orlando Sentinel, the funding 

20 memo included a flowchart depicting FPL’s funds flowing through several layers of conduits 

21 controlled by Pitts and Matrix, including Florida Promise and Broken Promises, before being 

102 Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 3, 31-38. 

103 Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 3, 31-32. 

Attachment 3 

Page 24 of 33

MUR808200371
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 25 of 33

contributed to federal and state political committees.104 1 While the specific plan reported by the 

2 news articles did not directly identify CAIJ, Grow United, or Stand Up for Justice, the proposal 

3 establishes the preexisting idea of making conduit contributions with entities just like these, 

4 which as discussed below, was ultimately carried out using the five alleged Conduit 

5 Corporations. 

6 News articles stated that the sources of the documents were from Matrix itself, noting 

that the documents were internal Matrix documents.105 7 FPL’s spokesperson, David Reuter, 

8 reportedly confirmed that the proposal as reported was indeed shared with its CEO, stating, “‘We 

9 are aware of the proposed structure as the legal memo was shared with us, and as we understand 

10 it, Joe Perkins’[s] team at Matrix created a proposal to fund their clients’ communication and 

outreach activities during 2020.’”106 11 Thus, there is no available information indicating that the 

12 news articles’ report that Pitts and Matrix created and shared a proposal to anonymize political 

13 contributions was inaccurate or not credible. 

14 Moreover, the available information does not indicate that the proposal was limited to 

15 acting solely within the legal bounds of minimizing public reporting of political activities. 

16 Specifically, the proposal did not indicate that Pitts and Matrix were soliciting funds from FPL 

17 on behalf of nonprofit corporations that would independently decide to make political 

18 contributions. Rather, the proposal indicated that funds would flow from FPL, through several 

19 layers of conduits controlled or associated with Matrix, before landing at “Florida Promise C4,” 

104 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

105 See Secretive Political Spending Plan, supra note 12 (stating that the Orlando Sentinel received records 

“includ[ing] checks, bank statements, emails, text messages, invoices, internal ledgers and more, all apparently 

unearthed during an internal investigation Matrix launched after its former employees left the firm at the end of 

2020.”).

106 Id.

Attachment 3 

Page 25 of 33

MUR808200372
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 26 of 33

1 “US Promise C4” and “Fed Promise C4,” which would also be controlled by Matrix, to make 

contributions to state and federal political committees.107 2 

3 Notably, there is no available information indicating that Pitts or Matrix presented the 

4 purposes or goals of the conduits referenced in its flowchart, besides being able to making 

5 political contributions, to explain why FPL’s funds would be expected to flow from one 

corporation to another.108 6 There is also no available information indicating that Pitts and Matrix 

7 presented any information as to why “Florida Promise C4,” “US Promise C4” and “Fed Promise 

8 C4,” would be expected to engage in political activity that FPL would support. Instead, Pitts’s 

9 and Matrix’s flowchart simply noted “Matrix” in a parenthetical below the names of “Broken 

10 Promises,” “Florida Promise C4,” “US Promise C4” and “Fed Promise C4,” similar to how 

11 Tyson, the executive director of LPAD, was included in a parenthetical under LPAD, suggesting 

that these entities are controlled by “Matrix,” similar to how Tyson controlled LPAD.109 12 

13 Moreover, the conduits depicted on the flowchart appear to have been in fact controlled 

14 by or associated with Matrix. Of the conduits mentioned, only Florida Promise, Broken 

15 Promises, LPAD, and SUN existed or eventually came into existence, and they all have ties to 

16 Pitts and/or Matrix. As explained above, Richard Alexander was the chairman of Florida 

Promise, and his sister, April Odom, was a Matrix contractor at the time of the allegations.110 17 

107 Id.; see also Compl. ¶¶ 33 Fig. 1, 36-37. 

108 See Secretive Political Spending Plan, supra note 12 (noting that, for example, “Florida Promise C4” would 

“allowed to spend 50% of revenues on political activities” and that “Florida PCs are allowed to take unlimited funds 

from C4s”); see also Compl. ¶ 33 Fig. 1 (same).

109 See Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1. While the term “person” 

appears in the parenthetical next to SUN, SUN had not yet been formed when Pitts sent the memo, and thus this

denotation appears to suggest that they were looking for a “person” to be in control of SUN at that time. See 

Secretive Political Spending Plan, supra note 12 (reporting that Pitts sent the memo to Silagy on November 26, 

2019).

110 Florida Promise 2018 Tax Return at 3, supra note 32; Dark Money Playbook, supra note 7 (reporting that 

April Odom is Anderson’s sister and was a former Matrix employee).

Attachment 3 

Page 26 of 33

MUR808200373
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 27 of 33

1 Sean J. Anderson, who was the president and chairman of Broken Promises, was also a former 

2 Matrix employee, a close friend of Pitts, and has a history of allowing Pitts to control the 

nonprofits that he purportedly ran.111 3 Tyson, the executive director of LPAD, reportedly 

4 associated with Pitts and Abigail MacIver, another former Matrix employee, as they 

communicated via text messages regarding Florida state senate races.112 5 Finally, as for SUN ⸺

6 FPL, which reportedly gave $250,000 to SUN in December 2019, states that it believes that SUN 

is owned by Matrix.113 7 Thus, the layers of corporations depicted on the flowchart appear to be 

8 linked together because they are controlled by persons associated with Pitts or Matrix. 

9 The available information also indicates that Pitts’s and Matrix’s proposal included the 

10 making of federal political contributions. According to news articles, Pitts’s email to Silagy 

11 included a “‘funding memo’” noting making “federal campaign contributions” as one of its 

goals.114 12 Pitts’s email to Silagy also included “‘a separate legal memo on federal elections 

13 support’” explaining that “a nonprofit might have to disclose its donors if it spent money directly 

14 supporting a candidate” but that “the nonprofit would not have to disclose its donors if it gave 

money to a type of political action committee known as a ‘Super PAC,’”115 15 which is a colloquial 

reference to federal independent expenditure-only committees.116 16 Moreover, this legal memo 

111 Broken Promises, 2018 Tax Return at 1, 7, supra note 60; Bachelor Party, supra note 10 (reporting Pitts as 

having attended Anderson’s bachelor party); Nightmare Scenario, supra note 10 (reporting that Pitts texted FPL 

Vice President Martell that Anderson was an old friend of his and that he was “‘in control 100 percent’” of the 

nonprofits purportedly run by Mr. Anderson).

112 FPL Execs, supra note 43. 

113 Secretive Political Spending Plan, supra note 12. 

114 Id.; see also Compl. ¶ 32.

115 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 38.

116 See McCutcheon v. FEC, 572 U.S. 185, 193 (2014) (“A so-called ‘Super PAC’ is a PAC that makes only 

independent expenditures and cannot contribute to candidates. The base and aggregate limits govern contributions 

to traditional PACs, but not to independent expenditure PACs.”).

Attachment 3 

Page 27 of 33

MUR808200374
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 28 of 33

1 appears to provide the missing explanation as to the purpose of providing funds to the “Fed 

2 Promise C4” entity in the funding memo’s flowchart, indicating that this purpose would be to 

make federal political contributions.117 3 The name, “Fed Promise C4,” also suggests that this 

4 conduit would be used to make federal political contributions, as this would be consistent with 

5 and parallel to the flowchart’s statements that “Florida Promise C4” would be used to fund 

6 “Florida PCs” and that “US Promise C4” would be used to fund other state-level political 

activities.118 7 Thus, the available information indicates that the Pitts/Matrix proposal included 

8 making federal political contributions. 

9 The available information also indicates that the alleged Conduit Corporations received 

10 funds with the direction that they be used for federal contribution purposes as federal courts have 

11 stated that a donor’s intent can be inferred from the donee’s solicitations. Specifically, in the 

12 context of interpreting 52 U.S.C. § 30104(c)(1) of the Act, which courts have held to require notpolitical committees to disclose donations received for political purposes,119 13 a district court in 

14 Wisconsin observed that “whether a contribution is earmarked for political purposes and tied to 

15 an election can depend on whether the contribution is received in response to a solicitation and 

the way the solicitation is worded.”120 16 As explained above, Pitts’s and Matrix’s proposal clearly 

17 implicated the making of federal contributions, and the alleged Conduit Corporations appear to 

18 have received donations in response to that proposal.

19 In addition to conceiving of and sharing the plan, Pitts and Matrix were also in a position 

117 See Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1 (noting that it was 

“[w]aiting on lawyers” to explain the purpose of Fed Promise C4).

118 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

119 Citizens for Resp. & Ethics in Washington v. FEC, 316 F. Supp. 3d 349, 389 (D.D.C. 2018), aff’d, 971 F.3d 

340 (D.C. Cir. 2020).

120 Wisconsin Fam. Action v. FEC, No. 21-C-1373, 2022 WL 844436, at *11 (E.D. Wis. Mar. 22, 2022). 

Attachment 3 

Page 28 of 33

MUR808200375
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 29 of 33

1 to carry it out using the names of alleged Conduit Corporations to make the contributions. As 

2 discussed above, the persons nominally in charge of the alleged Conduit Corporations, 

3 Alexander and Anderson, had close relationships with Pitts and Matrix. Alexander, who served 

4 as a director or officer of Florida Promise, CAIJ, and Grow United, is apparently the brother of 

5 April Odom, who was a Matrix contractor at the time of the contributions and worked on matters 

relating to CAIJ and Grow United on behalf of Matrix.121 6 Anderson, who was the chairman and 

7 president of Broken Promises and a director and president of Stand Up for Justice, was also 

former Matrix employee, and a close friend of Pitts.122 8 Pitts and Matrix also has a history of 

9 working with Anderson’s nonprofit corporations, as Pitts reportedly texted FPL Vice President 

10 Daniel Martell in 2016, four years prior to the contributions at issue here, “‘Bottom line is we are 

11 the ones with the check books and in control 100 percent’” of the nonprofits purportedly run by 

Anderson.123 12 

13 Pitts and Matrix also reportedly used the names of CAIJ and Grow United in other 

operations,124 and had access to CAIJ’s and Grow United’s bank accounts,125 14 further indicating 

15 that they had control over these corporations. Specifically, news reports indicate that, in October 

121 Dark Money Playbook, supra note 7 (reporting that April Odom is Anderson’s sister and was a former 

Matrix contractor); see also Compl. ¶¶ 13, 48.

122 Bachelor Party, supra note 10 (reporting Pitts as having attended Anderson’s bachelor party); Nightmare 

Scenario, supra note 10 (reporting that Pitts texted FPL Vice President Martell that Anderson was an old friend of 

his); see also Compl. ¶¶ 16, 52.

123 Nightmare Scenario, supra note 10; see also Compl. ¶¶ 16, 52. 

124 FPL Execs, supra note 43 (reporting that Matrix made a conduit contribution using CAIJ’s name on behalf 

of FPL); Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/ (reporting that Matrix offered a city councilman 

a job on behalf of FPL using Grow United’s name).

125 Dark Money Playbook, supra note 7 (reporting that internal Matrix records included a text message from

Odom stating that she procured access to the bank accounts of CAIJ and Grow United). 

Attachment 3 

Page 29 of 33

MUR808200376
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 30 of 33

2018, Pitts used CAIJ to make a contribution to House Majority PAC on behalf of Matrix.126 1 

2 News reports also indicate that in the summer of 2019, Matrix used Grow United to offer a job to 

a Jacksonville City Council member on behalf of FPL.127 3 In addition, according to the Orlando 

4 Sentinel, it received internal Matrix documents reflecting a September 23, 2020 text message 

from Odom stating that she procured access to CAIJ’s and Grow United’s bank accounts.128 5 

6 Finally, Tyson, the executive director of LPAD who donated $1,150,000 of LPAD funds to 

7 Grow United, testified that he understood that Pitts created and ran Grow United. Therefore, not 

8 only did Pitts and Matrix conceive of a plan for the making of conduit contributions, they also 

9 had sufficient control over the alleged Conduit Corporations to cause them to permit their names 

10 to be used to make contributions on behalf of Unknown Respondents. 

11 Although all five of the alleged Conduit Corporations were formed more than a year prior 

12 to making the contributions, the overall record of their known activities indicate that they were 

13 formed for the purpose of making conduit contributions. The only available information as to 

14 the five alleged Conduit Corporations’ activities was that they made federal and Florida state 

political contributions.129 15 Broken Promises and Stand Up for Justice spent at least 67% to 89% 

126 FPL Execs, see supra note 43 (reporting that Silagy, former CEO of FPL, emailed Pitts, former CEO of 

Matrix, to make a contribution to House Majority PAC to support Lauren Baer, and to make sure that “they don’t 

triangulate this donation to others we have done”); see also House Majority PAC, 2018 Amended 12-Day PreElection Report at 655 (Dec. 3, 2018), https://docquery.fec.gov/pdf/085/201812069135107085/20181206913510

7085.pdf (reflecting CAIJ’s contribution to House Majority PAC on October 16, 2018).

127 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/. FPL reportedly confirmed that Matrix 

employees came up with an idea to offer the City Council member a job, but that it rejected the idea. Id. 

128 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right-hand corner 

of the article’s sixth picture); see also Compl. ¶ 48.

129 Although Matrix reportedly used Grow United to offer a job to a Jacksonville council member, that never 

came to fruition as the council member rejected the offer. Nate Monroe, Amid JEA Privatization Controversy, a 

City Council Member Received a Mysterious Job Offer. A Dark-Money Group May Have Been Behind It, THE FL

Attachment 3 

Page 30 of 33

MUR808200377
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 31 of 33

1 and 78% to 94%, respectively, of their total funding on making federal and Florida state political 

2 contributions, indicating that they were created for the primary purpose of making political 

contributions.130 3 Moreover, consistent with the Pitts’s and Matrix’s proposal, federal tax records 

4 show that their funding was first transmitted through another Matrix-associated conduit, the 

5 Alliance for Consumer Protection Inc., which was reportedly controlled by Pitts’s former college 

roommate.131 6 While the available information does not indicate the total funding received by 

7 Florida Promise, CAIJ, or Grow United, the only known activities by these corporations are that 

they made an aggregate of $3,224,500 in federal and Florida state political contributions.

132 8 

9 In addition, only Florida Promise, Broken Promises, and Stand Up for Justice appeared to 

10 have filed federal tax returns, and these returns do not indicate that they engaged in any activity 

other than making political contributions, including through lobbying.133 11 The purpose 

12 statements in these tax returns indicate that Florida Promise, Broken Promises, and Stand Up for 

13 Justice were formed for political purposes, further suggesting they only engaged in political 

TIMES-UNION (Sept. 2, 2022), https://www.jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-salejacksonville-city-council-member-mysterious-job-offer-dark-money-group-nate-monroe/8850689002/. 

130 See supra pages 15-16, 18-19.

131 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095_201812_990O_20211020

19109756.pdf; Nightmare Scenario, supra note 10. 

132 See supra notes 33-34 and accompanying text (reflecting that Florida Promise made $1,230,000 in federal 

and Florida state contributions); supra notes 38, 40, 38 and accompanying text (reflecting that CAIJ made $432,000 

in federal and Florida state contributions); supra notes 46, 49 and accompanying text (reflecting that Grow United 

made $1,562,500 in federal and Florida state contributions).

133 See generally Florida Promise 2018 Tax Return, supra note 32; Broken Promises 2018 Tax Return, supra

note 60; Stand Up for Justice 2018 Tax Return, supra note 76. As indicated above, while Broken Promises and 

Stand Up for Justice indicated in their 2018 federal tax returns that they spent funding on “lobbying” and “other”

program expenses in 2018, the amounts they reportedly spent correspond to the same amounts that they spent on 

making Florida state political contributions. See supra pages 16, 18. 

Attachment 3 

Page 31 of 33

MUR808200378
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 32 of 33

activities.

134 1 

2 Furthermore, there are various organizational aspects of the alleged Conduit Corporations 

3 that suggest they were formed to serve as conduits. Specifically, despite the fact that CAIJ and 

4 Stand Up for Justice were incorporated in different states and do not share any officers, both 

entities reported having the same mailing address in Washington, D.C.135 5 In addition, despite 

6 both Broken Promises and Stand Up for Justice having the same three officers and nearly 

7 identical mission statements, both entities were incorporated on the same day in the same 

state.

136 8 Finally, Broken Promises’s federal tax return suggests that it was trying to conceal that 

9 it made political contributions. Specifically, Broken Promises characterized on its 2018 federal 

10 tax return that it spent $115,470 on “other” program service expenses, when that amount was 

actually used to make in-kind contributions to Florida state committees.137 11 Thus, the available 

12 information as to the activities, stated purpose, and creation of the Conduit Corporations suggests 

13 that they were created for making conduit contributions. 

134 Florida Promise 2018 Tax Return at 6, supra note 32 (stating that its purpose is to “develop and advocate 

for legislation, regulations, and government programs related to policies to benefit Floridians”); Broken Promises 

2018 Tax Return at 2, supra note 60 (stating that its purpose is to “develop[] and advocat[e] for legislation, 

regulations, and government programs to improve social environmental, economy and social environment”); Stand 

Up for Justice 2018 Tax Return at 2, supra note 76 (stating that its purpose is to “develop[] and advocat[e] for 

legistlation [sic], regulations, and government programs to improve social environment, economy & society”).

135 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting that CAIJ’s address was at 2020 Pennsylvania Avenue, 

NW, Ste. 449, Washington DC 20006); CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing

(last visited Sept. 25, 2023) (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for 

Justice’s business address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006). 

136 See CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023) 

(searching the organization names “Broken Promises” and “Stand Up For Justice”) (reflecting that both Broken 

Promises and Stand Up for Justice were incorporated on August 29, 2018); Broken Promises 2018 Tax Return at 1, 

7, supra note 60; Stand Up for Justice 2018 Tax Return at 1, 7, supra note 76. 

137 Compare Broken Promises 2018 Tax Return at 10, supra note 60 (stating that it spent $115,470 in “other” 

program service expenses), with Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.

myflorida.com/campaign-finance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and 

contributor last name “Broken Promises”) (reflecting that Broken Promises Broken Promises made $115,470 in inkind Florida state political contributions in 2018).

Attachment 3 

Page 32 of 33

MUR808200379
MUR 8082 (Center for Advancement of Integrity and Justice, Inc.) 

Factual and Legal Analysis

Page 33 of 33

1 In sum, the available information indicates that there was a plan to illegally disguise or 

2 withhold public reporting of political activities, and that this plan included making contributions 

3 through conduits and in a manner that closely matches what the available information shows had 

4 subsequently occurred. In addition, pursuant to this plan, the alleged Conduit Corporations 

5 permitted their names to be used to make federal political contributions on behalf of Unknown 

6 Respondents. Finally, the only known activities of the alleged Conduit Corporations were that 

7 they made federal and Florida state political contributions, indicating that their purpose was to 

8 serve as conduits. Thus, the Commission finds reason to believe that the Center for 

9 Advancement of Integrity and Justice, Inc., violated 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b) 

10 by knowingly permitting its name to be used to effect contributions in the name of another. 

Attachment 3 

Page 33 of 33

MUR808200380
1 FEDERAL ELECTION COMMISSION

2 FACTUAL AND LEGAL ANALYSIS

3 RESPONDENT: Grow United, Inc. MUR 8082 

4 I. INTRODUCTION

5 The Complaint alleges that Unknown Respondents made contributions in the name of 

6 another through a network of conduits associated with a political consulting firm called Matrix 

LLC (“Matrix”), to five federal independent expenditure-only political committees (“IEOPCs”).

1 7 

8 The specific contributions identified in the Complaint are as follows: 

9 • a $1,000,000 contribution reportedly from Florida Promise, Inc. (“Florida Promise”)

to Senate Leadership Fund, dated December 8, 2020;2 10 

11 • a $100,000 contribution reportedly from the Center for Advancement of Integrity and

Justice, Inc. (“CAIJ”) to American Valor PAC, dated October 27, 2020;3 12 

13 • a $100,000 contribution reportedly from Grow United, Inc. (“Grow United”) to

Conservative Action Fund (f/k/a Wingman PAC), also dated October 27, 2020;4 14 

15 • a $20,000 contribution reportedly from Broken Promises to Concerned

Conservatives, Inc., dated July 14, 2020;5 16 and

17 • a $50,000 contribution reportedly from Stand Up for Justice to South Florida

Residents First, dated March 31, 2020.6 18 

1 Compl. ¶¶ 2, 5, 27, 42, 89-93 (Oct. 27, 2022).

2 Senate Leadership Fund, Amended 2020 Year End Report at 72 (Mar. 18, 2021), https://docquery.fec.gov/

pdf/807/202103189441299807/202103189441299807.pdf; see also Compl. ¶¶ 49-50.

3

 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/2020

12039337569242/202012039337569242.pdf; see also Compl. ¶¶ 47-48.

4

 Wingman PAC, 2020 30-Day Post Election Report at 1, 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting a $100,000 contribution from Grow United, Inc., on 

October 27, 2020, and the committee’s FEC identification number of C00742296); Conservative Action Fund, 

Amended Statement of Organization at 1 (May 20, 2022), https://docquery.fec.gov/pdf/048/202205209512421048/

202205209512421048.pdf (reflecting that its name has changed to Conservative Action Fund and that its FEC 

identification number is C00742296); see also Compl. ¶¶ 43-44.

5 Concerned Conservatives, Inc., 2020 12-Day Pre-Primary Election Report at 6 (Aug. 6, 2020), https://doc

query.fec.gov/pdf/823/202008069261263823/202008069261263823.pdf; see also Compl. ¶¶ 51-52.

6

 South Florida Residents First, 2020 April Quarterly Report at 11 (Apr. 13, 2020), https://docquery.fec.gov/

pdf/294/202004159216942294/202004159216942294.pdf; see also Compl. ¶¶ 53-54.

Attachment 4 

Page 1 of 33

MUR808200381
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 2 of 33

1 The Complaint relies on news articles regarding a 2019 email and two accompanying 

2 memoranda sent from Jeff Pitts, Matrix’s former CEO, to Eric Silagy, Florida Power & Light 

3 Company’s (FPL) former CEO, reportedly proposing a method for FPL to make anonymous 

4 contributions to federal and state political committees by transferring funds through multiple 

levels of conduits.7 5 The proposal called for funds to be first sent to and passed through higher6 level Matrix-associated conduits, including SUN Marketing & Advertising LLC (“SUN”) and 

7 Let’s Preserve the American Dream, Inc. (“LPAD”), before being sent to various lower-level 

8 Matrix-controlled conduits, including Florida Promise, that would be reported as the source of 

9 the contributions. Thus, the Complaint alleges that each of the five alleged lower-level Matrix10 controlled conduits (referred to herein as the “Conduit Corporations”) permitted their names to 

11 be used to effect contributions in the name of another pursuant to Pitts’s and Matrix’s proposal. 

12 To support its central allegation, the Complaint alleges that all five of the alleged Conduit 

13 Corporations had ties to Pitts or Matrix through having either Richard Alexander or Sean J. 

Anderson as a director or officer.

8 14 Citing news articles, the Complaint alleges that Alexander’s 

sister was a Matrix contractor at the time of the allegations9 15 and that Anderson was a former 

Matrix employee and a good friend of Pitts.10 16 

7

 Compl. ¶¶ 3-4, 28-41; see, e.g., Jason Garcia & Annie Martin, Florida’s Dark Money Playbook: How 

‘Ghost’ Candidate Scheme Revealed Secretive Political Tactics, ORLANDO SENTINEL (Dec. 30, 2021), 

https://www.orlandosentinel.com/news/os-ne-dark-money-ghost-candidates-tactics-20211230-7zelkoadffclde3z

76ax3cgx3m-htmlstory.html [hereinafter Dark Money Playbook].

8

 Compl. ¶¶ 13, 16. 

9

 Id. ¶ 13; see Dark Money Playbook, supra note 7 (reporting that Alexander’s sister, April Odom, was a 

Matrix employee at the time of the allegations, and that she worked on matters relating to Grow United and CAIJ).

10 Compl ¶ 16; see John Archibald, Archibald: ‘Bachelor party’ Makes For Strange Bedfellows, AL.COM

(Nov. 14, 2010), https://www.al.com/archiblog/2010/11/archibald bachelor party makes.html [hereinafter 

“Bachelor Party”] (reporting that Pitts attended Anderson’s bachelor party and that they were both employed by 

Matrix at the time); Mary Ellen Klas, et al., ‘Nightmare Scenario’: How FPL Secretly Manipulated a Florida State 

Senate Election, MIAMI HERALD (Aug. 29, 2022), https://www.miamiherald.com/news/politics-government/statepolitics/article264196761.html [hereinafter “Nightmare Scenario”] (reporting that Pitts texted FPL vice president 

Attachment 4 

Page 2 of 33

MUR808200382
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 3 of 33

1 As discussed below, the five contributions purportedly made by the alleged Conduit 

2 Corporations as identified by the Complaint appear to be consistent with the conduit 

3 contributions proposed by Pitts and Matrix to FPL to anonymize its political contributions. In 

4 addition, all five of the alleged Conduit Corporations appear to be controlled by or associated 

5 with Pitts and Matrix. Accordingly, the Commission finds reason to believe that Grow United, 

6 Inc., violated 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b) by knowingly permitting its name to 

7 be used to effect contributions in the name of another. 

8 II. FACTUAL BACKGROUND

9 A. Jeff Pitts of Matrix Appears to Have Created a Plan to Anonymize Federal 

10 Political Contributions Using a Network of Conduits Controlled by or 

11 Associated with Pitts or Matrix 

Matrix is a “strategic communications firm” based in Alabama.11 12 According to the 

13 Orlando Sentinel, it received a cache of internal documents from Matrix, “includ[ing] checks, 

14 bank statements, emails, text messages, invoices, internal ledgers and more, all apparently 

15 unearthed during an internal investigation Matrix launched after its former employees left the 

firm at the end of 2020.”12 16 These internal records included a copy of a November 26, 2019 

17 email sent from former Matrix CEO, Jeff Pitts, to former FPL CEO, Eric Silagy, stating, 

18 “‘Attached is an updated funding memo along with a separate legal memo on federal elections 

support.’”13 19 The “funding memo” noted goals such as making “federal campaign contributions” 

Daniel Martell that Anderson was an old friend of his and that Pitts was in control of the nonprofits run by 

Anderson).

11 Matrix, LLC, v. Canopy Partners, LLC, et al, 2021 WL 3127729 (Ala. Cir. Ct.).

12 Jason Garcia & Annie Martin, Operative Pitched Secretive Political Spending Plan to FPL Exec’s Email 

Alias, Records Reveal, ORLANDO SENTINEL (Jan. 24, 2022), https://www.orlandosentinel.com/politics/os-ne-floridapower-and-light-matrix-dark-money-20211217-v64274eytjeb5hnstdognvqds4-story.html [hereinafter “Secretive 

Political Spending Plan”]. 

13 Id.; see also Compl. ¶¶ 3, 31-38.

Attachment 4 

Page 3 of 33

MUR808200383
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 4 of 33

and “‘minimiz[ing] all public reporting of entities and activities.’”14 1 It also included a flowchart

2 depicting money flowing from FPL through a network of conduits before being contributed to 

federal and state political committees, as reproduced below:15 3 

14 See Secretive Political Spending Plan, supra note 12; Compl. ¶ 32.

15 See Secretive Political Spending Plan, supra note 12; Compl. ¶ 33 Fig. 1.

Attachment 4 

Page 4 of 33

MUR808200384
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 5 of 33

1 Notably, next to or below the name of each conduit is a parenthetical, which may indicate the 

2 person or entity controlling or associating with that conduit. Specifically, the flowchart 

3 identifies a “LPAD C4 (Tyson),” which appears to refer to LPAD and its executive director Ryan 

Tyson.16 4 The flowchart also identifies “Matrix/Foley” in a parenthetical next to or below the 

16 See Compl. ¶ 35.

Attachment 4 

Page 5 of 33

MUR808200385
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 6 of 33

1 names of the following conduits: “Broken Promises,” “Florida Promise C4,” “US Promise C4,” 

2 and “Fed Promise C4,” suggesting that these conduits are directly associated with and/or 

controlled by Matrix and its legal counsel, Foley and Lardner, LLP (“Foley”).17 3 

4 According to the flowchart, money could flow to a “Florida Promise C4,” which could 

5 “spend 50% of revenues on political activities” due to its tax status as a section 501(c)(4) 

6 corporation, and be used to contribute to Florida state political committees on the basis that 

“Florida PCs are allowed to take unlimited funds from C4s.”18 7 Money could also flow to a “US 

8 Promise C4,” which similarly could “spend 50% of revenues on political activities” due to its tax 

9 status, and be used to contribute to other states’ political committees on the basis that “[e]ach 

state operates under unique state elections.”19 10 Lastly, the flowchart indicates that money could 

11 flow to a “Fed Promise C4,” but because Matrix was “[w]aiting on lawyers,” it could not state

the purpose of this proposed funding.20 12 

13 The legal memo attached to the email, which was drafted by Foley attorney Erika Alba, 

addressed “the legalities of using nonprofits to spend money on federal elections.”21 14 The memo 

15 states that “a nonprofit might have to disclose its donors if it spent money directly supporting a 

16 candidate,” but that “the nonprofit would not have to disclose its donors if it gave money to a 

17 type of political committee known as a “‘Super PAC’” (i.e., an IEOPC) “that then spent money 

supporting the candidate.”22 18 The legal memo then concluded: “‘Thus, it could be strategic for a 

17 See Secretive Political Spending Plan, supra note 12 (noting that Erika Alba of Foley & Lardner LLP 

drafted a legal memo attached to the email); see also Compl. ¶ 38 (alleging the same). 

18 Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 33 Fig. 1, 37.

19 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

20 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

21 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 38.

22 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 38.

Attachment 4 

Page 6 of 33

MUR808200386
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 7 of 33

[nonprofit] who wishes to make Independent Expenditures to do so via a Super PAC.’”23 1 

2 Based on the record of contributions disclosed by the recipient IEOPCs and news articles 

3 reporting that LPAD provided funding to Grow United and Broken Promises, the Complaint 

depicts the implementation of the Matrix plan as taking the following altered form:24 4 

5 

6 The Complaint alleges that Matrix pitched the above-referenced plan to Unknown 

7 Respondent clients, noting that FPL’s spokesperson, David Reuter, stated, “‘We are aware of the 

8 proposed structure as the legal memo was shared with us, and as we understand it, Joe 

23 Secretive Political Spending Plan, supra note 12 (alteration in original); see also Compl. ¶ 38.

24 Compl. ¶¶ 42 Fig. 2, 45, 52.

Attachment 4 

Page 7 of 33

MUR808200387
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 8 of 33

1 Perkins’[s] team at Matrix created a proposal to fund their clients’ communication and outreach 

activities during 2020.’”25 2 

3 B. The Alleged Conduit Corporations Appear to Have Been Controlled by or 

4 Associated with Pitts and/or Matrix 

5 The Complaint alleges that five alleged Conduit Corporations, Florida Promise, CAIJ, 

6 Grow United, Broken Promises, and Stand Up for Justice, permitted their names to effect the 

7 $1.27 million in contributions that they purportedly made to IEOPCs on behalf of Unknown 

Respondents.26 8 Richard Alexander served as a director or officer of the first three alleged 

9 Conduit Corporations, while Sean J. Anderson was a director or officer of the latter two. 

10 According to news reports, both Alexander and Anderson had close ties to Matrix. 

11 Alexander’s sister, April Odom, was a Matrix contractor at the time of the allegations and 

12 reportedly worked on behalf of Matrix regarding CAIJ and Grow United, which were entities 

associated with Alexander.

27 13 Anderson, on the other hand, was a former Matrix employee, and 

reportedly a close friend of Pitts. 28 14 Anderson also has a history of working with Pitts, as Pitts 

15 reportedly texted FPL Vice President Daniel Martell in 2016, four years prior to the alleged 

16 contributions, as follows: “‘Bottom line is we are the ones with the check books and in control 

100 percent’” of the nonprofits purportedly run by Anderson.29 17 The discussion below sets out 

18 the available information about each of the alleged Conduit Corporations and their relationships 

19 with Pitts and/or Matrix.

25 Secretive Political Spending Plan, supra note 12 (emphasis added); Compl. ¶ 40 (emphasis added). 

26 Compl. ¶¶ 5, 43-54.

27 Dark Money Playbook, supra note 7 (reporting that April Odom is Anderson’s sister and was a former 

Matrix employee); see also Compl. ¶¶ 13, 48.

28 Bachelor Party, supra note 10; Nightmare Scenario, supra note 10 (reporting that Pitts texted FPL Vice 

President Martell that Anderson was an old friend of his); see also Compl. ¶ 16.

29 Nightmare Scenario, supra note 10; see also Compl. ¶ 16. 

Attachment 4 

Page 8 of 33

MUR808200388
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 9 of 33

1 1. Florida Promise, Inc. 

2 Florida Promise is a corporation identified in Matrix’s proposal to FPL that could be used 

as a conduit to make contributions to Florida political committees,

30 3 and it was incorporated on 

December 18, 2018.31 4 According to Florida Promise’s 2018 federal tax return, it is a 501(c)(4) 

5 corporation; its mission is to “develop and advocate for legislation, regulations, and government 

6 programs related to policies to benefit Floridians”; Alexander was its chairman; it did not have a 

website; and it did not have any expenses or revenue that year.32 7 

8 On December 8, 2020, Florida Promise made a $1,000,000 contribution to the Senate 

Leadership Fund.33 9 In addition, consistent with Matrix’s proposal to use Florida Promise to

10 make Florida political contributions, Florida Promise also made contributions to Florida political 

committees on June 12, 2019, and January 27, 2021, totaling $230,000.34 11 Other than making the 

12 $1,230,000 in federal and Florida state political contributions, there is no publicly available 

13 information regarding Florida Promise’s activities. 

30 See Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 33 Fig. 1, 50. 

31 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Florida Promise”); see also Compl. ¶ 12.

32 IRS Form 990-EZ, Florida Promise, Inc., 2018 Short Form Return of Organization Exempt from Income 

Tax at 2-3, 6 (Nov. 13, 2019), https://apps.irs.gov/pub/epostcard/cor/832961305_201812_990EO_202006011716

8825.pdf [hereinafter Florida Promise 2018 Tax Return]. 

33 Senate Leadership Fund, Amended 2020 Year End Report at 72 (Mar. 18, 2021), https://docquery.fec.gov/

pdf/807/202103189441299807/202103189441299807.pdf; see also Compl. ¶ 49. 

34 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (searching “all” election years with contributor’s last name 

starting with “Florida Promise”); see also Compl. ¶ 50.

Attachment 4 

Page 9 of 33

MUR808200389
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 10 of 33

1 2. Center for Advancement of Integrity and Justice, Inc. 

CAIJ was incorporated on October 1, 2018,35 2 and shared a mailing address with Stand Up 

for Justice.36 There are no publicly available CAIJ federal tax returns.37 3 Alexander served as 

4 either a director or officer of CAIJ.

On October 27, 2020, CAIJ made a $100,000 contribution to American Valor PAC,38 5 an 

6 IEOPC that made independent expenditures during the 2020 election cycle solely in Florida’s

7 13th Congressional District, which supported Anna Paulina Luna, the Republican nominee, and 

opposed Charlie Joseph Crist, the Democratic nominee.39 8 CAIJ also made contributions to 

9 Florida political committees totaling $307,000, starting in November 2018 and through 

December 2020.

40 10 

35 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Center for Advancement of Integrity and 

Justice”); see also Compl. ¶ 11.

36 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting that CAIJ’s address was at 2020 Pennsylvania Avenue, 

NW, Ste. 449, Washington DC 20006); CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing

(last visited Sept. 25, 2023) (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for 

Justice’s business address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006). 

37 On May 15, 2021, the IRS automatically revoked CAIJ’s 501(c)(4) status for not filing a Form 990s-series 

return for three consecutive years, suggesting that CAIJ has not filed any tax returns. See Tax Exempt Organization 

Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited July 25, 2023) (searching the organization name “center 

for advancement of integrity” which reflect that CAIJ’s federal tax exempt status was automatically revoked on May 

15, 2021for not filing a Form 990-series return or notice for three consecutive years).

38 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf; see also Compl. ¶ 47. 

39 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00757179&is_notice=false&most_recent=true (last visited 

Aug. 18, 2023) (reflecting independent expenditures made by American Valor PAC); November 3, 2020 General 

Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=

11/3/2020&DATAMODE= (last visited Sept. 25, 2023) (selecting “Federal Offices”) (reflecting that Anna Luna 

was the Republican nominee and that Charlie Crist was the Democratic nominee in Florida’s 13th Congressional 

District).

40 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited July 25, 2023) (searching “all” election years with contributor’s last name starting 

with “center for advancement”).

Attachment 4 

Page 10 of 33

MUR808200390
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 11 of 33

1 While CAIJ was not referenced by name in Matrix’s proposal to FPL, news reports 

2 suggest that it was controlled by Matrix. Specifically, Matrix’s internal files reportedly include a 

3 September 23, 2020 text message from Odom, Alexander’s sister and a Matrix contractor at the 

time of the allegations, stating that she procured access to CAIJ’s bank account.41 4 In addition, 

5 on October 16, 2018, just 15 days after CAIJ’s incorporation, CAIJ made a $25,000 contribution 

to House Majority PAC.42 6 According to news reports, FPL directed Matrix to make this 

7 contribution on its behalf to support Lauren Baer, who was seeking election in Florida’s 18th 

8 Congressional District, and asked Matrix to ensure that House Majority PAC “‘do[es]n’t 

triangulate this donation to others we have done.’”43 9 Other than making the $432,000 in federal 

10 and Florida state political contributions, there is no publicly available information regarding 

11 CAIJ’s activities. 

41 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right-hand corner 

of the article’s sixth picture); see also Compl. ¶ 48.

42 House Majority PAC, 2018 Amended 12-Day Pre-Election Report at 655 (Dec. 3, 2018), https://docquery

.fec.gov/pdf/085/201812069135107085/201812069135107085.pdf. 

43 Jason Garcia & Annie Martin, Florida Power & Light Execs Worked Closely with Consultants Behind 

‘Ghost’ Candidate Scheme, Records Reveal, ORLANDO SENTINEL (Apr. 14, 2022), https://www.orlandosentinel.com/

politics/os-ne-florida-power-and-light-senate-ghost-candidates-20211202-szjhv7ox6vcmphm6pgd437y52i-htmlstory

.html [hereinafter “FPL Execs”] (reporting that Silagy forwarded Pitts instructions to make a contribution to House 

Majority PAC to support Lauren Baer and to make sure that “they don’t triangulate this donation to others we have 

done”); November 6, 2018 General Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.my

florida.com/Index.asp?ElectionDate=11/6/2018&DATAMODE= (last visited Sept. 25, 2023) (reflecting that Lauren 

Baer was the democratic nominee in Florida’s 18th Congressional District). 

Attachment 4 

Page 11 of 33

MUR808200391
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 12 of 33

1 3. Grow United, Inc. 

Grow United was incorporated on July 24, 2019.44 2 There are no publicly available Grow 

3 United federal tax records and it did not identify itself as a nonprofit organization to the Internal 

Revenue Service.

45 4 Alexander served either as a director or officer of Grow United. 

On October 27, 2020, Grow United made a $100,000 contribution to Wingman PAC,46 5 

now known as the Conservative Action Fund.47 6 Wingman PAC made independent expenditures 

7 during the 2020 election cycle solely in Florida’s 15th Congressional District, which supported 

8 Scott Franklin, the Republican nominee; opposed Alan Michael Cohn, the Democratic nominee; 

9 and opposed Vincent Spano Ross, who competed against Franklin for the Republican 

44 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Grow United”). 

45 See Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited Sept. 25, 2023)

(reflecting that there are no results when searching Grow United’s name or its EIN number identified in the 

Complaint, 84-2546999). 

46 Wingman PAC, 2020 30-Day Post Election Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/423/

202012039338666423/202012039338666423.pdf (reflecting a $100,000 contribution from Grow United on October 

27, 2020).

47 Id. at 1(reflecting an FEC identification number of C00742296); Conservative Action Fund, Amended 

Statement of Organization at 1 (May 20, 2022), https://docquery.fec.gov/pdf/048/202205209512421048/2022

05209512421048.pdf (reflecting that its name has changed to Conservative Action Fund and its FEC identification 

number is C00742296). 

Attachment 4 

Page 12 of 33

MUR808200392
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 13 of 33

nomination.48 1 Earlier that month, from October 3, 2020, through October 20, 2020, Grow 

United made contributions to Florida state political committees totaling $1,462,500.49 2 

3 Grow United appears to have been created and controlled by Pitts and Matrix. Ryan 

4 Tyson, the executive director of LPAD — which contributed $1,150,000 to Grow United in 

202050 5 — was deposed by the Miami-Dade State Attorney’s Office in a criminal matter 

6 regarding a former LPAD contractor’s creation of fake Florida state senate candidates during the 

7 2020 election cycle. Tyson testified in the deposition that he understood that Jeff Pitts started 

8 and ran Grow United. In addition, FPL reportedly asserted that Grow United was created by 

Matrix.51 9 

10 Matrix’s internal records also reportedly indicate that it had control of Grow United. 

11 According to news reports, Matrix’s internal ledger reflect an August 7, 2019 entry billed to FPL 

12 for “‘Grow United SOS Fees,’” which likely referred to the fees charged by the Delaware 

48 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00742296&is_notice=false&min_date=01%2F01%2F2019&max

_date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting Wingman PAC’s independent expenditures in the 

2020 election cycle); November 3, 2020 General Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results

.elections.myflorida.com/Index.asp?ElectionDate=11/3/2020&DATAMODE= (last visited Sept. 25, 2023) 

(selecting “Federal Offices”) (reflecting that Scott Franklin was the Republican nominee and Alan Cohn was the 

Democratic nominee in Florida’s 15th Congressional District); August 18, 2020 Primary Election Republican 

Primary, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate

=8/18/2020&DATAMODE= (last visited Sept. 25, 2023) (selecting “Federal Offices” in the Republican Primary 

section) (reflecting that both Scott Franklin and Ross Spano were seeking the Republican nomination in Florida’s 

15th Congressional District).

49 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (selecting election year “all” and searching contributor last name 

starting with “grow united”); see also Compl. ¶ 46.

50 See Compl. ¶ 45.

51 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Dec. 10, 2021, updated Sept. 2, 

2022), https://www.jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-citycouncil-member-mysterious-job-offer-dark-money-group-nate-monroe/8850689002/. Joe Perkins, owner of Matrix, 

denies that Matrix created Grow United, and Perkins’s attorney asserts that “[t]o the extent any rogue Matrix 

employees were involved in those activities, they were undertaken in secret, without Dr. Perkins’[s] knowledge or 

consent.” Id.

Attachment 4 

Page 13 of 33

MUR808200393
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 14 of 33

Secretary of State for incorporating Grow United a few weeks prior.

52 1 Matrix’s internal records 

2 also reportedly include a September 23, 2020 message from Odom stating that she procured 

access to Grow United’s bank account.53 3 In addition, as part of her duties at Matrix, Odom 

4 reportedly sent checks from Grow United to make contributions to Florida committees, asked the 

committees to confirm their receipt of the checks,54 5 and emailed a $12,813.54 invoice to Matrix

6 with the subject line, “FPL Expenses for Grow United c4,” for expenses that included traveling 

to Colorado to update the nonprofit’s mailbox at a UPS Store in Denver.55 7 

8 News articles also report that, in the summer of 2019, Matrix used Grow United to offer a 

job to a Jacksonville City Councilmember on behalf of FPL.56 9 Furthermore, Foley attorney 

10 Erika Alba reportedly billed Matrix in the fall of 2020 for her work on IRS submission forms for 

Grow United.57 11 Other than making the $1,562,500 in political contributions, there is no publicly 

12 available information regarding Grow United’s activities.

52 FPL Execs, supra note 43. 

53 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right corner of the 

article’s sixth picture); see also Compl. ¶ 48.

54 Dark Money Playbook, supra note 7. 

55 FPL Execs, supra note 43. 

56 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/. FPL reportedly confirmed that Matrix 

employees came up with an idea to offer the City Council member a job, but that it rejected the idea. Id. 

57 Nate Monroe, Law Firm that Advised on Botched JEA Sale Also Helped Former FPL Consultants On 

Dark-Money Projects, FL TIMES-UNION (Dec. 17, 2021), https://www.jacksonville.com/story/news/columns/natemonroe/2021/12/17/jea-privatization-law-firm-foley-lardner-also-helped-former-fpl-consultants-political-giving/

8850686002/. There are no publicly available tax forms from Grow United, Inc., however. See Tax Exempt 

Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited Sept. 25, 2023) (reflecting that there are no 

results when searching Grow United’s name or its EIN number identified in the Complaint, 84-2546999).

Attachment 4 

Page 14 of 33

MUR808200394
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 15 of 33

1 4. Broken Promises 

2 Broken Promises is referenced by name in Matrix’s proposal to FPL as a middleman that 

3 would receive funds and send them to conduits, including Florida Promise, that would in turn 

make political contributions.58 4 Broken Promises was incorporated on August 29, 2018, along 

with Stand Up for Justice.59 5 According to Broken Promises’s federal tax return for the 2018 

6 calendar year, it is a 501(c)(4) corporation; its purpose is to “develop[] and advocat[e] for 

7 legislation, regulations, and government programs to improve social environmental, economy 

8 and social environment”; Sean J. Anderson is its president and chairman; it did not have a 

website; and it received $200,000 of funding that year.60 9 In addition, according to news reports, 

Broken Promises reportedly received $26,000 from LPAD on July 9, 2020.61 10 

11 On July 14, 2020, five days after reportedly receiving the $26,000 from LPAD, Broken 

Promises made a $20,000 contribution to Concerned Conservatives, Inc., an IEOPC.62 12 During 

13 the 2020 election cycle, Concerned Conservatives, Inc., made independent expenditures only in 

14 Florida’s 19th Congressional District to support Dane Eagle, who unsuccessfully ran for the 

15 Republican nomination, and oppose his competitors, William Matthew Figlesthaler, Byron 

58 See Secretive Political Spending Plan, supra note 12; Compl. ¶¶ 33 Fig. 1, 52. 

59 CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023)

(searching the organization name “Broken Promises” and “Stand Up for Justice”).

60 See IRS Form 990, Broken Promises, 2018 Return of Organization Exempt from Income Tax at 1, 7 

(Nov. 15, 2019), https://apps.irs.gov/pub/epostcard/cor/831745117_201812_990O_2020012317057600.pdf

[hereinafter Broken Promises 2018 Tax Return] (reflecting an unfilled line for the organization’s website).

61 Jeff Weiner & Annie Martin, Bank Records Shed Light on Dark-Money Group in ‘Ghost’ Candidate 

Scandal, ORLANDO SENTINEL (Apr. 18, 2022), https://www.orlandosentinel.com/2022/04/18/bank-records-shedlight-on-dark-money-group-in-ghost-candidate-scandal/; see Compl. ¶ 52.

62 Concerned Conservatives, Inc., 2020 12-Day Pre-Primary Election Report at 6 (Aug. 6, 2020), 

https://docquery.fec.gov/pdf/823/202008069261263823/202008069261263823.pdf; see also Compl. ¶ 51.

Attachment 4 

Page 15 of 33

MUR808200395
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 16 of 33

Donalds, and Casey Askar.63 1 In addition, in 2018, Broken Promises made $160,470 in Florida 

2 state political contributions, and in 2019, it made $21,500 in Florida state political 

contributions.64 3 Thus, it appears that Broken Promises made at least $201,970 in political 

4 contributions during its existence. 

5 According to Broken Promises’s federal tax returns and other information received by the 

6 Commission, it received a total of $226,000 to $300,000 in funding during its existence: 

$200,000 in 2018,65 7 $50,000 or less in 2019, and $26,000 to $50,000 in 2020 before terminating 

later that year.

66 8 Broken Promises’s 2018 federal tax return also indicates that it spent $500 on 

legal expenses and $40 on management and general expenses that year.67 9 Although Broken 

10 Promises characterized spending $45,000 on lobbying and $115,470 on “other” program 

11 expenses in its 2018 federal tax return, this sum of $160,470 corresponds precisely to the dollar 

with its 2018 Florida state political contributions also totaling $160,470.68 12 Thus, Broken 

13 Promises spent at least 67% to 89% of its total funding on making political contributions.

63 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data type=processed&q spender=C00728402&is notice=false&min date=01%2F01%2F2019&max

date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting Concerned Conservatives, Inc.’s, independent 

expenditures during the 2020 election cycle); August 18, 2020 Primary Election Republican Primary, FL DEP’T OF 

STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=8/18/2020&DATA

MODE= (last visited Sept. 25, 2023) (selecting “Federal Offices” in the Republican Primary section) (reflecting that 

Dane Eagle, William Figlesthaler, Byron Donalds, and Casey Askgar were seeking the Republican nomination in 

Florida’s 19th Congressional District).

64 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and contributor last name “Broken 

Promises”).

65 Broken Promises 2018 Tax Return at 1, supra note 60. 

66 For 2019 and 2020, Broken Promises filed an IRS Form 990-N, indicating that its gross receipts were 

$50,000 or less in those years. Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited 

Sept. 25, 2023) (searching organization name “Broken Promises”). 

67 Broken Promises 2018 Tax Return at 10, supra note 60. 

68 Id.; see also Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/

campaign-finance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and contributor last name 

“Broken Promises”) (reflecting that Broken Promises made $160,470 in Florida state political contributions in 2018, 

Attachment 4 

Page 16 of 33

MUR808200396
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 17 of 33

1 According to the Miami Herald, Broken Promises’s entire $200,000 of funding in 2018 

was from FPL.69 2 Specifically, the Miami Herald claims it received an internal Matrix ledger 

3 showing how, in 2018, Matrix distributed $200,000 of funds labeled as coming from FPL to 

Broken Promises.70 4 The ledger reportedly shows that Matrix sent $100,000 of FPL funds to 

Broken Promises on September 26, 2018, and again on October 16, 2018, totaling $200,000.71 5 

6 This money was likely transmitted through other Matrix-controlled corporations before coming 

7 to Broken Promises, because federal tax records show that the Alliance for Consumer Protection 

Inc., donated $100,000 to Broken Promises in 2018.72 8 According to a news report regarding a 

9 text message between Pitts and FPL Vice President Martell, the director of the Alliance for 

Consumer Protection Inc., David Calvert, is Pitts’s former college roommate.

73 10 

11 5. Stand Up for Justice 

As discussed above, Stand Up for Justice was incorporated on August 29, 2018,74 12 the 

same day as Broken Promises, and it shared a mailing address with CAIJ.

75 13 According to its 

of which $45,000 were cash contributions and $115,470 were in-kind contributions in the forms of direct mail and 

advertising).

69 Nicholas Nehamas & Mary Ellen Klas, DeSantis ’18 Campaign Got $25,000 From Nonprofit Secretly 

Funded by FPL Cash, Records Show, MIAMI HERALD (Sept. 9, 2022), https://www.miamiherald.com/news/politicsgovernment/state-politics/article265213541.html. 

70 Id. FPL spokesperson Reuter called the ledger “fake” and stated, “We have no record of FPL, or any 

NextEra Energy entity for that matter, ever having paid Broken Promises.” Id

71 Nightmare Scenario, supra note 10; see also Nicholas Nehamas & Mary Ellen Klas, DeSantis ’18 

Campaign Got $25,000 From Nonprofit Secretly Funded by FPL Cash, Records Show, MIAMI HERALD (Sept. 9, 

2022), https://www.miamiherald.com/news/politics-government/state-politics/article265213541.html. 

72 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095 201812 990O 20211020

19109756.pdf. 

73 Nightmare Scenario, supra note 10. 

74 CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023) 

(searching the organization names “Stand Up for Justice” and “Broken Promises”). 

75 Id. (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for Justice’s business 

address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006); American Valor PAC, 2020 

Attachment 4 

Page 17 of 33

MUR808200397
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 18 of 33

1 2018 federal tax return, Stand Up for Justice is a 501(c)(4) corporation; its purpose is to 

2 “develop[] and advocat[e] for legistlation [sic], regulations and government programs to improve 

3 social environment, economy & society”; Anderson was a director and its president; it did not 

have a website; and it received $350,000 in funding that year.76 4 

5 On March 31, 2020, Stand Up for Justice made a $50,000 contribution to South Florida 

Residents First,

77 6 an IEOPC that made independent expenditures during the 2020 election cycle 

7 only in Florida’s 26th Congressional District, which supported Republican nominee Carlos 

Gimenez and opposed Democratic nominee Debbie Mucarsel-Powell.78 8 In addition, just two 

9 months after it was incorporated, Stand Up for Justice made contributions to a Florida political 

committee in October 2018, totaling $300,000,79 10 which Stand Up for Justice characterized as 

“lobbying” on its 2018 federal tax return.80 11 Thus, it appears that Stand Up for Justice made at 

12 least $350,000 in political contributions during its existence. 

Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/202012039337569242/20201203

9337569242.pdf (reflecting that CAIJ’s address is at 2020 Pennsylvania Avenue, NW, Ste. 449, Washington DC 

20006). 

76 IRS Form 990, Stand Up for Justice, 2018 Return of Organization Exempt from Income Tax at 1-2, 7 

(Nov. 15, 2019), https://apps.irs.gov/pub/epostcard/cor/831749759_201812_990O_2020021317141891.pdf

[hereinafter Stand Up for Justice 2018 Tax Return]. 

77 South Florida Residents First, 2020 April Quarterly Report at 11 (April 13, 2020), https://docquery.fec

.gov/pdf/294/202004159216942294/202004159216942294.pdf; see also Compl. ¶ 53.

78 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00733402&is_notice=false&min_date=01%2F01%2F2019&max

_date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting South Florida Residents First’s independent 

expenditures in the 2020 election cycle); November 3, 2020 General Election, FL DEP’T OF STATE DIV. OF 

ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=11/3/2020&DATAMODE= (last visited 

Sept. 25, 2023) (selecting “Federal Offices”) (reflecting that Carlos Gimenez was the Republican nominee and

Debbie Mucarsel-Powell was the Democratic nominee in Florida’s 26th Congressional District); see Compl. ¶ 53. 

79 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited July 25, 2023) (searching election year “all” and contributor last name starting 

with “Stand Up for Justice”).

80 Stand Up for Justice 2018 Tax Return at 10, supra note 76. 

Attachment 4 

Page 18 of 33

MUR808200398
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 19 of 33

1 According to Stand Up for Justice’s federal tax returns, it received $350,000 to $450,000 

during its existence: $350,000 in 2018,81 2 and $50,000 or less per year in each of 2019 and 2020 

before terminating.82 3 Stand Up for Justice’s federal tax returns also state that it spent $20,577 on 

legal fees and $100 on bank service charges in 2018,83 4 indicating that its total funding was at 

5 least $370,677 to cover its lifetime spending. Thus, Stand Up for Justice spent at least 78% to 

6 94% of its total funding on making political contributions.

7 Federal tax records show that Alliance for Consumer Protection Inc., contributed 

$150,000 to Stand Up for Justice in 2018.84 8 As indicated above, the Alliance for Consumer 

9 Protection Inc. also contributed $100,000 to Broken Promises in 2018, and its executive director 

is reportedly Pitts’s former college roommate.

85 10 

11 C. Let’s Preserve the American Dream, Inc., was Associated with Pitts and 

12 Matrix

13 Relying on news reports of Matrix’s proposal to FPL, which reference LPAD as a higher14 level Matrix-associated conduit that would receive funds and transmit them to other entities in 

15 Matrix’s network, and news reports indicating that LPAD made donations to Grow United and 

16 Broken Promises, the Complaint alleges that Unknown Respondents used LPAD as a middleman 

to make contributions using the names of Grow United and Broken Promises.86 17 

81 Id. at 1.

82 For 2019 and 2020, Stand Up for Justice filed an IRS Form 990-N, and indicated that its gross receipts 

were not greater than $50,000 in those years. Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/

eos/ (last visited Sept. 25, 2023) (searching organization name “Stand Up for Justice”).

83 Stand Up for Justice 2018 Tax Return at 10, supra note 76. 

84 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095_201812_990O_20211020

19109756.pdf. 

85 Id.; Nightmare Scenario, supra note 10. 

86 Compl. ¶¶ 33 Fig. 1, 35, 37, 42 Fig. 2, 45, 52; see also Secretive Political Spending Plan, supra note 12. 

Attachment 4 

Page 19 of 33

MUR808200399
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 20 of 33

1 In a deposition conducted by the Miami-Dade State Attorney’s Office regarding a former 

2 LPAD contractor’s creation of fake Florida state senate candidates, Tyson stated that he 

3 discussed LPAD’s donation to Grow United with Matrix’s former CEO, Jeff Pitts, and that it was 

4 actually Pitts who proposed for LPAD to make that donation. Specifically, Tyson testified: 

5 Well, as best as I can recall, I called [Pitts] up and I said, “Do you 

6 have any social welfare groups that are interested in working on 

7 issues that are amenable to my organizational narrative? Are they 

8 interested in supporting other interests in other committees around 

9 the country, in Florida specifically too, that would focus purely on 

the center left spectrum and on issues that are center left?”87 10 

11 According to Tyson, Pitts “said he did,” referring to Grow United, and so Tyson “said we’d be 

12 happy to support them.” 

13 In the same above-referenced deposition, Tyson also testified that he spoke with Pitts 

14 about how Grow United should use LPAD’s donation. Specifically, in response to whether 

15 Tyson knew that Alex Alvarado’s Florida state political committees received their funding from 

16 Grow United, Tyson stated, “I told you earlier I knew it came from Grow United. There was a 

17 story about it. And I knew, I actually told Grow United that Alvarado would probably call them 

and ask, raise money.”88 18 Tyson further explained that the person he spoke with was Jeff Pitts. 

19 According to text messages obtained by the Orlando Sentinel, on September 24, 2020, just five 

20 days prior to LPAD making its first $600,000 donation to Grow United on September 29, 2020, 

21 Tyson communicated with Pitts and Abigail MacIver, another former Matrix employee, 

regarding the Florida state senate races that the Alvarado committees were seeking to impact.89 22 

87 Tyson testified in response to the question, “So give me your best recollection of the content of the 

conversation that you had with Jeff Pitts that caused you to want to send the money to Grow United.”

88 Emphasis was added to the original transcription.

89 FPL Execs, supra note 43. 

Attachment 4 

Page 20 of 33

MUR808200400
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 21 of 33

1 When further queried as to whether Tyson “did not authorize the money, the $600,000 

2 [from LPAD], to go to Grow United so they can then turn around and send it to Alex Alvarado’s 

3 two political campaigns,” Tyson testified that he “can’t tell [Grow United] how to spend their 

4 money” and that he “do[es]n’t have the ability to restrain how they spend their funds.” However, 

5 when asked, “Did you know when this $600,000 [from LPAD] was sent to Grow United, that it 

6 was going to [⸺] that 550,000 of it was going to go to Alex Alvarado’s two political 

7 committees,” Tyson testified that he “had a hunch” that Grow United would be supportive of the 

8 Alvarado committees and that he was “not testifying it’s a coincidence.” Tyson further stated, “I 

9 knew [Grow United] would likely be supportive, but I also didn’t know when, I mean, we made 

10 other contributions to them as well. We were supporting a lot of what they were doing.” Tyson 

11 then testified that he “assume[d] [Grow United would] probably be supported [sic] if Alex 

12 called, but I had no way to know if they actually would. Because once I make a contribution to 

13 an entity, I lose control of how they spend that money.” 

14 D. SUN Marketing & Advertising LLC Appears to be Associated with Matrix

15 SUN Marketing & Advertising LLC is another conduit identified in Matrix’s proposal to 

FPL,

90 16 and it appears to have been created by Matrix after the memo was circulated. 

17 Specifically, SUN was formed on December 13, 2019, about two weeks after Pitts reportedly 

emailed the above-referenced proposal to Silagy on November 26, 2019.91 18 FPL spokesman 

19 Reuter reportedly confirmed that FPL gave $250,000 to SUN in December 2019, but stated that 

20 the purpose was to purchase advertising related to a proposed constitutional amendment that FPL 

90 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 32 Fig. 1.

91 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “SUN Marketing & Advertising”). 

Attachment 4 

Page 21 of 33

MUR808200401
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 22 of 33

opposed.92 According to Reuter, FPL believes that SUN is owned by Matrix.93 1 News reports 

indicate that SUN was used to create favorable press for FPL.94 2 SUN’s former sole member, 

Tim Fitzpatrick, was a former FPL officer.95 3 

4 III. LEGAL ANALYSIS

5 A. The Commission Finds Reason to Believe that the $100,000 Contribution 

6 Reported as Having Been Made by Grow United, Inc., Was a Contribution 

7 Made In the Name of Another

8 The Act and the Commission’s regulations prohibit a person from (1) making a 

9 contribution in the name of another person, (2) knowingly permitting his or her name to be used 

to effect such a contribution, and (3) knowingly accepting such a contribution.96 10 The term 

11 “person” in this context includes partnerships, corporations, and “any other organization or group 

of persons.”97 12 In its regulations, the Commission has illustrated examples of activities that 

13 constitute making a contribution in the name of another, as follows: 

14 (i) Giving money or anything of value, all or part of which was 

15 provided to the contributor by another person (the true contributor) 

16 without disclosing the source of money or the thing of value to the 

17 recipient candidate or committee at the time the contribution is 

18 made; or

92 Secretive Political Spending Plan, supra note 12. 

93 Id.

94 Sarah Blaskey, Powerbrokers: How FPL Secretly Took Over a Florida News Site and Used It to Bash 

Critics, MIAMI HERALD (Aug. 13, 2022), https://www.miamiherald.com/article263757423.html. 

95 PG&E Names Tim Fitzpatrick As Vice President And Chief Communications Officer, CISION PR

NEWSWIRE (Mar. 11, 2013), https://www.prnewswire.com/news-releases/pge-names-tim-fitzpatrick-as-vicepresident-and-chief-communications-officer-197098061.html (“Fitzpatrick joined NextEra Energy in January 2008, 

serving as Vice President of Marketing and Corporate Communications and as an officer of Florida Power & Light 

Company (FPL).”).

96 52 U.S.C. § 30122; see also 11 C.F.R. § 110.4(b).

97 52 U.S.C. § 30101(11); 11 C.F.R. § 100.10.

Attachment 4 

Page 22 of 33

MUR808200402
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 23 of 33

1 (ii) Making a contribution of money or anything of value and 

2 attributing as the source of the money or thing of value another 

person when in fact the contributor is the source.98 3 

4 Because a primary purpose of the Act’s disclosure provisions is to reveal the true source from 

5 which a contribution to a candidate or committee originates, regardless of the mechanism by 

which the funds are transmitted,99 6 the Commission examines the structure of the transaction 

7 itself and the arrangement between the parties to determine who in fact “made” a given 

contribution.100 8 

9 In prior matters, the Commission has found reason to believe that a contribution was 

10 made in the name of another where the available information indicates that another person 

11 provided the funds for the purpose of making the contribution and his or her identity was not 

disclosed to the recipient committee or candidate at the time of the contribution.

101 12 Absent direct 

13 evidence as to the purpose of providing the funds, the Commission considers the overall record

14 to determine its purpose. In the context of contributions made by limited liability companies 

15 (“LLCs”), the Commission has addressed whether the LLC “had the means to make the 

16 contribution absent an infusion of funds provided for that purpose,” the “temporal proximity 

98 11 C.F.R. § 110.4(b)(2)(i)-(ii).

99 See Campaign Legal Ctr. v. FEC, 952 F.3d 352, 354 (D.C. Cir. 2020) (“As the Supreme Court has 

repeatedly declared, the electorate has an interest in knowing where political campaign money comes from and how 

it is spent by the candidate. To that end, the [Act] imposes disclosure requirements on those who give and spend 

money to influence elections. The straw donor provision, 52 U.S.C. § 30122, is designed to ensure accurate 

disclosure of contributor information.”) (internal citations and quotation marks omitted). 

100 Cf. 11 C.F.R. § 110.6(a) (“All contributions by a person made on behalf of or to a candidate, including 

contributions which are in any way earmarked or otherwise directed to the candidate through an intermediary or 

conduit, are contributions from the person to the candidate.”).

101 See, e.g., Factual and Legal Analysis (“F&LA”) at 5, MUR 7903 (Tomfoolery, LLC, et al.) (“[T]he 

contributions made in Tomfoolery’s name were, in fact, actually made by Thomas A. Chavez, when Chavez 

furnished Tomfoolery with funds for the purpose of having the LLC make the contributions.”); F&LA at 1-2, 

MUR 6920 (American Conservative Union) (finding reason to believe that the contribution was made in the name of 

another where the organization who was reported as the contributor later indicated that it was not the true source of 

the contribution, and instead merely delivered the contribution upon receipt of the funds from another person); see 

also 11 C.F.R. § 110.4(b)(2)(i)-(ii).

Attachment 4 

Page 23 of 33

MUR808200403
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 24 of 33

1 between the LLC’s formation date and the contribution,” “the amount of the contribution relative 

2 to [the LLC’s] other activities, the LLC’s known activities prior to making the contribution, and 

3 whether any other information suggests an attempt to circumvent the Act’s disclosure 

4 requirements.” 

5 Here, the available information indicates that the five 2020 political contributions 

6 purportedly made by the alleged Conduit Corporations — Florida Promise, Broken Promises, 

7 Grow United, CAIJ, and Stand Up for Justice — were actually made on behalf of Unknown 

8 Respondents. The overall record indicates that there was plan whose purpose was “to 

9 circumvent the Act’s disclosure requirements” by using the names of the Conduit Corporations 

10 to make contributions and that this plan was implemented in largely the way the blueprint set 

11 out. In addition, the overall record of the Conduit Corporations’ known activities indicate that 

12 they may have been formed for the purpose of making conduit contributions. 

13 Specifically, news articles indicate that, during the 2020 election cycle, Matrix invited 

14 FPL to anonymize its political activities by funneling money through several layers of conduits, 

15 including Florida Promise and Broken Promises, and then using those funds to make federal and 

state political contributions.

102 16 The articles report that Jeff Pitts, former CEO of Matrix, emailed

17 Eric Silagy, former CEO of FPL, a “‘funding memo’” with goals such as making “federal 

18 campaign contributions” and “‘minimiz[ing] all public reporting of entities and activities,’” and a 

“‘legal memo on federal elections support.’”103 19 According to the Orlando Sentinel, the funding 

20 memo included a flowchart depicting FPL’s funds flowing through several layers of conduits 

21 controlled by Pitts and Matrix, including Florida Promise and Broken Promises, before being 

102 Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 3, 31-38. 

103 Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 3, 31-32. 

Attachment 4 

Page 24 of 33

MUR808200404
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 25 of 33

contributed to federal and state political committees.104 1 While the specific plan reported by the 

2 news articles did not directly identify CAIJ, Grow United, or Stand Up for Justice, the proposal 

3 establishes the preexisting idea of making conduit contributions with entities just like these, 

4 which as discussed below, was ultimately carried out using the five alleged Conduit 

5 Corporations. 

6 News articles stated that the sources of the documents were from Matrix itself, noting 

that the documents were internal Matrix documents.105 7 FPL’s spokesperson, David Reuter, 

8 reportedly confirmed that the proposal as reported was indeed shared with its CEO, stating, “‘We 

9 are aware of the proposed structure as the legal memo was shared with us, and as we understand 

10 it, Joe Perkins’[s] team at Matrix created a proposal to fund their clients’ communication and 

outreach activities during 2020.’”106 11 Thus, there is no available information indicating that the 

12 news articles’ report that Pitts and Matrix created and shared a proposal to anonymize political 

13 contributions was inaccurate or not credible. 

14 Moreover, the available information does not indicate that the proposal was limited to 

15 acting solely within the legal bounds of minimizing public reporting of political activities. 

16 Specifically, the proposal did not indicate that Pitts and Matrix were soliciting funds from FPL 

17 on behalf of nonprofit corporations that would independently decide to make political 

18 contributions. Rather, the proposal indicated that funds would flow from FPL, through several 

19 layers of conduits controlled or associated with Matrix, before landing at “Florida Promise C4,” 

104 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

105 See Secretive Political Spending Plan, supra note 12 (stating that the Orlando Sentinel received records 

“includ[ing] checks, bank statements, emails, text messages, invoices, internal ledgers and more, all apparently 

unearthed during an internal investigation Matrix launched after its former employees left the firm at the end of 

2020.”).

106 Id.

Attachment 4 

Page 25 of 33

MUR808200405
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 26 of 33

1 “US Promise C4” and “Fed Promise C4,” which would also be controlled by Matrix, to make 

contributions to state and federal political committees.107 2 

3 Notably, there is no available information indicating that Pitts or Matrix presented the 

4 purposes or goals of the conduits referenced in its flowchart, besides being able to making 

5 political contributions, to explain why FPL’s funds would be expected to flow from one 

corporation to another.108 6 There is also no available information indicating that Pitts and Matrix 

7 presented any information as to why “Florida Promise C4,” “US Promise C4” and “Fed Promise 

8 C4,” would be expected to engage in political activity that FPL would support. Instead, Pitts’s 

9 and Matrix’s flowchart simply noted “Matrix” in a parenthetical below the names of “Broken 

10 Promises,” “Florida Promise C4,” “US Promise C4” and “Fed Promise C4,” similar to how 

11 Tyson, the executive director of LPAD, was included in a parenthetical under LPAD, suggesting 

that these entities are controlled by “Matrix,” similar to how Tyson controlled LPAD.109 12 

13 Moreover, the conduits depicted on the flowchart appear to have been in fact controlled 

14 by or associated with Matrix. Of the conduits mentioned, only Florida Promise, Broken 

15 Promises, LPAD, and SUN existed or eventually came into existence, and they all have ties to 

16 Pitts and/or Matrix. As explained above, Richard Alexander was the chairman of Florida 

Promise, and his sister, April Odom, was a Matrix contractor at the time of the allegations.110 17 

107 Id.; see also Compl. ¶¶ 33 Fig. 1, 36-37. 

108 See Secretive Political Spending Plan, supra note 12 (noting that, for example, “Florida Promise C4” would 

“allowed to spend 50% of revenues on political activities” and that “Florida PCs are allowed to take unlimited funds 

from C4s”); see also Compl. ¶ 33 Fig. 1 (same).

109 See Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1. While the term “person” 

appears in the parenthetical next to SUN, SUN had not yet been formed when Pitts sent the memo, and thus this

denotation appears to suggest that they were looking for a “person” to be in control of SUN at that time. See 

Secretive Political Spending Plan, supra note 12 (reporting that Pitts sent the memo to Silagy on November 26, 

2019).

110 Florida Promise 2018 Tax Return at 3, supra note 32; Dark Money Playbook, supra note 7 (reporting that 

April Odom is Anderson’s sister and was a former Matrix employee).

Attachment 4 

Page 26 of 33

MUR808200406
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 27 of 33

1 Sean J. Anderson, who was the president and chairman of Broken Promises, was also a former 

2 Matrix employee, a close friend of Pitts, and has a history of allowing Pitts to control the 

nonprofits that he purportedly ran.111 3 Tyson, the executive director of LPAD, reportedly 

4 associated with Pitts and Abigail MacIver, another former Matrix employee, as they 

communicated via text messages regarding Florida state senate races.112 5 Finally, as for SUN ⸺

6 FPL, which reportedly gave $250,000 to SUN in December 2019, states that it believes that SUN 

is owned by Matrix.113 7 Thus, the layers of corporations depicted on the flowchart appear to be 

8 linked together because they are controlled by persons associated with Pitts or Matrix.

9 The available information also indicates that Pitts’s and Matrix’s proposal included the 

10 making of federal political contributions. According to news articles, Pitts’s email to Silagy 

11 included a “‘funding memo’” noting making “federal campaign contributions” as one of its 

goals.114 12 Pitts’s email to Silagy also included “‘a separate legal memo on federal elections 

13 support’” explaining that “a nonprofit might have to disclose its donors if it spent money directly 

14 supporting a candidate” but that “the nonprofit would not have to disclose its donors if it gave 

money to a type of political action committee known as a ‘Super PAC,’”115 15 which is a colloquial 

reference to federal independent expenditure-only committees.116 16 Moreover, this legal memo 

111 Broken Promises, 2018 Tax Return at 1, 7, supra note 60; Bachelor Party, supra note 10 (reporting Pitts as 

having attended Anderson’s bachelor party); Nightmare Scenario, supra note 10 (reporting that Pitts texted FPL 

Vice President Martell that Anderson was an old friend of his and that he was “‘in control 100 percent’” of the 

nonprofits purportedly run by Mr. Anderson).

112 FPL Execs, supra note 43. 

113 Secretive Political Spending Plan, supra note 12. 

114 Id.; see also Compl. ¶ 32.

115 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 38.

116 See McCutcheon v. FEC, 572 U.S. 185, 193 (2014) (“A so-called ‘Super PAC’ is a PAC that makes only 

independent expenditures and cannot contribute to candidates. The base and aggregate limits govern contributions 

to traditional PACs, but not to independent expenditure PACs.”).

Attachment 4 

Page 27 of 33

MUR808200407
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 28 of 33

1 appears to provide the missing explanation as to the purpose of providing funds to the “Fed 

2 Promise C4” entity in the funding memo’s flowchart, indicating that this purpose would be to 

make federal political contributions.117 3 The name, “Fed Promise C4,” also suggests that this 

4 conduit would be used to make federal political contributions, as this would be consistent with 

5 and parallel to the flowchart’s statements that “Florida Promise C4” would be used to fund 

6 “Florida PCs” and that “US Promise C4” would be used to fund other state-level political 

activities.118 7 Thus, the available information indicates that the Pitts/Matrix proposal included 

8 making federal political contributions. 

9 The available information also indicates that the alleged Conduit Corporations received 

10 funds with the direction that they be used for federal contribution purposes as federal courts have 

11 stated that a donor’s intent can be inferred from the donee’s solicitations. Specifically, in the 

12 context of interpreting 52 U.S.C. § 30104(c)(1) of the Act, which courts have held to require notpolitical committees to disclose donations received for political purposes,119 13 a district court in 

14 Wisconsin observed that “whether a contribution is earmarked for political purposes and tied to 

15 an election can depend on whether the contribution is received in response to a solicitation and 

the way the solicitation is worded.”120 16 As explained above, Pitts’s and Matrix’s proposal clearly 

17 implicated the making of federal contributions, and the alleged Conduit Corporations appear to 

18 have received donations in response to that proposal.

19 In addition to conceiving of and sharing the plan, Pitts and Matrix were also in a position 

117 See Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1 (noting that it was 

“[w]aiting on lawyers” to explain the purpose of Fed Promise C4).

118 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

119 Citizens for Resp. & Ethics in Washington v. FEC, 316 F. Supp. 3d 349, 389 (D.D.C. 2018), aff’d, 971 F.3d 

340 (D.C. Cir. 2020).

120 Wisconsin Fam. Action v. FEC, No. 21-C-1373, 2022 WL 844436, at *11 (E.D. Wis. Mar. 22, 2022). 

Attachment 4 

Page 28 of 33

MUR808200408
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 29 of 33

1 to carry it out using the names of alleged Conduit Corporations to make the contributions. As 

2 discussed above, the persons nominally in charge of the alleged Conduit Corporations, 

3 Alexander and Anderson, had close relationships with Pitts and Matrix. Alexander, who served 

4 as a director or officer of Florida Promise, CAIJ, and Grow United, is apparently the brother of 

5 April Odom, who was a Matrix contractor at the time of the contributions and worked on matters 

relating to CAIJ and Grow United on behalf of Matrix.

121 6 Anderson, who was the chairman and 

7 president of Broken Promises and a director and president of Stand Up for Justice, was also 

former Matrix employee, and a close friend of Pitts.122 8 Pitts and Matrix also has a history of 

9 working with Anderson’s nonprofit corporations, as Pitts reportedly texted FPL Vice President 

10 Daniel Martell in 2016, four years prior to the contributions at issue here, “‘Bottom line is we are 

11 the ones with the check books and in control 100 percent’” of the nonprofits purportedly run by 

Anderson.123 12 

13 Pitts and Matrix also reportedly used the names of CAIJ and Grow United in other 

operations,124 and had access to CAIJ’s and Grow United’s bank accounts,125 14 further indicating 

15 that they had control over these corporations. Specifically, news reports indicate that, in October 

121 Dark Money Playbook, supra note 7 (reporting that April Odom is Anderson’s sister and was a former 

Matrix contractor); see also Compl. ¶¶ 13, 48.

122 Bachelor Party, supra note 10 (reporting Pitts as having attended Anderson’s bachelor party); Nightmare 

Scenario, supra note 10 (reporting that Pitts texted FPL Vice President Martell that Anderson was an old friend of 

his); see also Compl. ¶¶ 16, 52.

123 Nightmare Scenario, supra note 10; see also Compl. ¶¶ 16, 52. 

124 FPL Execs, supra note 43 (reporting that Matrix made a conduit contribution using CAIJ’s name on behalf 

of FPL); Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/ (reporting that Matrix offered a city councilman 

a job on behalf of FPL using Grow United’s name).

125 Dark Money Playbook, supra note 7 (reporting that internal Matrix records included a text message from

Odom stating that she procured access to the bank accounts of CAIJ and Grow United). 

Attachment 4 

Page 29 of 33

MUR808200409
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 30 of 33

2018, Pitts used CAIJ to make a contribution to House Majority PAC on behalf of Matrix.126 1 

2 News reports also indicate that in the summer of 2019, Matrix used Grow United to offer a job to 

a Jacksonville City Council member on behalf of FPL.127 3 In addition, according to the Orlando 

4 Sentinel, it received internal Matrix documents reflecting a September 23, 2020 text message 

from Odom stating that she procured access to CAIJ’s and Grow United’s bank accounts.128 5 

6 Finally, Tyson, the executive director of LPAD who donated $1,150,000 of LPAD funds to 

7 Grow United, testified that he understood that Pitts created and ran Grow United. Therefore, not 

8 only did Pitts and Matrix conceive of a plan for the making of conduit contributions, they also 

9 had sufficient control over the alleged Conduit Corporations to cause them to permit their names 

10 to be used to make contributions on behalf of Unknown Respondents. 

11 Although all five of the alleged Conduit Corporations were formed more than a year prior 

12 to making the contributions, the overall record of their known activities indicate that they were 

13 formed for the purpose of making conduit contributions. The only available information as to 

14 the five alleged Conduit Corporations’ activities was that they made federal and Florida state 

political contributions.129 15 Broken Promises and Stand Up for Justice spent at least 67% to 89% 

126 FPL Execs, see supra note 43 (reporting that Silagy, former CEO of FPL, emailed Pitts, former CEO of 

Matrix, to make a contribution to House Majority PAC to support Lauren Baer, and to make sure that “they don’t 

triangulate this donation to others we have done”); see also House Majority PAC, 2018 Amended 12-Day PreElection Report at 655 (Dec. 3, 2018), https://docquery.fec.gov/pdf/085/201812069135107085/20181206913510

7085.pdf (reflecting CAIJ’s contribution to House Majority PAC on October 16, 2018).

127 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/. FPL reportedly confirmed that Matrix 

employees came up with an idea to offer the City Council member a job, but that it rejected the idea. Id. 

128 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right-hand corner 

of the article’s sixth picture); see also Compl. ¶ 48.

129 Although Matrix reportedly used Grow United to offer a job to a Jacksonville council member, that never 

came to fruition as the council member rejected the offer. Nate Monroe, Amid JEA Privatization Controversy, a 

City Council Member Received a Mysterious Job Offer. A Dark-Money Group May Have Been Behind It, THE FL

Attachment 4 

Page 30 of 33

MUR808200410
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 31 of 33

1 and 78% to 94%, respectively, of their total funding on making federal and Florida state political 

2 contributions, indicating that they were created for the primary purpose of making political 

contributions.130 3 Moreover, consistent with the Pitts’s and Matrix’s proposal, federal tax records 

4 show that their funding was first transmitted through another Matrix-associated conduit, the 

5 Alliance for Consumer Protection Inc., which was reportedly controlled by Pitts’s former college 

roommate.131 6 While the available information does not indicate the total funding received by 

7 Florida Promise, CAIJ, or Grow United, the only known activities by these corporations are that 

they made an aggregate of $3,224,500 in federal and Florida state political contributions.

132 8 

9 In addition, only Florida Promise, Broken Promises, and Stand Up for Justice appeared to 

10 have filed federal tax returns, and these returns do not indicate that they engaged in any activity 

other than making political contributions, including through lobbying.133 11 The purpose 

12 statements in these tax returns indicate that Florida Promise, Broken Promises, and Stand Up for 

13 Justice were formed for political purposes, further suggesting they only engaged in political 

TIMES-UNION (Sept. 2, 2022), https://www.jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-salejacksonville-city-council-member-mysterious-job-offer-dark-money-group-nate-monroe/8850689002/. 

130 See supra pages 15-16, 18-19.

131 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095_201812_990O_20211020

19109756.pdf; Nightmare Scenario, supra note 10. 

132 See supra notes 33-34 and accompanying text (reflecting that Florida Promise made $1,230,000 in federal 

and Florida state contributions); supra notes 38, 40, 38 and accompanying text (reflecting that CAIJ made $432,000 

in federal and Florida state contributions); supra notes 46, 49 and accompanying text (reflecting that Grow United 

made $1,562,500 in federal and Florida state contributions).

133 See generally Florida Promise 2018 Tax Return, supra note 32; Broken Promises 2018 Tax Return, supra

note 60; Stand Up for Justice 2018 Tax Return, supra note 76. As indicated above, while Broken Promises and 

Stand Up for Justice indicated in their 2018 federal tax returns that they spent funding on “lobbying” and “other”

program expenses in 2018, the amounts they reportedly spent correspond to the same amounts that they spent on 

making Florida state political contributions. See supra pages 16, 18. 

Attachment 4 

Page 31 of 33

MUR808200411
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 32 of 33

activities.

134 1 

2 Furthermore, there are various organizational aspects of the alleged Conduit Corporations 

3 that suggest they were formed to serve as conduits. Specifically, despite the fact that CAIJ and 

4 Stand Up for Justice were incorporated in different states and do not share any officers, both 

entities reported having the same mailing address in Washington, D.C.135 5 In addition, despite 

6 both Broken Promises and Stand Up for Justice having the same three officers and nearly 

7 identical mission statements, both entities were incorporated on the same day in the same 

state.

136 8 Finally, Broken Promises’s federal tax return suggests that it was trying to conceal that 

9 it made political contributions. Specifically, Broken Promises characterized on its 2018 federal 

10 tax return that it spent $115,470 on “other” program service expenses, when that amount was 

actually used to make in-kind contributions to Florida state committees.137 11 Thus, the available 

12 information as to the activities, stated purpose, and creation of the Conduit Corporations suggests 

13 that they were created for making conduit contributions. 

134 Florida Promise 2018 Tax Return at 6, supra note 32 (stating that its purpose is to “develop and advocate 

for legislation, regulations, and government programs related to policies to benefit Floridians”); Broken Promises 

2018 Tax Return at 2, supra note 60 (stating that its purpose is to “develop[] and advocat[e] for legislation, 

regulations, and government programs to improve social environmental, economy and social environment”); Stand 

Up for Justice 2018 Tax Return at 2, supra note 76 (stating that its purpose is to “develop[] and advocat[e] for 

legistlation [sic], regulations, and government programs to improve social environment, economy & society”).

135 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting that CAIJ’s address was at 2020 Pennsylvania Avenue, 

NW, Ste. 449, Washington DC 20006); CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing

(last visited Sept. 25, 2023) (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for 

Justice’s business address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006). 

136 See CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023) 

(searching the organization names “Broken Promises” and “Stand Up For Justice”) (reflecting that both Broken 

Promises and Stand Up for Justice were incorporated on August 29, 2018); Broken Promises 2018 Tax Return at 1, 

7, supra note 60; Stand Up for Justice 2018 Tax Return at 1, 7, supra note 76. 

137 Compare Broken Promises 2018 Tax Return at 10, supra note 60 (stating that it spent $115,470 in “other” 

program service expenses), with Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.

myflorida.com/campaign-finance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and 

contributor last name “Broken Promises”) (reflecting that Broken Promises Broken Promises made $115,470 in inkind Florida state political contributions in 2018).

Attachment 4 

Page 32 of 33

MUR808200412
MUR 8082 (Grow United, Inc.) 

Factual and Legal Analysis

Page 33 of 33

1 In sum, the available information indicates that there was a plan to illegally disguise or 

2 withhold public reporting of political activities, and that this plan included making contributions 

3 through conduits and in a manner that closely matches what the available information shows had 

4 subsequently occurred. In addition, pursuant to this plan, the alleged Conduit Corporations 

5 permitted their names to be used to make federal political contributions on behalf of Unknown 

6 Respondents. Finally, the only known activities of the alleged Conduit Corporations were that 

7 they made federal and Florida state political contributions, indicating that their purpose was to 

8 serve as conduits. Thus, the Commission finds reason to believe that Grow United, Inc., violated 

9 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b) by knowingly permitting its name to be used to 

10 effect contributions in the name of another. 

Attachment 4 

Page 33 of 33

MUR808200413
1 FEDERAL ELECTION COMMISSION

2 FACTUAL AND LEGAL ANALYSIS

3 RESPONDENT: Broken Promises MUR 8082 

4 I. INTRODUCTION

5 The Complaint alleges that Unknown Respondents made contributions in the name of 

6 another through a network of conduits associated with a political consulting firm called Matrix 

LLC (“Matrix”), to five federal independent expenditure-only political committees (“IEOPCs”).

1 7 

8 The specific contributions identified in the Complaint are as follows: 

9 • a $1,000,000 contribution reportedly from Florida Promise, Inc. (“Florida Promise”)

to Senate Leadership Fund, dated December 8, 2020;2 10 

11 • a $100,000 contribution reportedly from the Center for Advancement of Integrity and

Justice, Inc. (“CAIJ”) to American Valor PAC, dated October 27, 2020;3 12 

13 • a $100,000 contribution reportedly from Grow United, Inc. (“Grow United”) to

Conservative Action Fund (f/k/a Wingman PAC), also dated October 27, 2020;4 14 

15 • a $20,000 contribution reportedly from Broken Promises to Concerned

Conservatives, Inc., dated July 14, 2020;5 16 and

17 • a $50,000 contribution reportedly from Stand Up for Justice to South Florida

Residents First, dated March 31, 2020.6 18 

1 Compl. ¶¶ 2, 5, 27, 42, 89-93 (Oct. 27, 2022).

2 Senate Leadership Fund, Amended 2020 Year End Report at 72 (Mar. 18, 2021), https://docquery.fec.gov/

pdf/807/202103189441299807/202103189441299807.pdf; see also Compl. ¶¶ 49-50.

3

 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/2020

12039337569242/202012039337569242.pdf; see also Compl. ¶¶ 47-48.

4

 Wingman PAC, 2020 30-Day Post Election Report at 1, 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting a $100,000 contribution from Grow United, Inc., on 

October 27, 2020, and the committee’s FEC identification number of C00742296); Conservative Action Fund, 

Amended Statement of Organization at 1 (May 20, 2022), https://docquery.fec.gov/pdf/048/202205209512421048/

202205209512421048.pdf (reflecting that its name has changed to Conservative Action Fund and that its FEC 

identification number is C00742296); see also Compl. ¶¶ 43-44.

5 Concerned Conservatives, Inc., 2020 12-Day Pre-Primary Election Report at 6 (Aug. 6, 2020), https://doc

query.fec.gov/pdf/823/202008069261263823/202008069261263823.pdf; see also Compl. ¶¶ 51-52.

6

 South Florida Residents First, 2020 April Quarterly Report at 11 (Apr. 13, 2020), https://docquery.fec.gov/

pdf/294/202004159216942294/202004159216942294.pdf; see also Compl. ¶¶ 53-54.

Attachment 5 

Page 1 of 33

MUR808200414
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 2 of 33

1 The Complaint relies on news articles regarding a 2019 email and two accompanying 

2 memoranda sent from Jeff Pitts, Matrix’s former CEO, to Eric Silagy, Florida Power & Light 

3 Company’s (FPL) former CEO, reportedly proposing a method for FPL to make anonymous 

4 contributions to federal and state political committees by transferring funds through multiple 

levels of conduits.7 5 The proposal called for funds to be first sent to and passed through higher6 level Matrix-associated conduits, including SUN Marketing & Advertising LLC (“SUN”) and 

7 Let’s Preserve the American Dream, Inc. (“LPAD”), before being sent to various lower-level 

8 Matrix-controlled conduits, including Florida Promise, that would be reported as the source of 

9 the contributions. Thus, the Complaint alleges that each of the five alleged lower-level Matrix10 controlled conduits (referred to herein as the “Conduit Corporations”) permitted their names to 

11 be used to effect contributions in the name of another pursuant to Pitts’s and Matrix’s proposal. 

12 To support its central allegation, the Complaint alleges that all five of the alleged Conduit 

13 Corporations had ties to Pitts or Matrix through having either Richard Alexander or Sean J. 

Anderson as a director or officer.

8 14 Citing news articles, the Complaint alleges that Alexander’s 

sister was a Matrix contractor at the time of the allegations9 15 and that Anderson was a former 

Matrix employee and a good friend of Pitts.10 16 

7

 Compl. ¶¶ 3-4, 28-41; see, e.g., Jason Garcia & Annie Martin, Florida’s Dark Money Playbook: How 

‘Ghost’ Candidate Scheme Revealed Secretive Political Tactics, ORLANDO SENTINEL (Dec. 30, 2021), 

https://www.orlandosentinel.com/news/os-ne-dark-money-ghost-candidates-tactics-20211230-7zelkoadffclde3z

76ax3cgx3m-htmlstory.html [hereinafter Dark Money Playbook].

8

 Compl. ¶¶ 13, 16. 

9

 Id. ¶ 13; see Dark Money Playbook, supra note 7 (reporting that Alexander’s sister, April Odom, was a 

Matrix employee at the time of the allegations, and that she worked on matters relating to Grow United and CAIJ).

10 Compl ¶ 16; see John Archibald, Archibald: ‘Bachelor party’ Makes For Strange Bedfellows, AL.COM

(Nov. 14, 2010), https://www.al.com/archiblog/2010/11/archibald bachelor party makes.html [hereinafter 

“Bachelor Party”] (reporting that Pitts attended Anderson’s bachelor party and that they were both employed by 

Matrix at the time); Mary Ellen Klas, et al., ‘Nightmare Scenario’: How FPL Secretly Manipulated a Florida State 

Senate Election, MIAMI HERALD (Aug. 29, 2022), https://www.miamiherald.com/news/politics-government/statepolitics/article264196761.html [hereinafter “Nightmare Scenario”] (reporting that Pitts texted FPL vice president 

Attachment 5 

Page 2 of 33

MUR808200415
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 3 of 33

1 As discussed below, the five contributions purportedly made by the alleged Conduit 

2 Corporations as identified by the Complaint appear to be consistent with the conduit 

3 contributions proposed by Pitts and Matrix to FPL to anonymize its political contributions. In 

4 addition, all five of the alleged Conduit Corporations appear to be controlled by or associated 

5 with Pitts and Matrix. Accordingly, the Commission finds reason to believe that Broken 

6 Promises violated 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b) by knowingly permitting its name 

7 to be used to effect contributions in the name of another. 

8 II. FACTUAL BACKGROUND

9 A. Jeff Pitts of Matrix Appears to Have Created a Plan to Anonymize Federal 

10 Political Contributions Using a Network of Conduits Controlled by or 

11 Associated with Pitts or Matrix 

Matrix is a “strategic communications firm” based in Alabama.11 12 According to the 

13 Orlando Sentinel, it received a cache of internal documents from Matrix, “includ[ing] checks, 

14 bank statements, emails, text messages, invoices, internal ledgers and more, all apparently 

15 unearthed during an internal investigation Matrix launched after its former employees left the 

firm at the end of 2020.”12 16 These internal records included a copy of a November 26, 2019 

17 email sent from former Matrix CEO, Jeff Pitts, to former FPL CEO, Eric Silagy, stating, 

18 “‘Attached is an updated funding memo along with a separate legal memo on federal elections 

support.’”13 19 The “funding memo” noted goals such as making “federal campaign contributions” 

Daniel Martell that Anderson was an old friend of his and that Pitts was in control of the nonprofits run by 

Anderson).

11 Matrix, LLC, v. Canopy Partners, LLC, et al, 2021 WL 3127729 (Ala. Cir. Ct.).

12 Jason Garcia & Annie Martin, Operative Pitched Secretive Political Spending Plan to FPL Exec’s Email 

Alias, Records Reveal, ORLANDO SENTINEL (Jan. 24, 2022), https://www.orlandosentinel.com/politics/os-ne-floridapower-and-light-matrix-dark-money-20211217-v64274eytjeb5hnstdognvqds4-story.html [hereinafter “Secretive 

Political Spending Plan”]. 

13 Id.; see also Compl. ¶¶ 3, 31-38.

Attachment 5 

Page 3 of 33

MUR808200416
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 4 of 33

and “‘minimiz[ing] all public reporting of entities and activities.’”14 1 It also included a flowchart

2 depicting money flowing from FPL through a network of conduits before being contributed to 

federal and state political committees, as reproduced below:15 3 

14 See Secretive Political Spending Plan, supra note 12; Compl. ¶ 32.

15 See Secretive Political Spending Plan, supra note 12; Compl. ¶ 33 Fig. 1.

Attachment 5 

Page 4 of 33

MUR808200417
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 5 of 33

1 Notably, next to or below the name of each conduit is a parenthetical, which may indicate the 

2 person or entity controlling or associating with that conduit. Specifically, the flowchart 

3 identifies a “LPAD C4 (Tyson),” which appears to refer to LPAD and its executive director Ryan 

Tyson.16 4 The flowchart also identifies “Matrix/Foley” in a parenthetical next to or below the 

16 See Compl. ¶ 35.

Attachment 5 

Page 5 of 33

MUR808200418
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 6 of 33

1 names of the following conduits: “Broken Promises,” “Florida Promise C4,” “US Promise C4,” 

2 and “Fed Promise C4,” suggesting that these conduits are directly associated with and/or 

controlled by Matrix and its legal counsel, Foley and Lardner, LLP (“Foley”).17 3 

4 According to the flowchart, money could flow to a “Florida Promise C4,” which could 

5 “spend 50% of revenues on political activities” due to its tax status as a section 501(c)(4) 

6 corporation, and be used to contribute to Florida state political committees on the basis that 

“Florida PCs are allowed to take unlimited funds from C4s.”18 7 Money could also flow to a “US 

8 Promise C4,” which similarly could “spend 50% of revenues on political activities” due to its tax 

9 status, and be used to contribute to other states’ political committees on the basis that “[e]ach 

state operates under unique state elections.”19 10 Lastly, the flowchart indicates that money could 

11 flow to a “Fed Promise C4,” but because Matrix was “[w]aiting on lawyers,” it could not state

the purpose of this proposed funding.20 12 

13 The legal memo attached to the email, which was drafted by Foley attorney Erika Alba, 

addressed “the legalities of using nonprofits to spend money on federal elections.”21 14 The memo 

15 states that “a nonprofit might have to disclose its donors if it spent money directly supporting a 

16 candidate,” but that “the nonprofit would not have to disclose its donors if it gave money to a 

17 type of political committee known as a “‘Super PAC’” (i.e., an IEOPC) “that then spent money 

supporting the candidate.”22 18 The legal memo then concluded: “‘Thus, it could be strategic for a 

17 See Secretive Political Spending Plan, supra note 12 (noting that Erika Alba of Foley & Lardner LLP 

drafted a legal memo attached to the email); see also Compl. ¶ 38 (alleging the same). 

18 Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 33 Fig. 1, 37.

19 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

20 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

21 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 38.

22 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 38.

Attachment 5 

Page 6 of 33

MUR808200419
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 7 of 33

[nonprofit] who wishes to make Independent Expenditures to do so via a Super PAC.’”23 1 

2 Based on the record of contributions disclosed by the recipient IEOPCs and news articles 

3 reporting that LPAD provided funding to Grow United and Broken Promises, the Complaint 

depicts the implementation of the Matrix plan as taking the following altered form:24 4 

5 

6 The Complaint alleges that Matrix pitched the above-referenced plan to Unknown 

7 Respondent clients, noting that FPL’s spokesperson, David Reuter, stated, “‘We are aware of the 

8 proposed structure as the legal memo was shared with us, and as we understand it, Joe 

23 Secretive Political Spending Plan, supra note 12 (alteration in original); see also Compl. ¶ 38.

24 Compl. ¶¶ 42 Fig. 2, 45, 52.

Attachment 5 

Page 7 of 33

MUR808200420
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 8 of 33

1 Perkins’[s] team at Matrix created a proposal to fund their clients’ communication and outreach 

activities during 2020.’”25 2 

3 B. The Alleged Conduit Corporations Appear to Have Been Controlled by or 

4 Associated with Pitts and/or Matrix 

5 The Complaint alleges that five alleged Conduit Corporations, Florida Promise, CAIJ, 

6 Grow United, Broken Promises, and Stand Up for Justice, permitted their names to effect the 

7 $1.27 million in contributions that they purportedly made to IEOPCs on behalf of Unknown 

Respondents.26 8 Richard Alexander served as a director or officer of the first three alleged 

9 Conduit Corporations, while Sean J. Anderson was a director or officer of the latter two. 

10 According to news reports, both Alexander and Anderson had close ties to Matrix. 

11 Alexander’s sister, April Odom, was a Matrix contractor at the time of the allegations and 

12 reportedly worked on behalf of Matrix regarding CAIJ and Grow United, which were entities 

associated with Alexander.

27 13 Anderson, on the other hand, was a former Matrix employee, and 

reportedly a close friend of Pitts. 28 14 Anderson also has a history of working with Pitts, as Pitts 

15 reportedly texted FPL Vice President Daniel Martell in 2016, four years prior to the alleged 

16 contributions, as follows: “‘Bottom line is we are the ones with the check books and in control 

100 percent’” of the nonprofits purportedly run by Anderson.29 17 The discussion below sets out 

18 the available information about each of the alleged Conduit Corporations and their relationships 

19 with Pitts and/or Matrix.

25 Secretive Political Spending Plan, supra note 12 (emphasis added); Compl. ¶ 40 (emphasis added). 

26 Compl. ¶¶ 5, 43-54.

27 Dark Money Playbook, supra note 7 (reporting that April Odom is Anderson’s sister and was a former 

Matrix employee); see also Compl. ¶¶ 13, 48.

28 Bachelor Party, supra note 10; Nightmare Scenario, supra note 10 (reporting that Pitts texted FPL Vice 

President Martell that Anderson was an old friend of his); see also Compl. ¶ 16.

29 Nightmare Scenario, supra note 10; see also Compl. ¶ 16. 

Attachment 5 

Page 8 of 33

MUR808200421
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 9 of 33

1 1. Florida Promise, Inc. 

2 Florida Promise is a corporation identified in Matrix’s proposal to FPL that could be used 

as a conduit to make contributions to Florida political committees,

30 3 and it was incorporated on 

December 18, 2018.31 4 According to Florida Promise’s 2018 federal tax return, it is a 501(c)(4) 

5 corporation; its mission is to “develop and advocate for legislation, regulations, and government 

6 programs related to policies to benefit Floridians”; Alexander was its chairman; it did not have a 

website; and it did not have any expenses or revenue that year.32 7 

8 On December 8, 2020, Florida Promise made a $1,000,000 contribution to the Senate 

Leadership Fund.33 9 In addition, consistent with Matrix’s proposal to use Florida Promise to

10 make Florida political contributions, Florida Promise also made contributions to Florida political 

committees on June 12, 2019, and January 27, 2021, totaling $230,000.34 11 Other than making the 

12 $1,230,000 in federal and Florida state political contributions, there is no publicly available 

13 information regarding Florida Promise’s activities. 

30 See Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 33 Fig. 1, 50. 

31 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Florida Promise”); see also Compl. ¶ 12.

32 IRS Form 990-EZ, Florida Promise, Inc., 2018 Short Form Return of Organization Exempt from Income 

Tax at 2-3, 6 (Nov. 13, 2019), https://apps.irs.gov/pub/epostcard/cor/832961305_201812_990EO_202006011716

8825.pdf [hereinafter Florida Promise 2018 Tax Return]. 

33 Senate Leadership Fund, Amended 2020 Year End Report at 72 (Mar. 18, 2021), https://docquery.fec.gov/

pdf/807/202103189441299807/202103189441299807.pdf; see also Compl. ¶ 49. 

34 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (searching “all” election years with contributor’s last name 

starting with “Florida Promise”); see also Compl. ¶ 50.

Attachment 5 

Page 9 of 33

MUR808200422
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 10 of 33

1 2. Center for Advancement of Integrity and Justice, Inc.

CAIJ was incorporated on October 1, 2018,35 2 and shared a mailing address with Stand Up 

for Justice.36 There are no publicly available CAIJ federal tax returns.37 3 Alexander served as 

4 either a director or officer of CAIJ.

On October 27, 2020, CAIJ made a $100,000 contribution to American Valor PAC,38 5 an 

6 IEOPC that made independent expenditures during the 2020 election cycle solely in Florida’s

7 13th Congressional District, which supported Anna Paulina Luna, the Republican nominee, and 

opposed Charlie Joseph Crist, the Democratic nominee.39 8 CAIJ also made contributions to 

9 Florida political committees totaling $307,000, starting in November 2018 and through 

December 2020.

40 10 

35 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Center for Advancement of Integrity and 

Justice”); see also Compl. ¶ 11.

36 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting that CAIJ’s address was at 2020 Pennsylvania Avenue, 

NW, Ste. 449, Washington DC 20006); CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing

(last visited Sept. 25, 2023) (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for 

Justice’s business address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006). 

37 On May 15, 2021, the IRS automatically revoked CAIJ’s 501(c)(4) status for not filing a Form 990s-series 

return for three consecutive years, suggesting that CAIJ has not filed any tax returns. See Tax Exempt Organization 

Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited July 25, 2023) (searching the organization name “center 

for advancement of integrity” which reflect that CAIJ’s federal tax exempt status was automatically revoked on May 

15, 2021for not filing a Form 990-series return or notice for three consecutive years).

38 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf; see also Compl. ¶ 47. 

39 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00757179&is_notice=false&most_recent=true (last visited 

Aug. 18, 2023) (reflecting independent expenditures made by American Valor PAC); November 3, 2020 General 

Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=

11/3/2020&DATAMODE= (last visited Sept. 25, 2023) (selecting “Federal Offices”) (reflecting that Anna Luna 

was the Republican nominee and that Charlie Crist was the Democratic nominee in Florida’s 13th Congressional 

District).

40 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited July 25, 2023) (searching “all” election years with contributor’s last name starting 

with “center for advancement”).

Attachment 5 

Page 10 of 33

MUR808200423
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 11 of 33

1 While CAIJ was not referenced by name in Matrix’s proposal to FPL, news reports 

2 suggest that it was controlled by Matrix. Specifically, Matrix’s internal files reportedly include a 

3 September 23, 2020 text message from Odom, Alexander’s sister and a Matrix contractor at the 

time of the allegations, stating that she procured access to CAIJ’s bank account.41 4 In addition, 

5 on October 16, 2018, just 15 days after CAIJ’s incorporation, CAIJ made a $25,000 contribution 

to House Majority PAC.42 6 According to news reports, FPL directed Matrix to make this 

7 contribution on its behalf to support Lauren Baer, who was seeking election in Florida’s 18th 

8 Congressional District, and asked Matrix to ensure that House Majority PAC “‘do[es]n’t 

triangulate this donation to others we have done.’”43 9 Other than making the $432,000 in federal 

10 and Florida state political contributions, there is no publicly available information regarding 

11 CAIJ’s activities. 

41 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right-hand corner 

of the article’s sixth picture); see also Compl. ¶ 48.

42 House Majority PAC, 2018 Amended 12-Day Pre-Election Report at 655 (Dec. 3, 2018), https://docquery

.fec.gov/pdf/085/201812069135107085/201812069135107085.pdf. 

43 Jason Garcia & Annie Martin, Florida Power & Light Execs Worked Closely with Consultants Behind 

‘Ghost’ Candidate Scheme, Records Reveal, ORLANDO SENTINEL (Apr. 14, 2022), https://www.orlandosentinel.com/

politics/os-ne-florida-power-and-light-senate-ghost-candidates-20211202-szjhv7ox6vcmphm6pgd437y52i-htmlstory

.html [hereinafter “FPL Execs”] (reporting that Silagy forwarded Pitts instructions to make a contribution to House 

Majority PAC to support Lauren Baer and to make sure that “they don’t triangulate this donation to others we have 

done”); November 6, 2018 General Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.my

florida.com/Index.asp?ElectionDate=11/6/2018&DATAMODE= (last visited Sept. 25, 2023) (reflecting that Lauren 

Baer was the democratic nominee in Florida’s 18th Congressional District). 

Attachment 5 

Page 11 of 33

MUR808200424
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 12 of 33

1 3. Grow United, Inc. 

Grow United was incorporated on July 24, 2019.44 2 There are no publicly available Grow 

3 United federal tax records and it did not identify itself as a nonprofit organization to the Internal 

Revenue Service.

45 4 Alexander served either as a director or officer of Grow United. 

On October 27, 2020, Grow United made a $100,000 contribution to Wingman PAC,46 5 

now known as the Conservative Action Fund.47 6 Wingman PAC made independent expenditures 

7 during the 2020 election cycle solely in Florida’s 15th Congressional District, which supported 

8 Scott Franklin, the Republican nominee; opposed Alan Michael Cohn, the Democratic nominee; 

9 and opposed Vincent Spano Ross, who competed against Franklin for the Republican 

44 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Grow United”). 

45 See Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited Sept. 25, 2023)

(reflecting that there are no results when searching Grow United’s name or its EIN number identified in the 

Complaint, 84-2546999). 

46 Wingman PAC, 2020 30-Day Post Election Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/423/

202012039338666423/202012039338666423.pdf (reflecting a $100,000 contribution from Grow United on October 

27, 2020).

47 Id. at 1(reflecting an FEC identification number of C00742296); Conservative Action Fund, Amended 

Statement of Organization at 1 (May 20, 2022), https://docquery.fec.gov/pdf/048/202205209512421048/2022

05209512421048.pdf (reflecting that its name has changed to Conservative Action Fund and its FEC identification 

number is C00742296). 

Attachment 5 

Page 12 of 33

MUR808200425
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 13 of 33

nomination.48 1 Earlier that month, from October 3, 2020, through October 20, 2020, Grow 

United made contributions to Florida state political committees totaling $1,462,500.49 2 

3 Grow United appears to have been created and controlled by Pitts and Matrix. Ryan 

4 Tyson, the executive director of LPAD — which contributed $1,150,000 to Grow United in 

202050 5 — was deposed by the Miami-Dade State Attorney’s Office in a criminal matter 

6 regarding a former LPAD contractor’s creation of fake Florida state senate candidates during the 

7 2020 election cycle. Tyson testified in the deposition that he understood that Jeff Pitts started 

8 and ran Grow United. In addition, FPL reportedly asserted that Grow United was created by 

Matrix.51 9 

10 Matrix’s internal records also reportedly indicate that it had control of Grow United. 

11 According to news reports, Matrix’s internal ledger reflect an August 7, 2019 entry billed to FPL 

12 for “‘Grow United SOS Fees,’” which likely referred to the fees charged by the Delaware 

48 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00742296&is_notice=false&min_date=01%2F01%2F2019&max

_date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting Wingman PAC’s independent expenditures in the 

2020 election cycle); November 3, 2020 General Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results

.elections.myflorida.com/Index.asp?ElectionDate=11/3/2020&DATAMODE= (last visited Sept. 25, 2023) 

(selecting “Federal Offices”) (reflecting that Scott Franklin was the Republican nominee and Alan Cohn was the 

Democratic nominee in Florida’s 15th Congressional District); August 18, 2020 Primary Election Republican 

Primary, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate

=8/18/2020&DATAMODE= (last visited Sept. 25, 2023) (selecting “Federal Offices” in the Republican Primary 

section) (reflecting that both Scott Franklin and Ross Spano were seeking the Republican nomination in Florida’s 

15th Congressional District).

49 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (selecting election year “all” and searching contributor last name 

starting with “grow united”); see also Compl. ¶ 46.

50 See Compl. ¶ 45.

51 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Dec. 10, 2021, updated Sept. 2, 

2022), https://www.jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-citycouncil-member-mysterious-job-offer-dark-money-group-nate-monroe/8850689002/. Joe Perkins, owner of Matrix, 

denies that Matrix created Grow United, and Perkins’s attorney asserts that “[t]o the extent any rogue Matrix 

employees were involved in those activities, they were undertaken in secret, without Dr. Perkins’[s] knowledge or 

consent.” Id.

Attachment 5 

Page 13 of 33

MUR808200426
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 14 of 33

Secretary of State for incorporating Grow United a few weeks prior.

52 1 Matrix’s internal records 

2 also reportedly include a September 23, 2020 message from Odom stating that she procured 

access to Grow United’s bank account.53 3 In addition, as part of her duties at Matrix, Odom 

4 reportedly sent checks from Grow United to make contributions to Florida committees, asked the 

committees to confirm their receipt of the checks,54 5 and emailed a $12,813.54 invoice to Matrix

6 with the subject line, “FPL Expenses for Grow United c4,” for expenses that included traveling 

to Colorado to update the nonprofit’s mailbox at a UPS Store in Denver.55 7 

8 News articles also report that, in the summer of 2019, Matrix used Grow United to offer a 

job to a Jacksonville City Councilmember on behalf of FPL.56 9 Furthermore, Foley attorney 

10 Erika Alba reportedly billed Matrix in the fall of 2020 for her work on IRS submission forms for 

Grow United.57 11 Other than making the $1,562,500 in political contributions, there is no publicly 

12 available information regarding Grow United’s activities.

52 FPL Execs, supra note 43. 

53 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right corner of the 

article’s sixth picture); see also Compl. ¶ 48.

54 Dark Money Playbook, supra note 7. 

55 FPL Execs, supra note 43. 

56 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/. FPL reportedly confirmed that Matrix 

employees came up with an idea to offer the City Council member a job, but that it rejected the idea. Id. 

57 Nate Monroe, Law Firm that Advised on Botched JEA Sale Also Helped Former FPL Consultants On 

Dark-Money Projects, FL TIMES-UNION (Dec. 17, 2021), https://www.jacksonville.com/story/news/columns/natemonroe/2021/12/17/jea-privatization-law-firm-foley-lardner-also-helped-former-fpl-consultants-political-giving/

8850686002/. There are no publicly available tax forms from Grow United, Inc., however. See Tax Exempt 

Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited Sept. 25, 2023) (reflecting that there are no 

results when searching Grow United’s name or its EIN number identified in the Complaint, 84-2546999).

Attachment 5 

Page 14 of 33

MUR808200427
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 15 of 33

1 4. Broken Promises 

2 Broken Promises is referenced by name in Matrix’s proposal to FPL as a middleman that 

3 would receive funds and send them to conduits, including Florida Promise, that would in turn 

make political contributions.58 4 Broken Promises was incorporated on August 29, 2018, along 

with Stand Up for Justice.59 5 According to Broken Promises’s federal tax return for the 2018 

6 calendar year, it is a 501(c)(4) corporation; its purpose is to “develop[] and advocat[e] for 

7 legislation, regulations, and government programs to improve social environmental, economy 

8 and social environment”; Sean J. Anderson is its president and chairman; it did not have a 

website; and it received $200,000 of funding that year.60 9 In addition, according to news reports, 

Broken Promises reportedly received $26,000 from LPAD on July 9, 2020.61 10 

11 On July 14, 2020, five days after reportedly receiving the $26,000 from LPAD, Broken 

Promises made a $20,000 contribution to Concerned Conservatives, Inc., an IEOPC.62 12 During 

13 the 2020 election cycle, Concerned Conservatives, Inc., made independent expenditures only in 

14 Florida’s 19th Congressional District to support Dane Eagle, who unsuccessfully ran for the 

15 Republican nomination, and oppose his competitors, William Matthew Figlesthaler, Byron 

58 See Secretive Political Spending Plan, supra note 12; Compl. ¶¶ 33 Fig. 1, 52. 

59 CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023)

(searching the organization name “Broken Promises” and “Stand Up for Justice”).

60 See IRS Form 990, Broken Promises, 2018 Return of Organization Exempt from Income Tax at 1, 7 

(Nov. 15, 2019), https://apps.irs.gov/pub/epostcard/cor/831745117_201812_990O_2020012317057600.pdf

[hereinafter Broken Promises 2018 Tax Return] (reflecting an unfilled line for the organization’s website).

61 Jeff Weiner & Annie Martin, Bank Records Shed Light on Dark-Money Group in ‘Ghost’ Candidate 

Scandal, ORLANDO SENTINEL (Apr. 18, 2022), https://www.orlandosentinel.com/2022/04/18/bank-records-shedlight-on-dark-money-group-in-ghost-candidate-scandal/; see Compl. ¶ 52.

62 Concerned Conservatives, Inc., 2020 12-Day Pre-Primary Election Report at 6 (Aug. 6, 2020), 

https://docquery.fec.gov/pdf/823/202008069261263823/202008069261263823.pdf; see also Compl. ¶ 51.

Attachment 5 

Page 15 of 33

MUR808200428
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 16 of 33

Donalds, and Casey Askar.63 1 In addition, in 2018, Broken Promises made $160,470 in Florida 

2 state political contributions, and in 2019, it made $21,500 in Florida state political 

contributions.64 3 Thus, it appears that Broken Promises made at least $201,970 in political 

4 contributions during its existence. 

5 According to Broken Promises’s federal tax returns and other information received by the 

6 Commission, it received a total of $226,000 to $300,000 in funding during its existence: 

$200,000 in 2018,65 7 $50,000 or less in 2019, and $26,000 to $50,000 in 2020 before terminating 

later that year.

66 8 Broken Promises’s 2018 federal tax return also indicates that it spent $500 on 

legal expenses and $40 on management and general expenses that year.67 9 Although Broken 

10 Promises characterized spending $45,000 on lobbying and $115,470 on “other” program 

11 expenses in its 2018 federal tax return, this sum of $160,470 corresponds precisely to the dollar 

with its 2018 Florida state political contributions also totaling $160,470.68 12 Thus, Broken 

13 Promises spent at least 67% to 89% of its total funding on making political contributions.

63 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data type=processed&q spender=C00728402&is notice=false&min date=01%2F01%2F2019&max

date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting Concerned Conservatives, Inc.’s, independent 

expenditures during the 2020 election cycle); August 18, 2020 Primary Election Republican Primary, FL DEP’T OF 

STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=8/18/2020&DATA

MODE= (last visited Sept. 25, 2023) (selecting “Federal Offices” in the Republican Primary section) (reflecting that 

Dane Eagle, William Figlesthaler, Byron Donalds, and Casey Askgar were seeking the Republican nomination in 

Florida’s 19th Congressional District).

64 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and contributor last name “Broken 

Promises”).

65 Broken Promises 2018 Tax Return at 1, supra note 60. 

66 For 2019 and 2020, Broken Promises filed an IRS Form 990-N, indicating that its gross receipts were 

$50,000 or less in those years. Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited 

Sept. 25, 2023) (searching organization name “Broken Promises”). 

67 Broken Promises 2018 Tax Return at 10, supra note 60. 

68 Id.; see also Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/

campaign-finance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and contributor last name 

“Broken Promises”) (reflecting that Broken Promises made $160,470 in Florida state political contributions in 2018, 

Attachment 5 

Page 16 of 33

MUR808200429
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 17 of 33

1 According to the Miami Herald, Broken Promises’s entire $200,000 of funding in 2018 

was from FPL.69 2 Specifically, the Miami Herald claims it received an internal Matrix ledger 

3 showing how, in 2018, Matrix distributed $200,000 of funds labeled as coming from FPL to 

Broken Promises.70 4 The ledger reportedly shows that Matrix sent $100,000 of FPL funds to 

Broken Promises on September 26, 2018, and again on October 16, 2018, totaling $200,000.71 5 

6 This money was likely transmitted through other Matrix-controlled corporations before coming 

7 to Broken Promises, because federal tax records show that the Alliance for Consumer Protection 

Inc., donated $100,000 to Broken Promises in 2018.72 8 According to a news report regarding a 

9 text message between Pitts and FPL Vice President Martell, the director of the Alliance for 

Consumer Protection Inc., David Calvert, is Pitts’s former college roommate.

73 10 

11 5. Stand Up for Justice 

As discussed above, Stand Up for Justice was incorporated on August 29, 2018,74 12 the 

same day as Broken Promises, and it shared a mailing address with CAIJ.

75 13 According to its 

of which $45,000 were cash contributions and $115,470 were in-kind contributions in the forms of direct mail and 

advertising).

69 Nicholas Nehamas & Mary Ellen Klas, DeSantis ’18 Campaign Got $25,000 From Nonprofit Secretly 

Funded by FPL Cash, Records Show, MIAMI HERALD (Sept. 9, 2022), https://www.miamiherald.com/news/politicsgovernment/state-politics/article265213541.html. 

70 Id. FPL spokesperson Reuter called the ledger “fake” and stated, “We have no record of FPL, or any 

NextEra Energy entity for that matter, ever having paid Broken Promises.” Id

71 Nightmare Scenario, supra note 10; see also Nicholas Nehamas & Mary Ellen Klas, DeSantis ’18 

Campaign Got $25,000 From Nonprofit Secretly Funded by FPL Cash, Records Show, MIAMI HERALD (Sept. 9, 

2022), https://www.miamiherald.com/news/politics-government/state-politics/article265213541.html. 

72 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095 201812 990O 20211020

19109756.pdf. 

73 Nightmare Scenario, supra note 10. 

74 CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023) 

(searching the organization names “Stand Up for Justice” and “Broken Promises”). 

75 Id. (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for Justice’s business 

address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006); American Valor PAC, 2020 

Attachment 5 

Page 17 of 33

MUR808200430
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 18 of 33

1 2018 federal tax return, Stand Up for Justice is a 501(c)(4) corporation; its purpose is to 

2 “develop[] and advocat[e] for legistlation [sic], regulations and government programs to improve 

3 social environment, economy & society”; Anderson was a director and its president; it did not 

have a website; and it received $350,000 in funding that year.76 4 

5 On March 31, 2020, Stand Up for Justice made a $50,000 contribution to South Florida 

Residents First,

77 6 an IEOPC that made independent expenditures during the 2020 election cycle 

7 only in Florida’s 26th Congressional District, which supported Republican nominee Carlos 

Gimenez and opposed Democratic nominee Debbie Mucarsel-Powell.78 8 In addition, just two 

9 months after it was incorporated, Stand Up for Justice made contributions to a Florida political 

committee in October 2018, totaling $300,000,79 10 which Stand Up for Justice characterized as 

“lobbying” on its 2018 federal tax return.80 11 Thus, it appears that Stand Up for Justice made at 

12 least $350,000 in political contributions during its existence. 

Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/202012039337569242/20201203

9337569242.pdf (reflecting that CAIJ’s address is at 2020 Pennsylvania Avenue, NW, Ste. 449, Washington DC 

20006). 

76 IRS Form 990, Stand Up for Justice, 2018 Return of Organization Exempt from Income Tax at 1-2, 7 

(Nov. 15, 2019), https://apps.irs.gov/pub/epostcard/cor/831749759_201812_990O_2020021317141891.pdf

[hereinafter Stand Up for Justice 2018 Tax Return]. 

77 South Florida Residents First, 2020 April Quarterly Report at 11 (April 13, 2020), https://docquery.fec

.gov/pdf/294/202004159216942294/202004159216942294.pdf; see also Compl. ¶ 53.

78 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00733402&is_notice=false&min_date=01%2F01%2F2019&max

_date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting South Florida Residents First’s independent 

expenditures in the 2020 election cycle); November 3, 2020 General Election, FL DEP’T OF STATE DIV. OF 

ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=11/3/2020&DATAMODE= (last visited 

Sept. 25, 2023) (selecting “Federal Offices”) (reflecting that Carlos Gimenez was the Republican nominee and

Debbie Mucarsel-Powell was the Democratic nominee in Florida’s 26th Congressional District); see Compl. ¶ 53. 

79 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited July 25, 2023) (searching election year “all” and contributor last name starting 

with “Stand Up for Justice”).

80 Stand Up for Justice 2018 Tax Return at 10, supra note 76. 

Attachment 5 

Page 18 of 33

MUR808200431
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 19 of 33

1 According to Stand Up for Justice’s federal tax returns, it received $350,000 to $450,000 

during its existence: $350,000 in 2018,81 2 and $50,000 or less per year in each of 2019 and 2020 

before terminating.82 3 Stand Up for Justice’s federal tax returns also state that it spent $20,577 on 

legal fees and $100 on bank service charges in 2018,83 4 indicating that its total funding was at 

5 least $370,677 to cover its lifetime spending. Thus, Stand Up for Justice spent at least 78% to 

6 94% of its total funding on making political contributions.

7 Federal tax records show that Alliance for Consumer Protection Inc., contributed 

$150,000 to Stand Up for Justice in 2018.84 8 As indicated above, the Alliance for Consumer 

9 Protection Inc. also contributed $100,000 to Broken Promises in 2018, and its executive director 

is reportedly Pitts’s former college roommate.

85 10 

11 C. Let’s Preserve the American Dream, Inc., was Associated with Pitts and 

12 Matrix

13 Relying on news reports of Matrix’s proposal to FPL, which reference LPAD as a higher14 level Matrix-associated conduit that would receive funds and transmit them to other entities in 

15 Matrix’s network, and news reports indicating that LPAD made donations to Grow United and 

16 Broken Promises, the Complaint alleges that Unknown Respondents used LPAD as a middleman 

to make contributions using the names of Grow United and Broken Promises.86 17 

81 Id. at 1.

82 For 2019 and 2020, Stand Up for Justice filed an IRS Form 990-N, and indicated that its gross receipts 

were not greater than $50,000 in those years. Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/

eos/ (last visited Sept. 25, 2023) (searching organization name “Stand Up for Justice”).

83 Stand Up for Justice 2018 Tax Return at 10, supra note 76. 

84 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095_201812_990O_20211020

19109756.pdf. 

85 Id.; Nightmare Scenario, supra note 10. 

86 Compl. ¶¶ 33 Fig. 1, 35, 37, 42 Fig. 2, 45, 52; see also Secretive Political Spending Plan, supra note 12. 

Attachment 5 

Page 19 of 33

MUR808200432
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 20 of 33

1 In a deposition conducted by the Miami-Dade State Attorney’s Office regarding a former 

2 LPAD contractor’s creation of fake Florida state senate candidates, Tyson stated that he 

3 discussed LPAD’s donation to Grow United with Matrix’s former CEO, Jeff Pitts, and that it was 

4 actually Pitts who proposed for LPAD to make that donation. Specifically, Tyson testified: 

5 Well, as best as I can recall, I called [Pitts] up and I said, “Do you 

6 have any social welfare groups that are interested in working on 

7 issues that are amenable to my organizational narrative? Are they 

8 interested in supporting other interests in other committees around 

9 the country, in Florida specifically too, that would focus purely on 

the center left spectrum and on issues that are center left?”87 10 

11 According to Tyson, Pitts “said he did,” referring to Grow United, and so Tyson “said we’d be 

12 happy to support them.” 

13 In the same above-referenced deposition, Tyson also testified that he spoke with Pitts 

14 about how Grow United should use LPAD’s donation. Specifically, in response to whether 

15 Tyson knew that Alex Alvarado’s Florida state political committees received their funding from 

16 Grow United, Tyson stated, “I told you earlier I knew it came from Grow United. There was a 

17 story about it. And I knew, I actually told Grow United that Alvarado would probably call them 

and ask, raise money.”88 18 Tyson further explained that the person he spoke with was Jeff Pitts. 

19 According to text messages obtained by the Orlando Sentinel, on September 24, 2020, just five 

20 days prior to LPAD making its first $600,000 donation to Grow United on September 29, 2020, 

21 Tyson communicated with Pitts and Abigail MacIver, another former Matrix employee, 

regarding the Florida state senate races that the Alvarado committees were seeking to impact.89 22 

87 Tyson testified in response to the question, “So give me your best recollection of the content of the 

conversation that you had with Jeff Pitts that caused you to want to send the money to Grow United.”

88 Emphasis was added to the original transcription.

89 FPL Execs, supra note 43. 

Attachment 5 

Page 20 of 33

MUR808200433
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 21 of 33

1 When further queried as to whether Tyson “did not authorize the money, the $600,000 

2 [from LPAD], to go to Grow United so they can then turn around and send it to Alex Alvarado’s 

3 two political campaigns,” Tyson testified that he “can’t tell [Grow United] how to spend their 

4 money” and that he “do[es]n’t have the ability to restrain how they spend their funds.” However, 

5 when asked, “Did you know when this $600,000 [from LPAD] was sent to Grow United, that it 

6 was going to [⸺] that 550,000 of it was going to go to Alex Alvarado’s two political 

7 committees,” Tyson testified that he “had a hunch” that Grow United would be supportive of the 

8 Alvarado committees and that he was “not testifying it’s a coincidence.” Tyson further stated, “I 

9 knew [Grow United] would likely be supportive, but I also didn’t know when, I mean, we made 

10 other contributions to them as well. We were supporting a lot of what they were doing.” Tyson 

11 then testified that he “assume[d] [Grow United would] probably be supported [sic] if Alex 

12 called, but I had no way to know if they actually would. Because once I make a contribution to 

13 an entity, I lose control of how they spend that money.” 

14 D. SUN Marketing & Advertising LLC Appears to be Associated with Matrix

15 SUN Marketing & Advertising LLC is another conduit identified in Matrix’s proposal to 

FPL,

90 16 and it appears to have been created by Matrix after the memo was circulated. 

17 Specifically, SUN was formed on December 13, 2019, about two weeks after Pitts reportedly 

emailed the above-referenced proposal to Silagy on November 26, 2019.91 18 FPL spokesman 

19 Reuter reportedly confirmed that FPL gave $250,000 to SUN in December 2019, but stated that 

20 the purpose was to purchase advertising related to a proposed constitutional amendment that FPL 

90 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 32 Fig. 1.

91 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “SUN Marketing & Advertising”). 

Attachment 5 

Page 21 of 33

MUR808200434
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 22 of 33

opposed.92 According to Reuter, FPL believes that SUN is owned by Matrix.93 1 News reports 

indicate that SUN was used to create favorable press for FPL.94 2 SUN’s former sole member, 

Tim Fitzpatrick, was a former FPL officer.95 3 

4 III. LEGAL ANALYSIS

5 A. The Commission Finds Reason to Believe that the $20,000 Contribution 

6 Reported as Having Been Made by Broken Promises Was a Contribution 

7 Made In the Name of Another

8 The Act and the Commission’s regulations prohibit a person from (1) making a 

9 contribution in the name of another person, (2) knowingly permitting his or her name to be used 

to effect such a contribution, and (3) knowingly accepting such a contribution.96 10 The term 

11 “person” in this context includes partnerships, corporations, and “any other organization or group 

of persons.”97 12 In its regulations, the Commission has illustrated examples of activities that 

13 constitute making a contribution in the name of another, as follows: 

14 (i) Giving money or anything of value, all or part of which was 

15 provided to the contributor by another person (the true contributor) 

16 without disclosing the source of money or the thing of value to the 

17 recipient candidate or committee at the time the contribution is 

18 made; or

92 Secretive Political Spending Plan, supra note 12. 

93 Id.

94 Sarah Blaskey, Powerbrokers: How FPL Secretly Took Over a Florida News Site and Used It to Bash 

Critics, MIAMI HERALD (Aug. 13, 2022), https://www.miamiherald.com/article263757423.html. 

95 PG&E Names Tim Fitzpatrick As Vice President And Chief Communications Officer, CISION PR

NEWSWIRE (Mar. 11, 2013), https://www.prnewswire.com/news-releases/pge-names-tim-fitzpatrick-as-vicepresident-and-chief-communications-officer-197098061.html (“Fitzpatrick joined NextEra Energy in January 2008, 

serving as Vice President of Marketing and Corporate Communications and as an officer of Florida Power & Light 

Company (FPL).”).

96 52 U.S.C. § 30122; see also 11 C.F.R. § 110.4(b).

97 52 U.S.C. § 30101(11); 11 C.F.R. § 100.10.

Attachment 5 

Page 22 of 33

MUR808200435
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 23 of 33

1 (ii) Making a contribution of money or anything of value and 

2 attributing as the source of the money or thing of value another 

person when in fact the contributor is the source.98 3 

4 Because a primary purpose of the Act’s disclosure provisions is to reveal the true source from 

5 which a contribution to a candidate or committee originates, regardless of the mechanism by 

which the funds are transmitted,99 6 the Commission examines the structure of the transaction 

7 itself and the arrangement between the parties to determine who in fact “made” a given 

contribution.100 8 

9 In prior matters, the Commission has found reason to believe that a contribution was 

10 made in the name of another where the available information indicates that another person 

11 provided the funds for the purpose of making the contribution and his or her identity was not 

disclosed to the recipient committee or candidate at the time of the contribution.

101 12 Absent direct 

13 evidence as to the purpose of providing the funds, the Commission considers the overall record

14 to determine its purpose. In the context of contributions made by limited liability companies 

15 (“LLCs”), the Commission has addressed whether the LLC “had the means to make the 

16 contribution absent an infusion of funds provided for that purpose,” the “temporal proximity 

98 11 C.F.R. § 110.4(b)(2)(i)-(ii).

99 See Campaign Legal Ctr. v. FEC, 952 F.3d 352, 354 (D.C. Cir. 2020) (“As the Supreme Court has 

repeatedly declared, the electorate has an interest in knowing where political campaign money comes from and how 

it is spent by the candidate. To that end, the [Act] imposes disclosure requirements on those who give and spend 

money to influence elections. The straw donor provision, 52 U.S.C. § 30122, is designed to ensure accurate 

disclosure of contributor information.”) (internal citations and quotation marks omitted). 

100 Cf. 11 C.F.R. § 110.6(a) (“All contributions by a person made on behalf of or to a candidate, including 

contributions which are in any way earmarked or otherwise directed to the candidate through an intermediary or 

conduit, are contributions from the person to the candidate.”).

101 See, e.g., Factual and Legal Analysis (“F&LA”) at 5, MUR 7903 (Tomfoolery, LLC, et al.) (“[T]he 

contributions made in Tomfoolery’s name were, in fact, actually made by Thomas A. Chavez, when Chavez 

furnished Tomfoolery with funds for the purpose of having the LLC make the contributions.”); F&LA at 1-2, 

MUR 6920 (American Conservative Union) (finding reason to believe that the contribution was made in the name of 

another where the organization who was reported as the contributor later indicated that it was not the true source of 

the contribution, and instead merely delivered the contribution upon receipt of the funds from another person); see 

also 11 C.F.R. § 110.4(b)(2)(i)-(ii).

Attachment 5 

Page 23 of 33

MUR808200436
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 24 of 33

1 between the LLC’s formation date and the contribution,” “the amount of the contribution relative 

2 to [the LLC’s] other activities, the LLC’s known activities prior to making the contribution, and 

3 whether any other information suggests an attempt to circumvent the Act’s disclosure 

4 requirements.” 

5 Here, the available information indicates that the five 2020 political contributions 

6 purportedly made by the alleged Conduit Corporations — Florida Promise, Broken Promises, 

7 Grow United, CAIJ, and Stand Up for Justice — were actually made on behalf of Unknown 

8 Respondents. The overall record indicates that there was plan whose purpose was “to 

9 circumvent the Act’s disclosure requirements” by using the names of the Conduit Corporations 

10 to make contributions and that this plan was implemented in largely the way the blueprint set 

11 out. In addition, the overall record of the Conduit Corporations’ known activities indicate that 

12 they may have been formed for the purpose of making conduit contributions. 

13 Specifically, news articles indicate that, during the 2020 election cycle, Matrix invited 

14 FPL to anonymize its political activities by funneling money through several layers of conduits, 

15 including Florida Promise and Broken Promises, and then using those funds to make federal and 

state political contributions.

102 16 The articles report that Jeff Pitts, former CEO of Matrix, emailed

17 Eric Silagy, former CEO of FPL, a “‘funding memo’” with goals such as making “federal 

18 campaign contributions” and “‘minimiz[ing] all public reporting of entities and activities,’” and a 

“‘legal memo on federal elections support.’”103 19 According to the Orlando Sentinel, the funding 

20 memo included a flowchart depicting FPL’s funds flowing through several layers of conduits 

21 controlled by Pitts and Matrix, including Florida Promise and Broken Promises, before being 

102 Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 3, 31-38. 

103 Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 3, 31-32. 

Attachment 5 

Page 24 of 33

MUR808200437
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 25 of 33

contributed to federal and state political committees.104 1 While the specific plan reported by the 

2 news articles did not directly identify CAIJ, Grow United, or Stand Up for Justice, the proposal 

3 establishes the preexisting idea of making conduit contributions with entities just like these, 

4 which as discussed below, was ultimately carried out using the five alleged Conduit 

5 Corporations. 

6 News articles stated that the sources of the documents were from Matrix itself, noting 

that the documents were internal Matrix documents.105 7 FPL’s spokesperson, David Reuter, 

8 reportedly confirmed that the proposal as reported was indeed shared with its CEO, stating, “‘We 

9 are aware of the proposed structure as the legal memo was shared with us, and as we understand 

10 it, Joe Perkins’[s] team at Matrix created a proposal to fund their clients’ communication and 

outreach activities during 2020.’”106 11 Thus, there is no available information indicating that the 

12 news articles’ report that Pitts and Matrix created and shared a proposal to anonymize political 

13 contributions was inaccurate or not credible. 

14 Moreover, the available information does not indicate that the proposal was limited to 

15 acting solely within the legal bounds of minimizing public reporting of political activities. 

16 Specifically, the proposal did not indicate that Pitts and Matrix were soliciting funds from FPL 

17 on behalf of nonprofit corporations that would independently decide to make political 

18 contributions. Rather, the proposal indicated that funds would flow from FPL, through several 

19 layers of conduits controlled or associated with Matrix, before landing at “Florida Promise C4,” 

104 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

105 See Secretive Political Spending Plan, supra note 12 (stating that the Orlando Sentinel received records 

“includ[ing] checks, bank statements, emails, text messages, invoices, internal ledgers and more, all apparently 

unearthed during an internal investigation Matrix launched after its former employees left the firm at the end of 

2020.”).

106 Id.

Attachment 5 

Page 25 of 33

MUR808200438
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 26 of 33

1 “US Promise C4” and “Fed Promise C4,” which would also be controlled by Matrix, to make 

contributions to state and federal political committees.107 2 

3 Notably, there is no available information indicating that Pitts or Matrix presented the 

4 purposes or goals of the conduits referenced in its flowchart, besides being able to making 

5 political contributions, to explain why FPL’s funds would be expected to flow from one 

corporation to another.108 6 There is also no available information indicating that Pitts and Matrix 

7 presented any information as to why “Florida Promise C4,” “US Promise C4” and “Fed Promise 

8 C4,” would be expected to engage in political activity that FPL would support. Instead, Pitts’s 

9 and Matrix’s flowchart simply noted “Matrix” in a parenthetical below the names of “Broken 

10 Promises,” “Florida Promise C4,” “US Promise C4” and “Fed Promise C4,” similar to how 

11 Tyson, the executive director of LPAD, was included in a parenthetical under LPAD, suggesting 

that these entities are controlled by “Matrix,” similar to how Tyson controlled LPAD.109 12 

13 Moreover, the conduits depicted on the flowchart appear to have been in fact controlled 

14 by or associated with Matrix. Of the conduits mentioned, only Florida Promise, Broken 

15 Promises, LPAD, and SUN existed or eventually came into existence, and they all have ties to 

16 Pitts and/or Matrix. As explained above, Richard Alexander was the chairman of Florida 

Promise, and his sister, April Odom, was a Matrix contractor at the time of the allegations.110 17 

107 Id.; see also Compl. ¶¶ 33 Fig. 1, 36-37. 

108 See Secretive Political Spending Plan, supra note 12 (noting that, for example, “Florida Promise C4” would 

“allowed to spend 50% of revenues on political activities” and that “Florida PCs are allowed to take unlimited funds 

from C4s”); see also Compl. ¶ 33 Fig. 1 (same).

109 See Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1. While the term “person” 

appears in the parenthetical next to SUN, SUN had not yet been formed when Pitts sent the memo, and thus this

denotation appears to suggest that they were looking for a “person” to be in control of SUN at that time. See 

Secretive Political Spending Plan, supra note 12 (reporting that Pitts sent the memo to Silagy on November 26, 

2019).

110 Florida Promise 2018 Tax Return at 3, supra note 32; Dark Money Playbook, supra note 7 (reporting that 

April Odom is Anderson’s sister and was a former Matrix employee).

Attachment 5 

Page 26 of 33

MUR808200439
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 27 of 33

1 Sean J. Anderson, who was the president and chairman of Broken Promises, was also a former 

2 Matrix employee, a close friend of Pitts, and has a history of allowing Pitts to control the 

nonprofits that he purportedly ran.

111 3 Tyson, the executive director of LPAD, reportedly 

4 associated with Pitts and Abigail MacIver, another former Matrix employee, as they 

communicated via text messages regarding Florida state senate races.112 5 Finally, as for SUN ⸺

6 FPL, which reportedly gave $250,000 to SUN in December 2019, states that it believes that SUN 

is owned by Matrix.113 7 Thus, the layers of corporations depicted on the flowchart appear to be 

8 linked together because they are controlled by persons associated with Pitts or Matrix. 

9 The available information also indicates that Pitts’s and Matrix’s proposal included the 

10 making of federal political contributions. According to news articles, Pitts’s email to Silagy 

11 included a “‘funding memo’” noting making “federal campaign contributions” as one of its 

goals.114 12 Pitts’s email to Silagy also included “‘a separate legal memo on federal elections 

13 support’” explaining that “a nonprofit might have to disclose its donors if it spent money directly 

14 supporting a candidate” but that “the nonprofit would not have to disclose its donors if it gave 

money to a type of political action committee known as a ‘Super PAC,’”115 15 which is a colloquial 

reference to federal independent expenditure-only committees.116 16 Moreover, this legal memo 

111 Broken Promises, 2018 Tax Return at 1, 7, supra note 60; Bachelor Party, supra note 10 (reporting Pitts as 

having attended Anderson’s bachelor party); Nightmare Scenario, supra note 10 (reporting that Pitts texted FPL 

Vice President Martell that Anderson was an old friend of his and that he was “‘in control 100 percent’” of the 

nonprofits purportedly run by Mr. Anderson).

112 FPL Execs, supra note 43. 

113 Secretive Political Spending Plan, supra note 12. 

114 Id.; see also Compl. ¶ 32.

115 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 38.

116 See McCutcheon v. FEC, 572 U.S. 185, 193 (2014) (“A so-called ‘Super PAC’ is a PAC that makes only 

independent expenditures and cannot contribute to candidates. The base and aggregate limits govern contributions 

to traditional PACs, but not to independent expenditure PACs.”).

Attachment 5 

Page 27 of 33

MUR808200440
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 28 of 33

1 appears to provide the missing explanation as to the purpose of providing funds to the “Fed 

2 Promise C4” entity in the funding memo’s flowchart, indicating that this purpose would be to 

make federal political contributions.117 3 The name, “Fed Promise C4,” also suggests that this 

4 conduit would be used to make federal political contributions, as this would be consistent with 

5 and parallel to the flowchart’s statements that “Florida Promise C4” would be used to fund 

6 “Florida PCs” and that “US Promise C4” would be used to fund other state-level political 

activities.118 7 Thus, the available information indicates that the Pitts/Matrix proposal included 

8 making federal political contributions. 

9 The available information also indicates that the alleged Conduit Corporations received 

10 funds with the direction that they be used for federal contribution purposes as federal courts have 

11 stated that a donor’s intent can be inferred from the donee’s solicitations. Specifically, in the 

12 context of interpreting 52 U.S.C. § 30104(c)(1) of the Act, which courts have held to require notpolitical committees to disclose donations received for political purposes,119 13 a district court in 

14 Wisconsin observed that “whether a contribution is earmarked for political purposes and tied to 

15 an election can depend on whether the contribution is received in response to a solicitation and 

the way the solicitation is worded.”120 16 As explained above, Pitts’s and Matrix’s proposal clearly 

17 implicated the making of federal contributions, and the alleged Conduit Corporations appear to 

18 have received donations in response to that proposal.

19 In addition to conceiving of and sharing the plan, Pitts and Matrix were also in a position 

117 See Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1 (noting that it was 

“[w]aiting on lawyers” to explain the purpose of Fed Promise C4).

118 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

119 Citizens for Resp. & Ethics in Washington v. FEC, 316 F. Supp. 3d 349, 389 (D.D.C. 2018), aff’d, 971 F.3d 

340 (D.C. Cir. 2020).

120 Wisconsin Fam. Action v. FEC, No. 21-C-1373, 2022 WL 844436, at *11 (E.D. Wis. Mar. 22, 2022). 

Attachment 5 

Page 28 of 33

MUR808200441
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 29 of 33

1 to carry it out using the names of alleged Conduit Corporations to make the contributions. As 

2 discussed above, the persons nominally in charge of the alleged Conduit Corporations, 

3 Alexander and Anderson, had close relationships with Pitts and Matrix. Alexander, who served 

4 as a director or officer of Florida Promise, CAIJ, and Grow United, is apparently the brother of 

5 April Odom, who was a Matrix contractor at the time of the contributions and worked on matters 

relating to CAIJ and Grow United on behalf of Matrix.121 6 Anderson, who was the chairman and 

7 president of Broken Promises and a director and president of Stand Up for Justice, was also 

former Matrix employee, and a close friend of Pitts.122 8 Pitts and Matrix also has a history of 

9 working with Anderson’s nonprofit corporations, as Pitts reportedly texted FPL Vice President 

10 Daniel Martell in 2016, four years prior to the contributions at issue here, “‘Bottom line is we are 

11 the ones with the check books and in control 100 percent’” of the nonprofits purportedly run by 

Anderson.123 12 

13 Pitts and Matrix also reportedly used the names of CAIJ and Grow United in other 

operations,124 and had access to CAIJ’s and Grow United’s bank accounts,125 14 further indicating 

15 that they had control over these corporations. Specifically, news reports indicate that, in October 

121 Dark Money Playbook, supra note 7 (reporting that April Odom is Anderson’s sister and was a former 

Matrix contractor); see also Compl. ¶¶ 13, 48.

122 Bachelor Party, supra note 10 (reporting Pitts as having attended Anderson’s bachelor party); Nightmare 

Scenario, supra note 10 (reporting that Pitts texted FPL Vice President Martell that Anderson was an old friend of 

his); see also Compl. ¶¶ 16, 52.

123 Nightmare Scenario, supra note 10; see also Compl. ¶¶ 16, 52. 

124 FPL Execs, supra note 43 (reporting that Matrix made a conduit contribution using CAIJ’s name on behalf 

of FPL); Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/ (reporting that Matrix offered a city councilman 

a job on behalf of FPL using Grow United’s name).

125 Dark Money Playbook, supra note 7 (reporting that internal Matrix records included a text message from

Odom stating that she procured access to the bank accounts of CAIJ and Grow United). 

Attachment 5 

Page 29 of 33

MUR808200442
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 30 of 33

2018, Pitts used CAIJ to make a contribution to House Majority PAC on behalf of Matrix.126 1 

2 News reports also indicate that in the summer of 2019, Matrix used Grow United to offer a job to 

a Jacksonville City Council member on behalf of FPL.127 3 In addition, according to the Orlando 

4 Sentinel, it received internal Matrix documents reflecting a September 23, 2020 text message 

from Odom stating that she procured access to CAIJ’s and Grow United’s bank accounts.128 5 

6 Finally, Tyson, the executive director of LPAD who donated $1,150,000 of LPAD funds to 

7 Grow United, testified that he understood that Pitts created and ran Grow United. Therefore, not 

8 only did Pitts and Matrix conceive of a plan for the making of conduit contributions, they also 

9 had sufficient control over the alleged Conduit Corporations to cause them to permit their names 

10 to be used to make contributions on behalf of Unknown Respondents. 

11 Although all five of the alleged Conduit Corporations were formed more than a year prior 

12 to making the contributions, the overall record of their known activities indicate that they were 

13 formed for the purpose of making conduit contributions. The only available information as to 

14 the five alleged Conduit Corporations’ activities was that they made federal and Florida state 

political contributions.129 15 Broken Promises and Stand Up for Justice spent at least 67% to 89% 

126 FPL Execs, see supra note 43 (reporting that Silagy, former CEO of FPL, emailed Pitts, former CEO of 

Matrix, to make a contribution to House Majority PAC to support Lauren Baer, and to make sure that “they don’t 

triangulate this donation to others we have done”); see also House Majority PAC, 2018 Amended 12-Day PreElection Report at 655 (Dec. 3, 2018), https://docquery.fec.gov/pdf/085/201812069135107085/20181206913510

7085.pdf (reflecting CAIJ’s contribution to House Majority PAC on October 16, 2018).

127 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/. FPL reportedly confirmed that Matrix 

employees came up with an idea to offer the City Council member a job, but that it rejected the idea. Id. 

128 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right-hand corner 

of the article’s sixth picture); see also Compl. ¶ 48.

129 Although Matrix reportedly used Grow United to offer a job to a Jacksonville council member, that never 

came to fruition as the council member rejected the offer. Nate Monroe, Amid JEA Privatization Controversy, a 

City Council Member Received a Mysterious Job Offer. A Dark-Money Group May Have Been Behind It, THE FL

Attachment 5 

Page 30 of 33

MUR808200443
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 31 of 33

1 and 78% to 94%, respectively, of their total funding on making federal and Florida state political 

2 contributions, indicating that they were created for the primary purpose of making political 

contributions.130 3 Moreover, consistent with the Pitts’s and Matrix’s proposal, federal tax records 

4 show that their funding was first transmitted through another Matrix-associated conduit, the 

5 Alliance for Consumer Protection Inc., which was reportedly controlled by Pitts’s former college 

roommate.131 6 While the available information does not indicate the total funding received by 

7 Florida Promise, CAIJ, or Grow United, the only known activities by these corporations are that 

they made an aggregate of $3,224,500 in federal and Florida state political contributions.

132 8 

9 In addition, only Florida Promise, Broken Promises, and Stand Up for Justice appeared to 

10 have filed federal tax returns, and these returns do not indicate that they engaged in any activity 

other than making political contributions, including through lobbying.133 11 The purpose 

12 statements in these tax returns indicate that Florida Promise, Broken Promises, and Stand Up for 

13 Justice were formed for political purposes, further suggesting they only engaged in political 

TIMES-UNION (Sept. 2, 2022), https://www.jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-salejacksonville-city-council-member-mysterious-job-offer-dark-money-group-nate-monroe/8850689002/. 

130 See supra pages 15-16, 18-19.

131 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095_201812_990O_20211020

19109756.pdf; Nightmare Scenario, supra note 10. 

132 See supra notes 33-34 and accompanying text (reflecting that Florida Promise made $1,230,000 in federal 

and Florida state contributions); supra notes 38, 40, 38 and accompanying text (reflecting that CAIJ made $432,000 

in federal and Florida state contributions); supra notes 46, 49 and accompanying text (reflecting that Grow United 

made $1,562,500 in federal and Florida state contributions).

133 See generally Florida Promise 2018 Tax Return, supra note 32; Broken Promises 2018 Tax Return, supra

note 60; Stand Up for Justice 2018 Tax Return, supra note 76. As indicated above, while Broken Promises and 

Stand Up for Justice indicated in their 2018 federal tax returns that they spent funding on “lobbying” and “other”

program expenses in 2018, the amounts they reportedly spent correspond to the same amounts that they spent on 

making Florida state political contributions. See supra pages 16, 18. 

Attachment 5 

Page 31 of 33

MUR808200444
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 32 of 33

activities.

134 1 

2 Furthermore, there are various organizational aspects of the alleged Conduit Corporations 

3 that suggest they were formed to serve as conduits. Specifically, despite the fact that CAIJ and 

4 Stand Up for Justice were incorporated in different states and do not share any officers, both 

entities reported having the same mailing address in Washington, D.C.135 5 In addition, despite 

6 both Broken Promises and Stand Up for Justice having the same three officers and nearly 

7 identical mission statements, both entities were incorporated on the same day in the same 

state.

136 8 Finally, Broken Promises’s federal tax return suggests that it was trying to conceal that 

9 it made political contributions. Specifically, Broken Promises characterized on its 2018 federal 

10 tax return that it spent $115,470 on “other” program service expenses, when that amount was 

actually used to make in-kind contributions to Florida state committees.137 11 Thus, the available 

12 information as to the activities, stated purpose, and creation of the Conduit Corporations suggests 

13 that they were created for making conduit contributions. 

134 Florida Promise 2018 Tax Return at 6, supra note 32 (stating that its purpose is to “develop and advocate 

for legislation, regulations, and government programs related to policies to benefit Floridians”); Broken Promises 

2018 Tax Return at 2, supra note 60 (stating that its purpose is to “develop[] and advocat[e] for legislation, 

regulations, and government programs to improve social environmental, economy and social environment”); Stand 

Up for Justice 2018 Tax Return at 2, supra note 76 (stating that its purpose is to “develop[] and advocat[e] for 

legistlation [sic], regulations, and government programs to improve social environment, economy & society”).

135 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting that CAIJ’s address was at 2020 Pennsylvania Avenue, 

NW, Ste. 449, Washington DC 20006); CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing

(last visited Sept. 25, 2023) (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for 

Justice’s business address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006). 

136 See CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023) 

(searching the organization names “Broken Promises” and “Stand Up For Justice”) (reflecting that both Broken 

Promises and Stand Up for Justice were incorporated on August 29, 2018); Broken Promises 2018 Tax Return at 1, 

7, supra note 60; Stand Up for Justice 2018 Tax Return at 1, 7, supra note 76. 

137 Compare Broken Promises 2018 Tax Return at 10, supra note 60 (stating that it spent $115,470 in “other” 

program service expenses), with Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.

myflorida.com/campaign-finance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and 

contributor last name “Broken Promises”) (reflecting that Broken Promises Broken Promises made $115,470 in inkind Florida state political contributions in 2018).

Attachment 5 

Page 32 of 33

MUR808200445
MUR 8082 (Broken Promises) 

Factual and Legal Analysis

Page 33 of 33

1 In sum, the available information indicates that there was a plan to illegally disguise or 

2 withhold public reporting of political activities, and that this plan included making contributions 

3 through conduits and in a manner that closely matches what the available information shows had 

4 subsequently occurred. In addition, pursuant to this plan, the alleged Conduit Corporations 

5 permitted their names to be used to make federal political contributions on behalf of Unknown 

6 Respondents. Finally, the only known activities of the alleged Conduit Corporations were that 

7 they made federal and Florida state political contributions, indicating that their purpose was to 

8 serve as conduits. Thus, the Commission finds reason to believe that Broken Promises violated 

9 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b) by knowingly permitting its name to be used to 

10 effect contributions in the name of another. 

Attachment 5 

Page 33 of 33

MUR808200446
1 FEDERAL ELECTION COMMISSION

2 FACTUAL AND LEGAL ANALYSIS

3 RESPONDENT: Stand Up for Justice MUR 8082 

4 I. INTRODUCTION

5 The Complaint alleges that Unknown Respondents made contributions in the name of 

6 another through a network of conduits associated with a political consulting firm called Matrix 

LLC (“Matrix”), to five federal independent expenditure-only political committees (“IEOPCs”).

1 7 

8 The specific contributions identified in the Complaint are as follows: 

9 • a $1,000,000 contribution reportedly from Florida Promise, Inc. (“Florida Promise”)

to Senate Leadership Fund, dated December 8, 2020;2 10 

11 • a $100,000 contribution reportedly from the Center for Advancement of Integrity and

Justice, Inc. (“CAIJ”) to American Valor PAC, dated October 27, 2020;3 12 

13 • a $100,000 contribution reportedly from Grow United, Inc. (“Grow United”) to

Conservative Action Fund (f/k/a Wingman PAC), also dated October 27, 2020;4 14 

15 • a $20,000 contribution reportedly from Broken Promises to Concerned

Conservatives, Inc., dated July 14, 2020;5 16 and

17 • a $50,000 contribution reportedly from Stand Up for Justice to South Florida

Residents First, dated March 31, 2020.6 18 

1 Compl. ¶¶ 2, 5, 27, 42, 89-93 (Oct. 27, 2022).

2 Senate Leadership Fund, Amended 2020 Year End Report at 72 (Mar. 18, 2021), https://docquery.fec.gov/

pdf/807/202103189441299807/202103189441299807.pdf; see also Compl. ¶¶ 49-50.

3

 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/2020

12039337569242/202012039337569242.pdf; see also Compl. ¶¶ 47-48.

4

 Wingman PAC, 2020 30-Day Post Election Report at 1, 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting a $100,000 contribution from Grow United, Inc., on 

October 27, 2020, and the committee’s FEC identification number of C00742296); Conservative Action Fund, 

Amended Statement of Organization at 1 (May 20, 2022), https://docquery.fec.gov/pdf/048/202205209512421048/

202205209512421048.pdf (reflecting that its name has changed to Conservative Action Fund and that its FEC 

identification number is C00742296); see also Compl. ¶¶ 43-44.

5 Concerned Conservatives, Inc., 2020 12-Day Pre-Primary Election Report at 6 (Aug. 6, 2020), https://doc

query.fec.gov/pdf/823/202008069261263823/202008069261263823.pdf; see also Compl. ¶¶ 51-52.

6

 South Florida Residents First, 2020 April Quarterly Report at 11 (Apr. 13, 2020), https://docquery.fec.gov/

pdf/294/202004159216942294/202004159216942294.pdf; see also Compl. ¶¶ 53-54.

Attachment 6 

Page 1 of 33

MUR808200447
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 2 of 33

1 The Complaint relies on news articles regarding a 2019 email and two accompanying 

2 memoranda sent from Jeff Pitts, Matrix’s former CEO, to Eric Silagy, Florida Power & Light 

3 Company’s (FPL) former CEO, reportedly proposing a method for FPL to make anonymous 

4 contributions to federal and state political committees by transferring funds through multiple 

levels of conduits.7 5 The proposal called for funds to be first sent to and passed through higher6 level Matrix-associated conduits, including SUN Marketing & Advertising LLC (“SUN”) and 

7 Let’s Preserve the American Dream, Inc. (“LPAD”), before being sent to various lower-level 

8 Matrix-controlled conduits, including Florida Promise, that would be reported as the source of 

9 the contributions. Thus, the Complaint alleges that each of the five alleged lower-level Matrix10 controlled conduits (referred to herein as the “Conduit Corporations”) permitted their names to 

11 be used to effect contributions in the name of another pursuant to Pitts’s and Matrix’s proposal. 

12 To support its central allegation, the Complaint alleges that all five of the alleged Conduit 

13 Corporations had ties to Pitts or Matrix through having either Richard Alexander or Sean J. 

Anderson as a director or officer.

8 14 Citing news articles, the Complaint alleges that Alexander’s 

sister was a Matrix contractor at the time of the allegations9 15 and that Anderson was a former 

Matrix employee and a good friend of Pitts.10 16 

7

 Compl. ¶¶ 3-4, 28-41; see, e.g., Jason Garcia & Annie Martin, Florida’s Dark Money Playbook: How 

‘Ghost’ Candidate Scheme Revealed Secretive Political Tactics, ORLANDO SENTINEL (Dec. 30, 2021), 

https://www.orlandosentinel.com/news/os-ne-dark-money-ghost-candidates-tactics-20211230-7zelkoadffclde3z

76ax3cgx3m-htmlstory.html [hereinafter Dark Money Playbook].

8

 Compl. ¶¶ 13, 16. 

9

 Id. ¶ 13; see Dark Money Playbook, supra note 7 (reporting that Alexander’s sister, April Odom, was a 

Matrix employee at the time of the allegations, and that she worked on matters relating to Grow United and CAIJ).

10 Compl ¶ 16; see John Archibald, Archibald: ‘Bachelor party’ Makes For Strange Bedfellows, AL.COM

(Nov. 14, 2010), https://www.al.com/archiblog/2010/11/archibald bachelor party makes.html [hereinafter 

“Bachelor Party”] (reporting that Pitts attended Anderson’s bachelor party and that they were both employed by 

Matrix at the time); Mary Ellen Klas, et al., ‘Nightmare Scenario’: How FPL Secretly Manipulated a Florida State 

Senate Election, MIAMI HERALD (Aug. 29, 2022), https://www.miamiherald.com/news/politics-government/statepolitics/article264196761.html [hereinafter “Nightmare Scenario”] (reporting that Pitts texted FPL vice president 

Attachment 6 

Page 2 of 33

MUR808200448
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 3 of 33

1 As discussed below, the five contributions purportedly made by the alleged Conduit 

2 Corporations as identified by the Complaint appear to be consistent with the conduit 

3 contributions proposed by Pitts and Matrix to FPL to anonymize its political contributions. In 

4 addition, all five of the alleged Conduit Corporations appear to be controlled by or associated 

5 with Pitts and Matrix. Accordingly, the Commission finds reason to believe that Stand Up for 

6 Justice violated 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b) by knowingly permitting its name to 

7 be used to effect contributions in the name of another. 

8 II. FACTUAL BACKGROUND

9 A. Jeff Pitts of Matrix Appears to Have Created a Plan to Anonymize Federal 

10 Political Contributions Using a Network of Conduits Controlled by or 

11 Associated with Pitts or Matrix 

Matrix is a “strategic communications firm” based in Alabama.11 12 According to the 

13 Orlando Sentinel, it received a cache of internal documents from Matrix, “includ[ing] checks, 

14 bank statements, emails, text messages, invoices, internal ledgers and more, all apparently 

15 unearthed during an internal investigation Matrix launched after its former employees left the 

firm at the end of 2020.”12 16 These internal records included a copy of a November 26, 2019 

17 email sent from former Matrix CEO, Jeff Pitts, to former FPL CEO, Eric Silagy, stating, 

18 “‘Attached is an updated funding memo along with a separate legal memo on federal elections 

support.’”13 19 The “funding memo” noted goals such as making “federal campaign contributions” 

Daniel Martell that Anderson was an old friend of his and that Pitts was in control of the nonprofits run by 

Anderson).

11 Matrix, LLC, v. Canopy Partners, LLC, et al, 2021 WL 3127729 (Ala. Cir. Ct.).

12 Jason Garcia & Annie Martin, Operative Pitched Secretive Political Spending Plan to FPL Exec’s Email 

Alias, Records Reveal, ORLANDO SENTINEL (Jan. 24, 2022), https://www.orlandosentinel.com/politics/os-ne-floridapower-and-light-matrix-dark-money-20211217-v64274eytjeb5hnstdognvqds4-story.html [hereinafter “Secretive 

Political Spending Plan”]. 

13 Id.; see also Compl. ¶¶ 3, 31-38.

Attachment 6 

Page 3 of 33

MUR808200449
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 4 of 33

and “‘minimiz[ing] all public reporting of entities and activities.’”14 1 It also included a flowchart

2 depicting money flowing from FPL through a network of conduits before being contributed to 

federal and state political committees, as reproduced below:15 3 

14 See Secretive Political Spending Plan, supra note 12; Compl. ¶ 32.

15 See Secretive Political Spending Plan, supra note 12; Compl. ¶ 33 Fig. 1.

Attachment 6 

Page 4 of 33

MUR808200450
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 5 of 33

1 Notably, next to or below the name of each conduit is a parenthetical, which may indicate the 

2 person or entity controlling or associating with that conduit. Specifically, the flowchart 

3 identifies a “LPAD C4 (Tyson),” which appears to refer to LPAD and its executive director Ryan 

Tyson.16 4 The flowchart also identifies “Matrix/Foley” in a parenthetical next to or below the 

16 See Compl. ¶ 35.

Attachment 6 

Page 5 of 33

MUR808200451
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 6 of 33

1 names of the following conduits: “Broken Promises,” “Florida Promise C4,” “US Promise C4,” 

2 and “Fed Promise C4,” suggesting that these conduits are directly associated with and/or 

controlled by Matrix and its legal counsel, Foley and Lardner, LLP (“Foley”).17 3 

4 According to the flowchart, money could flow to a “Florida Promise C4,” which could 

5 “spend 50% of revenues on political activities” due to its tax status as a section 501(c)(4) 

6 corporation, and be used to contribute to Florida state political committees on the basis that 

“Florida PCs are allowed to take unlimited funds from C4s.”18 7 Money could also flow to a “US 

8 Promise C4,” which similarly could “spend 50% of revenues on political activities” due to its tax 

9 status, and be used to contribute to other states’ political committees on the basis that “[e]ach 

state operates under unique state elections.”19 10 Lastly, the flowchart indicates that money could 

11 flow to a “Fed Promise C4,” but because Matrix was “[w]aiting on lawyers,” it could not state

the purpose of this proposed funding.20 12 

13 The legal memo attached to the email, which was drafted by Foley attorney Erika Alba, 

addressed “the legalities of using nonprofits to spend money on federal elections.”21 14 The memo 

15 states that “a nonprofit might have to disclose its donors if it spent money directly supporting a 

16 candidate,” but that “the nonprofit would not have to disclose its donors if it gave money to a 

17 type of political committee known as a “‘Super PAC’” (i.e., an IEOPC) “that then spent money 

supporting the candidate.”22 18 The legal memo then concluded: “‘Thus, it could be strategic for a 

17 See Secretive Political Spending Plan, supra note 12 (noting that Erika Alba of Foley & Lardner LLP 

drafted a legal memo attached to the email); see also Compl. ¶ 38 (alleging the same). 

18 Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 33 Fig. 1, 37.

19 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

20 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

21 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 38.

22 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 38.

Attachment 6 

Page 6 of 33

MUR808200452
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 7 of 33

[nonprofit] who wishes to make Independent Expenditures to do so via a Super PAC.’”23 1 

2 Based on the record of contributions disclosed by the recipient IEOPCs and news articles 

3 reporting that LPAD provided funding to Grow United and Broken Promises, the Complaint 

depicts the implementation of the Matrix plan as taking the following altered form:24 4 

5 

6 The Complaint alleges that Matrix pitched the above-referenced plan to Unknown 

7 Respondent clients, noting that FPL’s spokesperson, David Reuter, stated, “‘We are aware of the 

8 proposed structure as the legal memo was shared with us, and as we understand it, Joe 

23 Secretive Political Spending Plan, supra note 12 (alteration in original); see also Compl. ¶ 38.

24 Compl. ¶¶ 42 Fig. 2, 45, 52.

Attachment 6 

Page 7 of 33

MUR808200453
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 8 of 33

1 Perkins’[s] team at Matrix created a proposal to fund their clients’ communication and outreach 

activities during 2020.’”25 2 

3 B. The Alleged Conduit Corporations Appear to Have Been Controlled by or 

4 Associated with Pitts and/or Matrix 

5 The Complaint alleges that five alleged Conduit Corporations, Florida Promise, CAIJ, 

6 Grow United, Broken Promises, and Stand Up for Justice, permitted their names to effect the 

7 $1.27 million in contributions that they purportedly made to IEOPCs on behalf of Unknown 

Respondents.26 8 Richard Alexander served as a director or officer of the first three alleged 

9 Conduit Corporations, while Sean J. Anderson was a director or officer of the latter two. 

10 According to news reports, both Alexander and Anderson had close ties to Matrix. 

11 Alexander’s sister, April Odom, was a Matrix contractor at the time of the allegations and 

12 reportedly worked on behalf of Matrix regarding CAIJ and Grow United, which were entities 

associated with Alexander.

27 13 Anderson, on the other hand, was a former Matrix employee, and 

reportedly a close friend of Pitts. 28 14 Anderson also has a history of working with Pitts, as Pitts 

15 reportedly texted FPL Vice President Daniel Martell in 2016, four years prior to the alleged 

16 contributions, as follows: “‘Bottom line is we are the ones with the check books and in control 

100 percent’” of the nonprofits purportedly run by Anderson.29 17 The discussion below sets out 

18 the available information about each of the alleged Conduit Corporations and their relationships 

19 with Pitts and/or Matrix.

25 Secretive Political Spending Plan, supra note 12 (emphasis added); Compl. ¶ 40 (emphasis added). 

26 Compl. ¶¶ 5, 43-54.

27 Dark Money Playbook, supra note 7 (reporting that April Odom is Anderson’s sister and was a former 

Matrix employee); see also Compl. ¶¶ 13, 48.

28 Bachelor Party, supra note 10; Nightmare Scenario, supra note 10 (reporting that Pitts texted FPL Vice 

President Martell that Anderson was an old friend of his); see also Compl. ¶ 16.

29 Nightmare Scenario, supra note 10; see also Compl. ¶ 16. 

Attachment 6 

Page 8 of 33

MUR808200454
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 9 of 33

1 1. Florida Promise, Inc. 

2 Florida Promise is a corporation identified in Matrix’s proposal to FPL that could be used 

as a conduit to make contributions to Florida political committees,

30 3 and it was incorporated on 

December 18, 2018.31 4 According to Florida Promise’s 2018 federal tax return, it is a 501(c)(4) 

5 corporation; its mission is to “develop and advocate for legislation, regulations, and government 

6 programs related to policies to benefit Floridians”; Alexander was its chairman; it did not have a 

website; and it did not have any expenses or revenue that year.32 7 

8 On December 8, 2020, Florida Promise made a $1,000,000 contribution to the Senate 

Leadership Fund.33 9 In addition, consistent with Matrix’s proposal to use Florida Promise to

10 make Florida political contributions, Florida Promise also made contributions to Florida political 

committees on June 12, 2019, and January 27, 2021, totaling $230,000.34 11 Other than making the 

12 $1,230,000 in federal and Florida state political contributions, there is no publicly available 

13 information regarding Florida Promise’s activities. 

30 See Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 33 Fig. 1, 50. 

31 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Florida Promise”); see also Compl. ¶ 12.

32 IRS Form 990-EZ, Florida Promise, Inc., 2018 Short Form Return of Organization Exempt from Income 

Tax at 2-3, 6 (Nov. 13, 2019), https://apps.irs.gov/pub/epostcard/cor/832961305_201812_990EO_202006011716

8825.pdf [hereinafter Florida Promise 2018 Tax Return]. 

33 Senate Leadership Fund, Amended 2020 Year End Report at 72 (Mar. 18, 2021), https://docquery.fec.gov/

pdf/807/202103189441299807/202103189441299807.pdf; see also Compl. ¶ 49. 

34 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (searching “all” election years with contributor’s last name 

starting with “Florida Promise”); see also Compl. ¶ 50.

Attachment 6 

Page 9 of 33

MUR808200455
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 10 of 33

1 2. Center for Advancement of Integrity and Justice, Inc. 

CAIJ was incorporated on October 1, 2018,35 2 and shared a mailing address with Stand Up 

for Justice.36 There are no publicly available CAIJ federal tax returns.37 3 Alexander served as 

4 either a director or officer of CAIJ.

On October 27, 2020, CAIJ made a $100,000 contribution to American Valor PAC,38 5 an 

6 IEOPC that made independent expenditures during the 2020 election cycle solely in Florida’s

7 13th Congressional District, which supported Anna Paulina Luna, the Republican nominee, and 

opposed Charlie Joseph Crist, the Democratic nominee.39 8 CAIJ also made contributions to 

9 Florida political committees totaling $307,000, starting in November 2018 and through 

December 2020.

40 10 

35 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Center for Advancement of Integrity and 

Justice”); see also Compl. ¶ 11.

36 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting that CAIJ’s address was at 2020 Pennsylvania Avenue, 

NW, Ste. 449, Washington DC 20006); CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing

(last visited Sept. 25, 2023) (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for 

Justice’s business address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006). 

37 On May 15, 2021, the IRS automatically revoked CAIJ’s 501(c)(4) status for not filing a Form 990s-series 

return for three consecutive years, suggesting that CAIJ has not filed any tax returns. See Tax Exempt Organization 

Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited July 25, 2023) (searching the organization name “center 

for advancement of integrity” which reflect that CAIJ’s federal tax exempt status was automatically revoked on May 

15, 2021for not filing a Form 990-series return or notice for three consecutive years).

38 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf; see also Compl. ¶ 47. 

39 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00757179&is_notice=false&most_recent=true (last visited 

Aug. 18, 2023) (reflecting independent expenditures made by American Valor PAC); November 3, 2020 General 

Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=

11/3/2020&DATAMODE= (last visited Sept. 25, 2023) (selecting “Federal Offices”) (reflecting that Anna Luna 

was the Republican nominee and that Charlie Crist was the Democratic nominee in Florida’s 13th Congressional 

District).

40 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited July 25, 2023) (searching “all” election years with contributor’s last name starting 

with “center for advancement”).

Attachment 6 

Page 10 of 33

MUR808200456
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 11 of 33

1 While CAIJ was not referenced by name in Matrix’s proposal to FPL, news reports 

2 suggest that it was controlled by Matrix. Specifically, Matrix’s internal files reportedly include a 

3 September 23, 2020 text message from Odom, Alexander’s sister and a Matrix contractor at the 

time of the allegations, stating that she procured access to CAIJ’s bank account.41 4 In addition, 

5 on October 16, 2018, just 15 days after CAIJ’s incorporation, CAIJ made a $25,000 contribution 

to House Majority PAC.42 6 According to news reports, FPL directed Matrix to make this 

7 contribution on its behalf to support Lauren Baer, who was seeking election in Florida’s 18th 

8 Congressional District, and asked Matrix to ensure that House Majority PAC “‘do[es]n’t 

triangulate this donation to others we have done.’”43 9 Other than making the $432,000 in federal 

10 and Florida state political contributions, there is no publicly available information regarding 

11 CAIJ’s activities. 

41 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right-hand corner 

of the article’s sixth picture); see also Compl. ¶ 48.

42 House Majority PAC, 2018 Amended 12-Day Pre-Election Report at 655 (Dec. 3, 2018), https://docquery

.fec.gov/pdf/085/201812069135107085/201812069135107085.pdf. 

43 Jason Garcia & Annie Martin, Florida Power & Light Execs Worked Closely with Consultants Behind 

‘Ghost’ Candidate Scheme, Records Reveal, ORLANDO SENTINEL (Apr. 14, 2022), https://www.orlandosentinel.com/

politics/os-ne-florida-power-and-light-senate-ghost-candidates-20211202-szjhv7ox6vcmphm6pgd437y52i-htmlstory

.html [hereinafter “FPL Execs”] (reporting that Silagy forwarded Pitts instructions to make a contribution to House 

Majority PAC to support Lauren Baer and to make sure that “they don’t triangulate this donation to others we have 

done”); November 6, 2018 General Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.my

florida.com/Index.asp?ElectionDate=11/6/2018&DATAMODE= (last visited Sept. 25, 2023) (reflecting that Lauren 

Baer was the democratic nominee in Florida’s 18th Congressional District). 

Attachment 6 

Page 11 of 33

MUR808200457
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 12 of 33

1 3. Grow United, Inc. 

Grow United was incorporated on July 24, 2019.44 2 There are no publicly available Grow 

3 United federal tax records and it did not identify itself as a nonprofit organization to the Internal 

Revenue Service.

45 4 Alexander served either as a director or officer of Grow United. 

On October 27, 2020, Grow United made a $100,000 contribution to Wingman PAC,46 5 

now known as the Conservative Action Fund.47 6 Wingman PAC made independent expenditures 

7 during the 2020 election cycle solely in Florida’s 15th Congressional District, which supported 

8 Scott Franklin, the Republican nominee; opposed Alan Michael Cohn, the Democratic nominee; 

9 and opposed Vincent Spano Ross, who competed against Franklin for the Republican 

44 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “Grow United”). 

45 See Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited Sept. 25, 2023)

(reflecting that there are no results when searching Grow United’s name or its EIN number identified in the 

Complaint, 84-2546999). 

46 Wingman PAC, 2020 30-Day Post Election Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/423/

202012039338666423/202012039338666423.pdf (reflecting a $100,000 contribution from Grow United on October 

27, 2020).

47 Id. at 1(reflecting an FEC identification number of C00742296); Conservative Action Fund, Amended 

Statement of Organization at 1 (May 20, 2022), https://docquery.fec.gov/pdf/048/202205209512421048/2022

05209512421048.pdf (reflecting that its name has changed to Conservative Action Fund and its FEC identification 

number is C00742296). 

Attachment 6 

Page 12 of 33

MUR808200458
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 13 of 33

nomination.48 1 Earlier that month, from October 3, 2020, through October 20, 2020, Grow 

United made contributions to Florida state political committees totaling $1,462,500.49 2 

3 Grow United appears to have been created and controlled by Pitts and Matrix. Ryan 

4 Tyson, the executive director of LPAD — which contributed $1,150,000 to Grow United in 

202050 5 — was deposed by the Miami-Dade State Attorney’s Office in a criminal matter 

6 regarding a former LPAD contractor’s creation of fake Florida state senate candidates during the 

7 2020 election cycle. Tyson testified in the deposition that he understood that Jeff Pitts started 

8 and ran Grow United. In addition, FPL reportedly asserted that Grow United was created by 

Matrix.51 9 

10 Matrix’s internal records also reportedly indicate that it had control of Grow United. 

11 According to news reports, Matrix’s internal ledger reflect an August 7, 2019 entry billed to FPL 

12 for “‘Grow United SOS Fees,’” which likely referred to the fees charged by the Delaware 

48 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00742296&is_notice=false&min_date=01%2F01%2F2019&max

_date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting Wingman PAC’s independent expenditures in the 

2020 election cycle); November 3, 2020 General Election, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results

.elections.myflorida.com/Index.asp?ElectionDate=11/3/2020&DATAMODE= (last visited Sept. 25, 2023) 

(selecting “Federal Offices”) (reflecting that Scott Franklin was the Republican nominee and Alan Cohn was the 

Democratic nominee in Florida’s 15th Congressional District); August 18, 2020 Primary Election Republican 

Primary, FL DEP’T OF STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate

=8/18/2020&DATAMODE= (last visited Sept. 25, 2023) (selecting “Federal Offices” in the Republican Primary 

section) (reflecting that both Scott Franklin and Ross Spano were seeking the Republican nomination in Florida’s 

15th Congressional District).

49 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (selecting election year “all” and searching contributor last name 

starting with “grow united”); see also Compl. ¶ 46.

50 See Compl. ¶ 45.

51 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Dec. 10, 2021, updated Sept. 2, 

2022), https://www.jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-citycouncil-member-mysterious-job-offer-dark-money-group-nate-monroe/8850689002/. Joe Perkins, owner of Matrix, 

denies that Matrix created Grow United, and Perkins’s attorney asserts that “[t]o the extent any rogue Matrix 

employees were involved in those activities, they were undertaken in secret, without Dr. Perkins’[s] knowledge or 

consent.” Id.

Attachment 6 

Page 13 of 33

MUR808200459
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 14 of 33

Secretary of State for incorporating Grow United a few weeks prior.

52 1 Matrix’s internal records 

2 also reportedly include a September 23, 2020 message from Odom stating that she procured 

access to Grow United’s bank account.53 3 In addition, as part of her duties at Matrix, Odom 

4 reportedly sent checks from Grow United to make contributions to Florida committees, asked the 

committees to confirm their receipt of the checks,54 5 and emailed a $12,813.54 invoice to Matrix

6 with the subject line, “FPL Expenses for Grow United c4,” for expenses that included traveling 

to Colorado to update the nonprofit’s mailbox at a UPS Store in Denver.55 7 

8 News articles also report that, in the summer of 2019, Matrix used Grow United to offer a 

job to a Jacksonville City Councilmember on behalf of FPL.56 9 Furthermore, Foley attorney 

10 Erika Alba reportedly billed Matrix in the fall of 2020 for her work on IRS submission forms for 

Grow United.57 11 Other than making the $1,562,500 in political contributions, there is no publicly 

12 available information regarding Grow United’s activities.

52 FPL Execs, supra note 43. 

53 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right corner of the 

article’s sixth picture); see also Compl. ¶ 48.

54 Dark Money Playbook, supra note 7. 

55 FPL Execs, supra note 43. 

56 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/. FPL reportedly confirmed that Matrix 

employees came up with an idea to offer the City Council member a job, but that it rejected the idea. Id. 

57 Nate Monroe, Law Firm that Advised on Botched JEA Sale Also Helped Former FPL Consultants On 

Dark-Money Projects, FL TIMES-UNION (Dec. 17, 2021), https://www.jacksonville.com/story/news/columns/natemonroe/2021/12/17/jea-privatization-law-firm-foley-lardner-also-helped-former-fpl-consultants-political-giving/

8850686002/. There are no publicly available tax forms from Grow United, Inc., however. See Tax Exempt 

Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited Sept. 25, 2023) (reflecting that there are no 

results when searching Grow United’s name or its EIN number identified in the Complaint, 84-2546999).

Attachment 6 

Page 14 of 33

MUR808200460
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 15 of 33

1 4. Broken Promises 

2 Broken Promises is referenced by name in Matrix’s proposal to FPL as a middleman that 

3 would receive funds and send them to conduits, including Florida Promise, that would in turn 

make political contributions.58 4 Broken Promises was incorporated on August 29, 2018, along 

with Stand Up for Justice.59 5 According to Broken Promises’s federal tax return for the 2018 

6 calendar year, it is a 501(c)(4) corporation; its purpose is to “develop[] and advocat[e] for 

7 legislation, regulations, and government programs to improve social environmental, economy 

8 and social environment”; Sean J. Anderson is its president and chairman; it did not have a 

website; and it received $200,000 of funding that year.60 9 In addition, according to news reports, 

Broken Promises reportedly received $26,000 from LPAD on July 9, 2020.61 10 

11 On July 14, 2020, five days after reportedly receiving the $26,000 from LPAD, Broken 

Promises made a $20,000 contribution to Concerned Conservatives, Inc., an IEOPC.62 12 During 

13 the 2020 election cycle, Concerned Conservatives, Inc., made independent expenditures only in 

14 Florida’s 19th Congressional District to support Dane Eagle, who unsuccessfully ran for the 

15 Republican nomination, and oppose his competitors, William Matthew Figlesthaler, Byron 

58 See Secretive Political Spending Plan, supra note 12; Compl. ¶¶ 33 Fig. 1, 52. 

59 CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023)

(searching the organization name “Broken Promises” and “Stand Up for Justice”).

60 See IRS Form 990, Broken Promises, 2018 Return of Organization Exempt from Income Tax at 1, 7 

(Nov. 15, 2019), https://apps.irs.gov/pub/epostcard/cor/831745117_201812_990O_2020012317057600.pdf

[hereinafter Broken Promises 2018 Tax Return] (reflecting an unfilled line for the organization’s website).

61 Jeff Weiner & Annie Martin, Bank Records Shed Light on Dark-Money Group in ‘Ghost’ Candidate 

Scandal, ORLANDO SENTINEL (Apr. 18, 2022), https://www.orlandosentinel.com/2022/04/18/bank-records-shedlight-on-dark-money-group-in-ghost-candidate-scandal/; see Compl. ¶ 52.

62 Concerned Conservatives, Inc., 2020 12-Day Pre-Primary Election Report at 6 (Aug. 6, 2020), 

https://docquery.fec.gov/pdf/823/202008069261263823/202008069261263823.pdf; see also Compl. ¶ 51.

Attachment 6 

Page 15 of 33

MUR808200461
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 16 of 33

Donalds, and Casey Askar.63 1 In addition, in 2018, Broken Promises made $160,470 in Florida 

2 state political contributions, and in 2019, it made $21,500 in Florida state political 

contributions.64 3 Thus, it appears that Broken Promises made at least $201,970 in political 

4 contributions during its existence. 

5 According to Broken Promises’s federal tax returns and other information received by the 

6 Commission, it received a total of $226,000 to $300,000 in funding during its existence: 

$200,000 in 2018,65 7 $50,000 or less in 2019, and $26,000 to $50,000 in 2020 before terminating 

later that year.

66 8 Broken Promises’s 2018 federal tax return also indicates that it spent $500 on 

legal expenses and $40 on management and general expenses that year.67 9 Although Broken 

10 Promises characterized spending $45,000 on lobbying and $115,470 on “other” program 

11 expenses in its 2018 federal tax return, this sum of $160,470 corresponds precisely to the dollar 

with its 2018 Florida state political contributions also totaling $160,470.68 12 Thus, Broken 

13 Promises spent at least 67% to 89% of its total funding on making political contributions.

63 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data type=processed&q spender=C00728402&is notice=false&min date=01%2F01%2F2019&max

date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting Concerned Conservatives, Inc.’s, independent 

expenditures during the 2020 election cycle); August 18, 2020 Primary Election Republican Primary, FL DEP’T OF 

STATE DIV. OF ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=8/18/2020&DATA

MODE= (last visited Sept. 25, 2023) (selecting “Federal Offices” in the Republican Primary section) (reflecting that 

Dane Eagle, William Figlesthaler, Byron Donalds, and Casey Askgar were seeking the Republican nomination in 

Florida’s 19th Congressional District).

64 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and contributor last name “Broken 

Promises”).

65 Broken Promises 2018 Tax Return at 1, supra note 60. 

66 For 2019 and 2020, Broken Promises filed an IRS Form 990-N, indicating that its gross receipts were 

$50,000 or less in those years. Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/eos/ (last visited 

Sept. 25, 2023) (searching organization name “Broken Promises”). 

67 Broken Promises 2018 Tax Return at 10, supra note 60. 

68 Id.; see also Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/

campaign-finance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and contributor last name 

“Broken Promises”) (reflecting that Broken Promises made $160,470 in Florida state political contributions in 2018, 

Attachment 6 

Page 16 of 33

MUR808200462
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 17 of 33

1 According to the Miami Herald, Broken Promises’s entire $200,000 of funding in 2018 

was from FPL.69 2 Specifically, the Miami Herald claims it received an internal Matrix ledger 

3 showing how, in 2018, Matrix distributed $200,000 of funds labeled as coming from FPL to 

Broken Promises.70 4 The ledger reportedly shows that Matrix sent $100,000 of FPL funds to 

Broken Promises on September 26, 2018, and again on October 16, 2018, totaling $200,000.71 5 

6 This money was likely transmitted through other Matrix-controlled corporations before coming 

7 to Broken Promises, because federal tax records show that the Alliance for Consumer Protection 

Inc., donated $100,000 to Broken Promises in 2018.72 8 According to a news report regarding a 

9 text message between Pitts and FPL Vice President Martell, the director of the Alliance for 

Consumer Protection Inc., David Calvert, is Pitts’s former college roommate.

73 10 

11 5. Stand Up for Justice 

As discussed above, Stand Up for Justice was incorporated on August 29, 2018,74 12 the 

same day as Broken Promises, and it shared a mailing address with CAIJ.

75 13 According to its 

of which $45,000 were cash contributions and $115,470 were in-kind contributions in the forms of direct mail and 

advertising).

69 Nicholas Nehamas & Mary Ellen Klas, DeSantis ’18 Campaign Got $25,000 From Nonprofit Secretly 

Funded by FPL Cash, Records Show, MIAMI HERALD (Sept. 9, 2022), https://www.miamiherald.com/news/politicsgovernment/state-politics/article265213541.html. 

70 Id. FPL spokesperson Reuter called the ledger “fake” and stated, “We have no record of FPL, or any 

NextEra Energy entity for that matter, ever having paid Broken Promises.” Id

71 Nightmare Scenario, supra note 10; see also Nicholas Nehamas & Mary Ellen Klas, DeSantis ’18 

Campaign Got $25,000 From Nonprofit Secretly Funded by FPL Cash, Records Show, MIAMI HERALD (Sept. 9, 

2022), https://www.miamiherald.com/news/politics-government/state-politics/article265213541.html. 

72 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095 201812 990O 20211020

19109756.pdf. 

73 Nightmare Scenario, supra note 10. 

74 CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023) 

(searching the organization names “Stand Up for Justice” and “Broken Promises”). 

75 Id. (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for Justice’s business 

address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006); American Valor PAC, 2020 

Attachment 6 

Page 17 of 33

MUR808200463
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 18 of 33

1 2018 federal tax return, Stand Up for Justice is a 501(c)(4) corporation; its purpose is to 

2 “develop[] and advocat[e] for legistlation [sic], regulations and government programs to improve 

3 social environment, economy & society”; Anderson was a director and its president; it did not 

have a website; and it received $350,000 in funding that year.76 4 

5 On March 31, 2020, Stand Up for Justice made a $50,000 contribution to South Florida 

Residents First,

77 6 an IEOPC that made independent expenditures during the 2020 election cycle 

7 only in Florida’s 26th Congressional District, which supported Republican nominee Carlos 

Gimenez and opposed Democratic nominee Debbie Mucarsel-Powell.78 8 In addition, just two 

9 months after it was incorporated, Stand Up for Justice made contributions to a Florida political 

committee in October 2018, totaling $300,000,79 10 which Stand Up for Justice characterized as 

“lobbying” on its 2018 federal tax return.80 11 Thus, it appears that Stand Up for Justice made at 

12 least $350,000 in political contributions during its existence. 

Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/202012039337569242/20201203

9337569242.pdf (reflecting that CAIJ’s address is at 2020 Pennsylvania Avenue, NW, Ste. 449, Washington DC 

20006). 

76 IRS Form 990, Stand Up for Justice, 2018 Return of Organization Exempt from Income Tax at 1-2, 7 

(Nov. 15, 2019), https://apps.irs.gov/pub/epostcard/cor/831749759_201812_990O_2020021317141891.pdf

[hereinafter Stand Up for Justice 2018 Tax Return]. 

77 South Florida Residents First, 2020 April Quarterly Report at 11 (April 13, 2020), https://docquery.fec

.gov/pdf/294/202004159216942294/202004159216942294.pdf; see also Compl. ¶ 53.

78 FEC Independent Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independentexpenditures/?data_type=processed&q_spender=C00733402&is_notice=false&min_date=01%2F01%2F2019&max

_date=12%2F31%2F2020 (last visited Sept. 25, 2023) (reflecting South Florida Residents First’s independent 

expenditures in the 2020 election cycle); November 3, 2020 General Election, FL DEP’T OF STATE DIV. OF 

ELECTIONS, https://results.elections.myflorida.com/Index.asp?ElectionDate=11/3/2020&DATAMODE= (last visited 

Sept. 25, 2023) (selecting “Federal Offices”) (reflecting that Carlos Gimenez was the Republican nominee and

Debbie Mucarsel-Powell was the Democratic nominee in Florida’s 26th Congressional District); see Compl. ¶ 53. 

79 Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.myflorida.com/campaignfinance/contributions/ (last visited July 25, 2023) (searching election year “all” and contributor last name starting 

with “Stand Up for Justice”).

80 Stand Up for Justice 2018 Tax Return at 10, supra note 76. 

Attachment 6 

Page 18 of 33

MUR808200464
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 19 of 33

1 According to Stand Up for Justice’s federal tax returns, it received $350,000 to $450,000 

during its existence: $350,000 in 2018,81 2 and $50,000 or less per year in each of 2019 and 2020 

before terminating.82 3 Stand Up for Justice’s federal tax returns also state that it spent $20,577 on 

legal fees and $100 on bank service charges in 2018,83 4 indicating that its total funding was at 

5 least $370,677 to cover its lifetime spending. Thus, Stand Up for Justice spent at least 78% to 

6 94% of its total funding on making political contributions.

7 Federal tax records show that Alliance for Consumer Protection Inc., contributed 

$150,000 to Stand Up for Justice in 2018.84 8 As indicated above, the Alliance for Consumer 

9 Protection Inc. also contributed $100,000 to Broken Promises in 2018, and its executive director 

is reportedly Pitts’s former college roommate.

85 10 

11 C. Let’s Preserve the American Dream, Inc., was Associated with Pitts and 

12 Matrix

13 Relying on news reports of Matrix’s proposal to FPL, which reference LPAD as a higher14 level Matrix-associated conduit that would receive funds and transmit them to other entities in 

15 Matrix’s network, and news reports indicating that LPAD made donations to Grow United and 

16 Broken Promises, the Complaint alleges that Unknown Respondents used LPAD as a middleman 

to make contributions using the names of Grow United and Broken Promises.86 17 

81 Id. at 1.

82 For 2019 and 2020, Stand Up for Justice filed an IRS Form 990-N, and indicated that its gross receipts 

were not greater than $50,000 in those years. Tax Exempt Organization Search, IRS.GOV, https://apps.irs.gov/app/

eos/ (last visited Sept. 25, 2023) (searching organization name “Stand Up for Justice”).

83 Stand Up for Justice 2018 Tax Return at 10, supra note 76. 

84 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095_201812_990O_20211020

19109756.pdf. 

85 Id.; Nightmare Scenario, supra note 10. 

86 Compl. ¶¶ 33 Fig. 1, 35, 37, 42 Fig. 2, 45, 52; see also Secretive Political Spending Plan, supra note 12. 

Attachment 6 

Page 19 of 33

MUR808200465
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 20 of 33

1 In a deposition conducted by the Miami-Dade State Attorney’s Office regarding a former 

2 LPAD contractor’s creation of fake Florida state senate candidates, Tyson stated that he 

3 discussed LPAD’s donation to Grow United with Matrix’s former CEO, Jeff Pitts, and that it was 

4 actually Pitts who proposed for LPAD to make that donation. Specifically, Tyson testified: 

5 Well, as best as I can recall, I called [Pitts] up and I said, “Do you 

6 have any social welfare groups that are interested in working on 

7 issues that are amenable to my organizational narrative? Are they 

8 interested in supporting other interests in other committees around 

9 the country, in Florida specifically too, that would focus purely on 

the center left spectrum and on issues that are center left?”87 10 

11 According to Tyson, Pitts “said he did,” referring to Grow United, and so Tyson “said we’d be 

12 happy to support them.” 

13 In the same above-referenced deposition, Tyson also testified that he spoke with Pitts 

14 about how Grow United should use LPAD’s donation. Specifically, in response to whether 

15 Tyson knew that Alex Alvarado’s Florida state political committees received their funding from 

16 Grow United, Tyson stated, “I told you earlier I knew it came from Grow United. There was a 

17 story about it. And I knew, I actually told Grow United that Alvarado would probably call them 

and ask, raise money.”88 18 Tyson further explained that the person he spoke with was Jeff Pitts. 

19 According to text messages obtained by the Orlando Sentinel, on September 24, 2020, just five 

20 days prior to LPAD making its first $600,000 donation to Grow United on September 29, 2020, 

21 Tyson communicated with Pitts and Abigail MacIver, another former Matrix employee, 

regarding the Florida state senate races that the Alvarado committees were seeking to impact.89 22 

87 Tyson testified in response to the question, “So give me your best recollection of the content of the 

conversation that you had with Jeff Pitts that caused you to want to send the money to Grow United.”

88 Emphasis was added to the original transcription.

89 FPL Execs, supra note 43. 

Attachment 6 

Page 20 of 33

MUR808200466
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 21 of 33

1 When further queried as to whether Tyson “did not authorize the money, the $600,000 

2 [from LPAD], to go to Grow United so they can then turn around and send it to Alex Alvarado’s 

3 two political campaigns,” Tyson testified that he “can’t tell [Grow United] how to spend their 

4 money” and that he “do[es]n’t have the ability to restrain how they spend their funds.” However, 

5 when asked, “Did you know when this $600,000 [from LPAD] was sent to Grow United, that it 

6 was going to [⸺] that 550,000 of it was going to go to Alex Alvarado’s two political 

7 committees,” Tyson testified that he “had a hunch” that Grow United would be supportive of the 

8 Alvarado committees and that he was “not testifying it’s a coincidence.” Tyson further stated, “I 

9 knew [Grow United] would likely be supportive, but I also didn’t know when, I mean, we made 

10 other contributions to them as well. We were supporting a lot of what they were doing.” Tyson 

11 then testified that he “assume[d] [Grow United would] probably be supported [sic] if Alex 

12 called, but I had no way to know if they actually would. Because once I make a contribution to 

13 an entity, I lose control of how they spend that money.” 

14 D. SUN Marketing & Advertising LLC Appears to be Associated with Matrix

15 SUN Marketing & Advertising LLC is another conduit identified in Matrix’s proposal to 

FPL,

90 16 and it appears to have been created by Matrix after the memo was circulated. 

17 Specifically, SUN was formed on December 13, 2019, about two weeks after Pitts reportedly 

emailed the above-referenced proposal to Silagy on November 26, 2019.91 18 FPL spokesman 

19 Reuter reportedly confirmed that FPL gave $250,000 to SUN in December 2019, but stated that 

20 the purpose was to purchase advertising related to a proposed constitutional amendment that FPL 

90 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 32 Fig. 1.

91 Division of Corporations, DEL. SEC’Y OF STATE, https://icis.corp.delaware.gov/Ecorp/EntitySearch/

NameSearch.aspx (last visited Sept. 25, 2023) (searching the entity name “SUN Marketing & Advertising”). 

Attachment 6 

Page 21 of 33

MUR808200467
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 22 of 33

opposed.92 According to Reuter, FPL believes that SUN is owned by Matrix.93 1 News reports 

indicate that SUN was used to create favorable press for FPL.94 2 SUN’s former sole member, 

Tim Fitzpatrick, was a former FPL officer.95 3 

4 III. LEGAL ANALYSIS

5 A. The Commission Finds Reason to Believe that the $50,000 Contribution 

6 Reported as Having Been Made by Stand Up for Justice Was a Contribution 

7 Made In the Name of Another

8 The Act and the Commission’s regulations prohibit a person from (1) making a 

9 contribution in the name of another person, (2) knowingly permitting his or her name to be used 

to effect such a contribution, and (3) knowingly accepting such a contribution.96 10 The term 

11 “person” in this context includes partnerships, corporations, and “any other organization or group 

of persons.”97 12 In its regulations, the Commission has illustrated examples of activities that 

13 constitute making a contribution in the name of another, as follows: 

14 (i) Giving money or anything of value, all or part of which was 

15 provided to the contributor by another person (the true contributor) 

16 without disclosing the source of money or the thing of value to the 

17 recipient candidate or committee at the time the contribution is 

18 made; or

92 Secretive Political Spending Plan, supra note 12. 

93 Id.

94 Sarah Blaskey, Powerbrokers: How FPL Secretly Took Over a Florida News Site and Used It to Bash 

Critics, MIAMI HERALD (Aug. 13, 2022), https://www.miamiherald.com/article263757423.html. 

95 PG&E Names Tim Fitzpatrick As Vice President And Chief Communications Officer, CISION PR

NEWSWIRE (Mar. 11, 2013), https://www.prnewswire.com/news-releases/pge-names-tim-fitzpatrick-as-vicepresident-and-chief-communications-officer-197098061.html (“Fitzpatrick joined NextEra Energy in January 2008, 

serving as Vice President of Marketing and Corporate Communications and as an officer of Florida Power & Light 

Company (FPL).”).

96 52 U.S.C. § 30122; see also 11 C.F.R. § 110.4(b).

97 52 U.S.C. § 30101(11); 11 C.F.R. § 100.10.

Attachment 6 

Page 22 of 33

MUR808200468
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 23 of 33

1 (ii) Making a contribution of money or anything of value and 

2 attributing as the source of the money or thing of value another 

person when in fact the contributor is the source.98 3 

4 Because a primary purpose of the Act’s disclosure provisions is to reveal the true source from 

5 which a contribution to a candidate or committee originates, regardless of the mechanism by 

which the funds are transmitted,99 6 the Commission examines the structure of the transaction 

7 itself and the arrangement between the parties to determine who in fact “made” a given 

contribution.100 8 

9 In prior matters, the Commission has found reason to believe that a contribution was 

10 made in the name of another where the available information indicates that another person 

11 provided the funds for the purpose of making the contribution and his or her identity was not 

disclosed to the recipient committee or candidate at the time of the contribution.

101 12 Absent direct 

13 evidence as to the purpose of providing the funds, the Commission considers the overall record

14 to determine its purpose. In the context of contributions made by limited liability companies 

15 (“LLCs”), the Commission has addressed whether the LLC “had the means to make the 

16 contribution absent an infusion of funds provided for that purpose,” the “temporal proximity 

98 11 C.F.R. § 110.4(b)(2)(i)-(ii).

99 See Campaign Legal Ctr. v. FEC, 952 F.3d 352, 354 (D.C. Cir. 2020) (“As the Supreme Court has 

repeatedly declared, the electorate has an interest in knowing where political campaign money comes from and how 

it is spent by the candidate. To that end, the [Act] imposes disclosure requirements on those who give and spend 

money to influence elections. The straw donor provision, 52 U.S.C. § 30122, is designed to ensure accurate 

disclosure of contributor information.”) (internal citations and quotation marks omitted). 

100 Cf. 11 C.F.R. § 110.6(a) (“All contributions by a person made on behalf of or to a candidate, including 

contributions which are in any way earmarked or otherwise directed to the candidate through an intermediary or 

conduit, are contributions from the person to the candidate.”).

101 See, e.g., Factual and Legal Analysis (“F&LA”) at 5, MUR 7903 (Tomfoolery, LLC, et al.) (“[T]he 

contributions made in Tomfoolery’s name were, in fact, actually made by Thomas A. Chavez, when Chavez 

furnished Tomfoolery with funds for the purpose of having the LLC make the contributions.”); F&LA at 1-2, 

MUR 6920 (American Conservative Union) (finding reason to believe that the contribution was made in the name of 

another where the organization who was reported as the contributor later indicated that it was not the true source of 

the contribution, and instead merely delivered the contribution upon receipt of the funds from another person); see 

also 11 C.F.R. § 110.4(b)(2)(i)-(ii).

Attachment 6 

Page 23 of 33

MUR808200469
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 24 of 33

1 between the LLC’s formation date and the contribution,” “the amount of the contribution relative 

2 to [the LLC’s] other activities, the LLC’s known activities prior to making the contribution, and 

3 whether any other information suggests an attempt to circumvent the Act’s disclosure 

4 requirements.” 

5 Here, the available information indicates that the five 2020 political contributions 

6 purportedly made by the alleged Conduit Corporations — Florida Promise, Broken Promises, 

7 Grow United, CAIJ, and Stand Up for Justice — were actually made on behalf of Unknown 

8 Respondents. The overall record indicates that there was plan whose purpose was “to 

9 circumvent the Act’s disclosure requirements” by using the names of the Conduit Corporations 

10 to make contributions and that this plan was implemented in largely the way the blueprint set 

11 out. In addition, the overall record of the Conduit Corporations’ known activities indicate that 

12 they may have been formed for the purpose of making conduit contributions. 

13 Specifically, news articles indicate that, during the 2020 election cycle, Matrix invited 

14 FPL to anonymize its political activities by funneling money through several layers of conduits, 

15 including Florida Promise and Broken Promises, and then using those funds to make federal and 

state political contributions.

102 16 The articles report that Jeff Pitts, former CEO of Matrix, emailed

17 Eric Silagy, former CEO of FPL, a “‘funding memo’” with goals such as making “federal 

18 campaign contributions” and “‘minimiz[ing] all public reporting of entities and activities,’” and a 

“‘legal memo on federal elections support.’”103 19 According to the Orlando Sentinel, the funding 

20 memo included a flowchart depicting FPL’s funds flowing through several layers of conduits 

21 controlled by Pitts and Matrix, including Florida Promise and Broken Promises, before being 

102 Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 3, 31-38. 

103 Secretive Political Spending Plan, supra note 12; see also Compl. ¶¶ 3, 31-32. 

Attachment 6 

Page 24 of 33

MUR808200470
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 25 of 33

contributed to federal and state political committees.104 1 While the specific plan reported by the 

2 news articles did not directly identify CAIJ, Grow United, or Stand Up for Justice, the proposal 

3 establishes the preexisting idea of making conduit contributions with entities just like these, 

4 which as discussed below, was ultimately carried out using the five alleged Conduit 

5 Corporations. 

6 News articles stated that the sources of the documents were from Matrix itself, noting 

that the documents were internal Matrix documents.105 7 FPL’s spokesperson, David Reuter, 

8 reportedly confirmed that the proposal as reported was indeed shared with its CEO, stating, “‘We 

9 are aware of the proposed structure as the legal memo was shared with us, and as we understand 

10 it, Joe Perkins’[s] team at Matrix created a proposal to fund their clients’ communication and 

outreach activities during 2020.’”106 11 Thus, there is no available information indicating that the 

12 news articles’ report that Pitts and Matrix created and shared a proposal to anonymize political 

13 contributions was inaccurate or not credible. 

14 Moreover, the available information does not indicate that the proposal was limited to 

15 acting solely within the legal bounds of minimizing public reporting of political activities. 

16 Specifically, the proposal did not indicate that Pitts and Matrix were soliciting funds from FPL 

17 on behalf of nonprofit corporations that would independently decide to make political 

18 contributions. Rather, the proposal indicated that funds would flow from FPL, through several 

19 layers of conduits controlled or associated with Matrix, before landing at “Florida Promise C4,” 

104 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

105 See Secretive Political Spending Plan, supra note 12 (stating that the Orlando Sentinel received records 

“includ[ing] checks, bank statements, emails, text messages, invoices, internal ledgers and more, all apparently 

unearthed during an internal investigation Matrix launched after its former employees left the firm at the end of 

2020.”).

106 Id.

Attachment 6 

Page 25 of 33

MUR808200471
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 26 of 33

1 “US Promise C4” and “Fed Promise C4,” which would also be controlled by Matrix, to make 

contributions to state and federal political committees.107 2 

3 Notably, there is no available information indicating that Pitts or Matrix presented the 

4 purposes or goals of the conduits referenced in its flowchart, besides being able to making 

5 political contributions, to explain why FPL’s funds would be expected to flow from one 

corporation to another.108 6 There is also no available information indicating that Pitts and Matrix 

7 presented any information as to why “Florida Promise C4,” “US Promise C4” and “Fed Promise 

8 C4,” would be expected to engage in political activity that FPL would support. Instead, Pitts’s 

9 and Matrix’s flowchart simply noted “Matrix” in a parenthetical below the names of “Broken 

10 Promises,” “Florida Promise C4,” “US Promise C4” and “Fed Promise C4,” similar to how 

11 Tyson, the executive director of LPAD, was included in a parenthetical under LPAD, suggesting 

that these entities are controlled by “Matrix,” similar to how Tyson controlled LPAD.109 12 

13 Moreover, the conduits depicted on the flowchart appear to have been in fact controlled 

14 by or associated with Matrix. Of the conduits mentioned, only Florida Promise, Broken 

15 Promises, LPAD, and SUN existed or eventually came into existence, and they all have ties to 

16 Pitts and/or Matrix. As explained above, Richard Alexander was the chairman of Florida 

Promise, and his sister, April Odom, was a Matrix contractor at the time of the allegations.110 17 

107 Id.; see also Compl. ¶¶ 33 Fig. 1, 36-37. 

108 See Secretive Political Spending Plan, supra note 12 (noting that, for example, “Florida Promise C4” would 

“allowed to spend 50% of revenues on political activities” and that “Florida PCs are allowed to take unlimited funds 

from C4s”); see also Compl. ¶ 33 Fig. 1 (same).

109 See Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1. While the term “person” 

appears in the parenthetical next to SUN, SUN had not yet been formed when Pitts sent the memo, and thus this

denotation appears to suggest that they were looking for a “person” to be in control of SUN at that time. See 

Secretive Political Spending Plan, supra note 12 (reporting that Pitts sent the memo to Silagy on November 26, 

2019).

110 Florida Promise 2018 Tax Return at 3, supra note 32; Dark Money Playbook, supra note 7 (reporting that 

April Odom is Anderson’s sister and was a former Matrix employee).

Attachment 6 

Page 26 of 33

MUR808200472
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 27 of 33

1 Sean J. Anderson, who was the president and chairman of Broken Promises, was also a former 

2 Matrix employee, a close friend of Pitts, and has a history of allowing Pitts to control the 

nonprofits that he purportedly ran.

111 3 Tyson, the executive director of LPAD, reportedly 

4 associated with Pitts and Abigail MacIver, another former Matrix employee, as they 

communicated via text messages regarding Florida state senate races.112 5 Finally, as for SUN ⸺

6 FPL, which reportedly gave $250,000 to SUN in December 2019, states that it believes that SUN 

is owned by Matrix.113 7 Thus, the layers of corporations depicted on the flowchart appear to be 

8 linked together because they are controlled by persons associated with Pitts or Matrix. 

9 The available information also indicates that Pitts’s and Matrix’s proposal included the 

10 making of federal political contributions. According to news articles, Pitts’s email to Silagy 

11 included a “‘funding memo’” noting making “federal campaign contributions” as one of its 

goals.114 12 Pitts’s email to Silagy also included “‘a separate legal memo on federal elections 

13 support’” explaining that “a nonprofit might have to disclose its donors if it spent money directly 

14 supporting a candidate” but that “the nonprofit would not have to disclose its donors if it gave 

money to a type of political action committee known as a ‘Super PAC,’”115 15 which is a colloquial 

reference to federal independent expenditure-only committees.116 16 Moreover, this legal memo 

111 Broken Promises, 2018 Tax Return at 1, 7, supra note 60; Bachelor Party, supra note 10 (reporting Pitts as 

having attended Anderson’s bachelor party); Nightmare Scenario, supra note 10 (reporting that Pitts texted FPL 

Vice President Martell that Anderson was an old friend of his and that he was “‘in control 100 percent’” of the 

nonprofits purportedly run by Mr. Anderson).

112 FPL Execs, supra note 43. 

113 Secretive Political Spending Plan, supra note 12. 

114 Id.; see also Compl. ¶ 32.

115 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 38.

116 See McCutcheon v. FEC, 572 U.S. 185, 193 (2014) (“A so-called ‘Super PAC’ is a PAC that makes only 

independent expenditures and cannot contribute to candidates. The base and aggregate limits govern contributions 

to traditional PACs, but not to independent expenditure PACs.”).

Attachment 6 

Page 27 of 33

MUR808200473
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 28 of 33

1 appears to provide the missing explanation as to the purpose of providing funds to the “Fed 

2 Promise C4” entity in the funding memo’s flowchart, indicating that this purpose would be to 

make federal political contributions.117 3 The name, “Fed Promise C4,” also suggests that this 

4 conduit would be used to make federal political contributions, as this would be consistent with 

5 and parallel to the flowchart’s statements that “Florida Promise C4” would be used to fund 

6 “Florida PCs” and that “US Promise C4” would be used to fund other state-level political 

activities.118 7 Thus, the available information indicates that the Pitts/Matrix proposal included 

8 making federal political contributions. 

9 The available information also indicates that the alleged Conduit Corporations received 

10 funds with the direction that they be used for federal contribution purposes as federal courts have 

11 stated that a donor’s intent can be inferred from the donee’s solicitations. Specifically, in the 

12 context of interpreting 52 U.S.C. § 30104(c)(1) of the Act, which courts have held to require notpolitical committees to disclose donations received for political purposes,119 13 a district court in 

14 Wisconsin observed that “whether a contribution is earmarked for political purposes and tied to 

15 an election can depend on whether the contribution is received in response to a solicitation and 

the way the solicitation is worded.”120 16 As explained above, Pitts’s and Matrix’s proposal clearly 

17 implicated the making of federal contributions, and the alleged Conduit Corporations appear to 

18 have received donations in response to that proposal.

19 In addition to conceiving of and sharing the plan, Pitts and Matrix were also in a position 

117 See Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1 (noting that it was 

“[w]aiting on lawyers” to explain the purpose of Fed Promise C4).

118 Secretive Political Spending Plan, supra note 12; see also Compl. ¶ 33 Fig. 1.

119 Citizens for Resp. & Ethics in Washington v. FEC, 316 F. Supp. 3d 349, 389 (D.D.C. 2018), aff’d, 971 F.3d 

340 (D.C. Cir. 2020).

120 Wisconsin Fam. Action v. FEC, No. 21-C-1373, 2022 WL 844436, at *11 (E.D. Wis. Mar. 22, 2022). 

Attachment 6 

Page 28 of 33

MUR808200474
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 29 of 33

1 to carry it out using the names of alleged Conduit Corporations to make the contributions. As 

2 discussed above, the persons nominally in charge of the alleged Conduit Corporations, 

3 Alexander and Anderson, had close relationships with Pitts and Matrix. Alexander, who served 

4 as a director or officer of Florida Promise, CAIJ, and Grow United, is apparently the brother of 

5 April Odom, who was a Matrix contractor at the time of the contributions and worked on matters 

relating to CAIJ and Grow United on behalf of Matrix.121 6 Anderson, who was the chairman and 

7 president of Broken Promises and a director and president of Stand Up for Justice, was also 

former Matrix employee, and a close friend of Pitts.122 8 Pitts and Matrix also has a history of 

9 working with Anderson’s nonprofit corporations, as Pitts reportedly texted FPL Vice President 

10 Daniel Martell in 2016, four years prior to the contributions at issue here, “‘Bottom line is we are 

11 the ones with the check books and in control 100 percent’” of the nonprofits purportedly run by 

Anderson.123 12 

13 Pitts and Matrix also reportedly used the names of CAIJ and Grow United in other 

operations,124 and had access to CAIJ’s and Grow United’s bank accounts,125 14 further indicating 

15 that they had control over these corporations. Specifically, news reports indicate that, in October 

121 Dark Money Playbook, supra note 7 (reporting that April Odom is Anderson’s sister and was a former 

Matrix contractor); see also Compl. ¶¶ 13, 48.

122 Bachelor Party, supra note 10 (reporting Pitts as having attended Anderson’s bachelor party); Nightmare 

Scenario, supra note 10 (reporting that Pitts texted FPL Vice President Martell that Anderson was an old friend of 

his); see also Compl. ¶¶ 16, 52.

123 Nightmare Scenario, supra note 10; see also Compl. ¶¶ 16, 52. 

124 FPL Execs, supra note 43 (reporting that Matrix made a conduit contribution using CAIJ’s name on behalf 

of FPL); Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/ (reporting that Matrix offered a city councilman 

a job on behalf of FPL using Grow United’s name).

125 Dark Money Playbook, supra note 7 (reporting that internal Matrix records included a text message from

Odom stating that she procured access to the bank accounts of CAIJ and Grow United). 

Attachment 6 

Page 29 of 33

MUR808200475
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 30 of 33

2018, Pitts used CAIJ to make a contribution to House Majority PAC on behalf of Matrix.126 1 

2 News reports also indicate that in the summer of 2019, Matrix used Grow United to offer a job to 

a Jacksonville City Council member on behalf of FPL.127 3 In addition, according to the Orlando 

4 Sentinel, it received internal Matrix documents reflecting a September 23, 2020 text message 

from Odom stating that she procured access to CAIJ’s and Grow United’s bank accounts.128 5 

6 Finally, Tyson, the executive director of LPAD who donated $1,150,000 of LPAD funds to 

7 Grow United, testified that he understood that Pitts created and ran Grow United. Therefore, not 

8 only did Pitts and Matrix conceive of a plan for the making of conduit contributions, they also 

9 had sufficient control over the alleged Conduit Corporations to cause them to permit their names 

10 to be used to make contributions on behalf of Unknown Respondents. 

11 Although all five of the alleged Conduit Corporations were formed more than a year prior 

12 to making the contributions, the overall record of their known activities indicate that they were 

13 formed for the purpose of making conduit contributions. The only available information as to 

14 the five alleged Conduit Corporations’ activities was that they made federal and Florida state 

political contributions.129 15 Broken Promises and Stand Up for Justice spent at least 67% to 89% 

126 FPL Execs, see supra note 43 (reporting that Silagy, former CEO of FPL, emailed Pitts, former CEO of 

Matrix, to make a contribution to House Majority PAC to support Lauren Baer, and to make sure that “they don’t 

triangulate this donation to others we have done”); see also House Majority PAC, 2018 Amended 12-Day PreElection Report at 655 (Dec. 3, 2018), https://docquery.fec.gov/pdf/085/201812069135107085/20181206913510

7085.pdf (reflecting CAIJ’s contribution to House Majority PAC on October 16, 2018).

127 Nate Monroe, Amid JEA Privatization Controversy, a City Council Member Received a Mysterious Job 

Offer. A Dark-Money Group May Have Been Behind It, THE FL TIMES-UNION (Sept. 2, 2022), https://www.

jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-sale-jacksonville-city-council-membermysterious-job-offer-dark-money-group-nate-monroe/8850689002/. FPL reportedly confirmed that Matrix 

employees came up with an idea to offer the City Council member a job, but that it rejected the idea. Id. 

128 Dark Money Playbook, supra note 7 (reflecting a text message from Odom in the upper right-hand corner 

of the article’s sixth picture); see also Compl. ¶ 48.

129 Although Matrix reportedly used Grow United to offer a job to a Jacksonville council member, that never 

came to fruition as the council member rejected the offer. Nate Monroe, Amid JEA Privatization Controversy, a 

City Council Member Received a Mysterious Job Offer. A Dark-Money Group May Have Been Behind It, THE FL

Attachment 6 

Page 30 of 33

MUR808200476
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 31 of 33

1 and 78% to 94%, respectively, of their total funding on making federal and Florida state political 

2 contributions, indicating that they were created for the primary purpose of making political 

contributions.130 3 Moreover, consistent with the Pitts’s and Matrix’s proposal, federal tax records 

4 show that their funding was first transmitted through another Matrix-associated conduit, the 

5 Alliance for Consumer Protection Inc., which was reportedly controlled by Pitts’s former college 

roommate.131 6 While the available information does not indicate the total funding received by 

7 Florida Promise, CAIJ, or Grow United, the only known activities by these corporations are that 

they made an aggregate of $3,224,500 in federal and Florida state political contributions.

132 8 

9 In addition, only Florida Promise, Broken Promises, and Stand Up for Justice appeared to 

10 have filed federal tax returns, and these returns do not indicate that they engaged in any activity 

other than making political contributions, including through lobbying.133 11 The purpose 

12 statements in these tax returns indicate that Florida Promise, Broken Promises, and Stand Up for 

13 Justice were formed for political purposes, further suggesting they only engaged in political 

TIMES-UNION (Sept. 2, 2022), https://www.jacksonville.com/story/news/columns/nate-monroe/2021/12/10/jea-salejacksonville-city-council-member-mysterious-job-offer-dark-money-group-nate-monroe/8850689002/. 

130 See supra pages 15-16, 18-19.

131 IRS Form 990, Alliance for Consumer Protection Inc., 2018 Return of Organization Exempt from Income 

Tax, Sched. I at 1 (Sept. 28, 2020), https://apps.irs.gov/pub/epostcard/cor/813511095_201812_990O_20211020

19109756.pdf; Nightmare Scenario, supra note 10. 

132 See supra notes 33-34 and accompanying text (reflecting that Florida Promise made $1,230,000 in federal 

and Florida state contributions); supra notes 38, 40, 38 and accompanying text (reflecting that CAIJ made $432,000 

in federal and Florida state contributions); supra notes 46, 49 and accompanying text (reflecting that Grow United 

made $1,562,500 in federal and Florida state contributions).

133 See generally Florida Promise 2018 Tax Return, supra note 32; Broken Promises 2018 Tax Return, supra

note 60; Stand Up for Justice 2018 Tax Return, supra note 76. As indicated above, while Broken Promises and 

Stand Up for Justice indicated in their 2018 federal tax returns that they spent funding on “lobbying” and “other”

program expenses in 2018, the amounts they reportedly spent correspond to the same amounts that they spent on 

making Florida state political contributions. See supra pages 16, 18. 

Attachment 6 

Page 31 of 33

MUR808200477
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 32 of 33

activities.

134 1 

2 Furthermore, there are various organizational aspects of the alleged Conduit Corporations 

3 that suggest they were formed to serve as conduits. Specifically, despite the fact that CAIJ and 

4 Stand Up for Justice were incorporated in different states and do not share any officers, both 

entities reported having the same mailing address in Washington, D.C.135 5 In addition, despite 

6 both Broken Promises and Stand Up for Justice having the same three officers and nearly 

7 identical mission statements, both entities were incorporated on the same day in the same 

state.

136 8 Finally, Broken Promises’s federal tax return suggests that it was trying to conceal that 

9 it made political contributions. Specifically, Broken Promises characterized on its 2018 federal 

10 tax return that it spent $115,470 on “other” program service expenses, when that amount was 

actually used to make in-kind contributions to Florida state committees.137 11 Thus, the available 

12 information as to the activities, stated purpose, and creation of the Conduit Corporations suggests 

13 that they were created for making conduit contributions. 

134 Florida Promise 2018 Tax Return at 6, supra note 32 (stating that its purpose is to “develop and advocate 

for legislation, regulations, and government programs related to policies to benefit Floridians”); Broken Promises 

2018 Tax Return at 2, supra note 60 (stating that its purpose is to “develop[] and advocat[e] for legislation, 

regulations, and government programs to improve social environmental, economy and social environment”); Stand 

Up for Justice 2018 Tax Return at 2, supra note 76 (stating that its purpose is to “develop[] and advocat[e] for 

legistlation [sic], regulations, and government programs to improve social environment, economy & society”).

135 American Valor PAC, 2020 Termination Report at 6 (Dec. 3, 2020), https://docquery.fec.gov/pdf/242/

202012039337569242/202012039337569242.pdf (reflecting that CAIJ’s address was at 2020 Pennsylvania Avenue, 

NW, Ste. 449, Washington DC 20006); CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing

(last visited Sept. 25, 2023) (searching the organization name “Stand Up for Justice”) (reflecting that Stand Up for 

Justice’s business address was at 2020 Pennsylvania Avenue, NW, #449, Washington DC 20006). 

136 See CorpOnline, DC.GOV, https://corponline.dcra.dc.gov/Home.aspx/Landing (last visited Sept. 25, 2023) 

(searching the organization names “Broken Promises” and “Stand Up For Justice”) (reflecting that both Broken 

Promises and Stand Up for Justice were incorporated on August 29, 2018); Broken Promises 2018 Tax Return at 1, 

7, supra note 60; Stand Up for Justice 2018 Tax Return at 1, 7, supra note 76. 

137 Compare Broken Promises 2018 Tax Return at 10, supra note 60 (stating that it spent $115,470 in “other” 

program service expenses), with Campaign Finance Database, FLA. DEP’T OF STATE, https://dos.elections.

myflorida.com/campaign-finance/contributions/ (last visited Sept. 25, 2023) (searching election year “all” and 

contributor last name “Broken Promises”) (reflecting that Broken Promises Broken Promises made $115,470 in inkind Florida state political contributions in 2018).

Attachment 6 

Page 32 of 33

MUR808200478
MUR 8082 (Stand Up for Justice) 

Factual and Legal Analysis

Page 33 of 33

1 In sum, the available information indicates that there was a plan to illegally disguise or 

2 withhold public reporting of political activities, and that this plan included making contributions 

3 through conduits and in a manner that closely matches what the available information shows had 

4 subsequently occurred. In addition, pursuant to this plan, the alleged Conduit Corporations 

5 permitted their names to be used to make federal political contributions on behalf of Unknown 

6 Respondents. Finally, the only known activities of the alleged Conduit Corporations were that 

7 they made federal and Florida state political contributions, indicating that their purpose was to 

8 serve as conduits. Thus, the Commission finds reason to believe that Stand Up for Justice 

9 violated 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b) by knowingly permitting its name to be 

10 used to effect contributions in the name of another. 

Attachment 6 

Page 33 of 33

MUR808200479