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>>23097587 Flashback - CREW requests OGE documents on Federalist Society exec Leonard Leo

Re:Complaint Against Several Tax-Exempt OrganizationsPaying Excessive

Compensation, Directly or Indirectly, to Leonard Leo

Dear Sir or Madam:

Campaign for Accountability (“CfA”)1 respectfully submits this Tax-Exempt Organization

Complaint to the Internal Revenue Service (“IRS”) regarding following tax-exempt organizations:

Rule of Law Trust (EIN: 83-1047727), a Virginia trust and Section 501(c)(4) social welfare

organization (“Rule of Law Trust”);

Wellspring Committee, Inc. (EIN: 26-2046485), a Virginia nonstock corporation and

Section 501(c)(4) social welfare organization (“Wellspring Committee”);2

The 85 Fund (EIN: 20-2466871), a Virginia nonstock corporation and Section 501(c)(3)

tax-exempt entity (“The 85 Fund”);3

The Concord Fund (EIN: 20-2303252), a Virginia nonstock corporation and Section

501(c)(4) social welfare organization (“The Concord Fund”);4

The Federalist Society for Law & Public Policy Studies (EIN: 36-3235550), an Illinois not-

for-profit corporation and Section 501(c)(3) tax-exempt entity (the “Federalist Society”);

Freedom and Opportunity Fund (EIN: 81-1199959), a Delaware corporation and Section

501(c)(4) social welfare organization (“Freedom and Opportunity Fund”);5 and

Marble Freedom Trust (EIN: 85-0784793), a Utah trust and Section 501(c)(4) social

welfare organization (“Marble Freedom Trust”).

This complaint will refer to these seven tax-exempt entities as the “Leo-Affiliated Nonprofits.”

Each of the Leo-Affiliated Nonprofits is either (a) directly controlled by Leonard Leo (e.g., as an

officer, director, or trustee) or (b) shows other signs of being controlled by Leonard Leo, includin

https://s3.documentcloud.org/documents/23741538/campaign-for-accountability-irs-complaint-leonard-leo-nonprofits.pdf

>>23099053

>Re:Complaint Against Several Tax-Exempt OrganizationsPaying Excessive

>Compensation, Directly or Indirectly, to Leonard Leo

IRS EO Classification

Leonard Leo and Leo-Affiliated Nonprofits

Page 2

2

(i) having a small group of frequently overlapping individuals, who happen to control other Leo-

Affiliated Nonprofits as its directors, officers, or trustees, (ii) public statements and major media

publications identify the entity as controlled by Leonard Leo (regardless of its nominal directors,

officers, or trustees), (iii) having an entity or entities controlled by Leonard Leo as one of the

largest donors, and/or (iv) the same individual, who is a Leonard Leo business associate and

maintains books and records for Leo-Affiliated Nonprofits where Leonard Leo is the sole or

primary trustee, happens to maintain all of the books and records for the entity.

There are questions as to whether the Leo-Affiliated Nonprofits have diverted substantial

portions of their income and assets, directly or indirectly, to the personal benefit of Leonard Leo.

Most of these entities have either made substantial independent contractor payments one or more

of his for-profit business entities or made major contributions to other Leo-Affiliated Nonprofits

that made such payments. Such payments were generally listed as made in exchange alleged

consulting, research, public relations, or similar services, however, CfA has reasonable questions

about whether those alleged services were actually rendered at all or, if services were rendered,

whether the payments made were substantially in excess of the fair market value of those services.

Unfortunately, neither CfA nor the general public is able to easily determine all of the

complex, interwoven relationships among Leonard Leo’s business associates, who operate several

of the Leo-Affiliated Nonprofits, and Leonard Leo’s for-profit businesses that receive millions of

dollars in payments for alleged services. Additionally, the details of each of the business

transactions, such as contracts for consulting or public relations services, are not publicly available.

The IRS, however, with its summons, investigatory, and other related enforcement powers, would

be able to compel the production of information necessary to unravel the web of potential private

inurement, excess benefit, and/or and private benefit at the heart of these multimillion-dollar

independent contractor payments.

Form 13909 is enclosed with this letter.

FACTUAL BACKGROUND

Leonard Leo

Leonard Leo is an American lawyer and legal activist who began working for the Federalist

Society in 19916 and is currently the Co-Chairman of its Board of Directors.7 During most the

period examined in this Complaint (2016 through 2020), Leonard Leo worked full time at the

Federalist Society (40 hours per week).8 In addition, in many of those years, Leonard Leo worked

extensive part-time hours at other tax-exempt organizations. Illustratively, in 2019, Leonard Leo

worked five hours per week as Director and President of America Engaged (EIN: 81-2072162),9 a

Virginia nonstock corporation and Section 501(c)(4) social welfare organization, five hours per

week as sole trustee of Rule of Law Trust,10 and one hour per week as President of BH Fund (EIN

>>23099053

>>23099062

Funding Projects

Leonard Leo’s network has given $1.9 million to the Ethics and Public Policy Center; $565,000 to Concerned Women for America; $550,000 to the Becket Fund; and $6.5 million to the Republican Attorneys General Association. 11

Leo was an adviser to Judicial Education Project, a nonprofit that was involved producing a feature-length documentary film, Created Equal, about Associate Justice Clarence Thomas. 14

BH Group donated $1 million to the President-elect Donald Trump’s inaugural committee. 3

The 85 Fund contributed $400,000 in 2020 to the Public Interest Legal Foundation, a right-leaning legal group that focuses on election integrity. 11

Investigations

In April 2023, the Campaign for Accountability filed an IRS complaint alleging Leo caused nonprofits “to pay him (directly or indirectly) more than $73 million over a six-year period from 2016 through 2021.”15 The Campaign for Accountability began as a project fiscally sponsored by Hopewell Fund, an arm of the Arabella Advisors network. It has since spun off into an independent organization. 16

After making the IRS complaint, the Campaign for Accountability also wrote the District of Columbia Attorney General Brian Schwalb (D) requesting an investigation into Leo. 15 Schwalb opened an investigation into Leo and his network. Both Schwalb and his deputy attorney general Seth Rosenthal are reported to have ties to Arabella Advisors. 8

Personal Life

Leo and his wife, Sally, live in Northern Virginia. They have seven children. 1 Leo has said that his pro-life views derive in part from his daughter Margaret dying at age 14 from complications of spina bifida. 2

He is a New Jersey native and grandson of an Italian immigrant who worked for Brooks Brothers. 17

Leo was a founding board member of the National Catholic Prayer Breakfast and amember of the Sovereign Military Order of Malta, a Catholic lay religious order. 4

https://www.influencewatch.org/person/leonard-leo/

>>23099084

==Federalist Society’s Leonard Leo Works with Pence to Block RFK Jr Nomination

He's also been leading the charge with SCOTUS nominees.==

by AWray

January 28, 2025

in Big Pharma, News, The Swamp

Federalist Society’s Leonard Leo Works with Pence to Block RFK Jr Nomination

Last Updated on January 28, 2025

Federalist Society co-chair, Leonard Leo, has come under fire after it was discovered that he’s been working with a Mike Pence-founded org, aimed at blocking the appointment of Robert F. Kennedy for health secretary.

Leonard Leo

It was revealed in a report on Wednesday that Leo’s public relations firm, CRC Advisors, is working with a political advocacy group founded by former VP Mike Pence, in an effort to dissuade GOP senators from confirming Kennedy’s nomination for Secretary of Health and Human Services. CRC Advisors is promoting the campaign, which was launched by Pence’s organization, Advancing American Freedom, to the tune of hundreds of thousands of dollars.

Mike Pence, who served as Vice President during President Trump’s first term, is best known for his falling out with the President over his certification of the controversial 2020 election results.

An article in POLITICO Pro provided receipts of Leo’s participation in this effort; highlighting additional details related to his connections with Big Pharma:

The CRC employee’s 2020 resume file lists another corporate client: pharmaceutical giant Eli Lilly. Like its competitors, the drugmaker has faced scrutiny from Democratic lawmakers for jacking up the price of insulin products that diabetics need to live. While Lilly announced a price cut last year, the Los Angeles Times noted that the new price was “still higher by two-thirds than what it should be,” and the company could actually end up collecting higher profits.

Robert F. Kennedy, who mainstream media has labelled “anti-vax”, has been vocal about his skepticism of vaccines and the use of vaccine mandates. Kennedy has also expressed a desire to “devote half of research budgets … toward preventive, alternative and holistic approaches to health.” Additionally, Kennedy has been an outspoken opponent of the multi-billion-dollar a year “direct-to-consumer pharmaceutical advertising” industry, which he believes should be banned.

Pence’s AAF has fought to sway senators from supporting Kennedy’s confirmation, primarily by focusing on his past support for abortion; a legal issue that is determined by the courts at the state level – not HHS. Both sides of the aisle, however, oppose Kennedy’s views on vaccines; given the power the pharmaceutical lobby has in Washington.

On Sunday, Kennedy’s former running mate, Nicole Shanahan, took to X, calling out Leo’s firm for its collaboration with Pence’s AAF. The post, which included screenshots of the POLITICO Pro article, has received 3.7 million views as of the writing of this article.

“Why is a “conservative” PR firm spending hundreds of thousands of $ to try to sink RFK’s nomination? Could it be because they’re also pocketing millions from Big Pharma and super PACs that supported Nikki Haley’s campaign against Trump? This is the precise corruption the American public voted against in November,” Shanahan wrote in her post.

The POLITICO Pro article also highlighted Leo’s involvement with the Koch network’s political advocacy arm, Americans for Prosperity – and their history of opposition to President Trump’s agenda.

AFP’s super PAC spent more than $40 million supporting former South Carolina Gov. Nikki Haley’s failed Republican primary campaign against Trump this election cycle.

Given Leonard Leo’s questionable involvement with anti-Trump elements of the establishment Republican party, and his business connections to Big Pharma, whether his influence is enough to block Kennedy’s nomination is yet to be seen.

https://nationalfile.com/federalist-societys-leonard-leo-works-with-pence-to-block-rfk-jr-nomination/

>>23099285

>Federalist Society’s Leonard Leo Works with Pence to Block RFK Jr Nomination

>>23099285

>>23099293

>>Federalist Society’s Leonard Leo Works with Pence to Block RFK Jr Nomination

Leonard Leo's involvement in the pharmaceutical industry primarily revolves around his consulting firm, CRC Advisors, and its work with pharmaceutical companies, particularly in relation to drug pricing and access to medications

.

Key Points:

CRC Advisors and Eli Lilly: Leonard Leo's consulting firm, CRC Advisors, has worked for the pharmaceutical giant Eli Lilly. Eli Lilly has been actively fighting the Biden Administration's efforts to lower prescription drug costs.

Drug Pricing and Opposition to Government Intervention: Leo's firm's involvement with Eli Lilly highlights a connection between his network and opposition to government intervention in drug pricing. Eli Lilly, like other pharmaceutical companies, has faced scrutiny over the rising costs of essential medications like insulin.

Mifepristone and Reproductive Healthcare: Leonard Leo and his network have been actively involved in efforts to restrict access to mifepristone, a medication used in medication abortions. This effort includes challenging the FDA's approval of the drug.

Leonard Leo's Broader Influence:

Conservative Legal Movement: Leonard Leo is a prominent figure in the conservative legal movement and has played a significant role in shaping the judiciary, including the Supreme Court.

"Dark Money" Network: Leo's network is known for its use of "dark money," which involves funding political causes through non-profit organizations that are not required to disclose their donors. This lack of transparency makes it difficult to fully track the extent of his influence.

Controversial Figure: Leo's involvement in efforts to restrict access to abortion and his ties to the pharmaceutical industry have made him a controversial figure. Critics argue that his actions undermine public health and access to healthcare.

In Summary:

Leonard Leo's connection to the pharmaceutical industry is primarily through his consulting firm and its work representing companies like Eli Lilly. His network's efforts to restrict access to mifepristone and oppose government intervention in drug pricing demonstrate a clear link between his broader political goals and the pharmaceutical industry