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Posted on May 12 2019


By way of context and background (I’d simply repost my April, May and June 2017 twitter threads, oh wait I can’t because Twitter). Notwithstanding see April 2018 blog entry here. See March 2019 FEC & Broidy entry here. Also in March of 2019 I casually mentioned a case update involving George Higgenbotham, found here. The full Elliot Broidy Files can be found here.


Just to reiterate the import of Higgenbotham was in fact a huge clue of what was coming down the Judicial pipeline. I spent a decent amount of time actually reading the December 2018 hearing transcript, found here.




About Damn Time...

SpicyFiles laughs and laughs


For those of you who have followed me on Twitter and this blog then you know that I’ve had an odd obsession with the 1MBD Fubar. Yet even I was a bit caught off guard by yesterday DOJ OPA Release, which reads in part:


A United States entertainer and businessman and a Malaysian financier were charged  in a four-count indictment unsealed today in the District of Columbia for conspiring to make and conceal foreign and conduit campaign contributions during the United States presidential election in 2012



The unsealed indictment charges PRAKAZREL MICHEL and LOW TAEK JHO with the following counts:


Count 1: 18 U.S.C. § 371 Conspiracy 
Count 2: 18 U.S.C. §§ 1001 & 2 False Statement(s)
Count 3: 18 U.S.C. §§ 1519 & 2 False Entry in Record
Count 4: 18 U.S.C. §§ 1519 & 2 False Entry in Record


 “between June 2012 and November 2012, Low directed the transfer of approximately $21,600,000 from foreign entities and accounts to Michel for the purpose of funneling significant sums of money into the United States presidential election as purportedly legitimate contributions, all while concealing the true source of the money. 

To facilitate the excessive contributions and conceal their true source, Michel paid approximately $865,000 of the money received from Low to about 20 straw donors, or conduits, so that the straw donors could make donations in their names to a presidential joint fundraising committee.  In addition, Michel personally directed more than $1 million of the money received from Low to an independent expenditure committee also involved in the presidential election in 2012.


I suppose it’s welcomed news that Attorney General Barr’s new and arguably not well throughout nonsense that  “any presidential campaign can accept help from any foreign national or country” (as per the farce of his April 18, 2019 press conference) now proves the Department Of Justice might in fact find Foreign Influence is actually impermissible. Blessed Be, Jesus wept, NOT...

On page 2, paragraph 2 of the indictment it states (pretty clearly) that this involved the 2012 Presidential Election but it also takes great care to disclose that the Obama campaign and subsequent Administration had the origins of the funds hidden from them. I just personally think something is “off” with the secular nature of this indictment given the plethora of previous research, where I walked you through the straw donations and Elliot Broidy’s grubby fingerprints.  


foreign influence by engaging in a scheme to funnel millions of dollars of foreign money from JHO LOW into an election for the Office of President of the United States so that JHO LOW and MICHEL could buy access to, and potential influence with, a candidate, the candidate's campaign, and the candidate's administration...


To be clear the recently unsealed indictment is strictly related to the 2012 election cycle. When then President Obama’s re-election campaign accepted >$1million in campaign donations from 11 separate “straw donors”. Moreover if I was truly was a partisan hack, I wouldn’t highlight this (or other) indictments or scandals which may cause some Democrats to think I’m a troll or rabble rouser. I am neither. I’m a hunter of facts, collector of receipts and procurer of snark.

Although personally speaking I do not give a rat’s ass if you’re a R, D or I...

just to reiterate there’s no allegation of any wrongdoing by President Obama, his re-election campaign or by his administration. Irrespective of what the Alt-Right & Conservative “news” organizations are “reporting”.


 As alleged on page 4 of the indictment, the Defedants had 11 straw donors and controlled five different “shell” companies, as detailed on page 5:



With a high degree of confidence I’m comfortable stating that one of the entities disclosed in yesterday’s indictment is SPM Holdings, LLC


“they alleged that Prakazrel Michel had improperly used an entity called SPM Holdings LLC as a “straw donor” for two contributions, totaling $875,000, to the super PAC Black Men Vote...”


You might ask how do I know this to be true?

I assume a 2017 DC Order in a civil case brought by CREW pressing the FEC to actually enforce our campaign finance laws would be sufficient. As in DC Civil Action No. 16-752 (JDB).


I now refer you to page 6 of their October 2012 FEC Filing, also not to be a total PITA but if you’re going to tweet out FEC filings, take the time to properly redact a donor’s home address. I do not condone doxxing of any kind. Even if the data is publicly available on a public database, I simply do not see an upside to tweeting out someone’s PII via FEC reports. The only caveat (at least for me) is if I’m 100% confident that the “donor’s address” is their business address:

See Page 6 of their November 2012 FEC report.

During the 2011/2012 election cycle, this SuperPAC had three entities/individuals as their primary donors, as itemized below in a recent FEC search



Circling back to the Indictment, note the following datapoints:

1) note the expanded timeframe of 2012 to 2015. That’s largely due in part that the defendants filed false tax information and FEC reports in 2015 to cover up their 2012 largesse.

2) the distinction in paragraph 24 b & c? It really shouldn’t surprise you that the indictment, prosecutors are alleging the defendants violated both subsections of the election law which makes it impermissible for foreign funds to enter into our electoral system.  



On page six of the Indictment, the Government explains the methods and means of how this impermissible scheme allowed foreign money to flow in to the 2012 presidential election:

June 2012 to in or about November 2012, JHO LOW directed the transfer of approximately $21,000,000 from Company A and Company B, both shell companies in the British Virgin Islands with bank accounts in Singapore, to Company C and Company D, companies in the United States with bank accounts under the control of MICHEL and/or his financial advisor.

In addition, during the same period, JHO LOW directed the transfer of approximately $600,000 from Company B to one of MICHEL' s personal bank accounts in the United States 


In the furtherance of the conspiracy  Prakazrel “Pras” Michel and Low Taek Jho set up a series of shell companies and when questioned by various Federal Enforcement Agencies (mainly the FEC, see 2015 complaint) funneled millions of dollars, filed false tax returns and repeatedly lied to the FEC. As further explained on pages 7 thru 11 of the indictment.

The Indictment goes on to explain that at least one “straw donor” was uncomfortable with the scheme and went as far as to question the legality of said scheme..


In late April of 2019 it was widely reported that Jho Low was “gallivanting throughout China” and shuttling back and forth between Hong Kong, Macau and at least 4 providences throughout China. Both Malaysian and American law enforcement want Jho Low, yet oddly China has allowed this fugitive to essentially roam freely throughout China.


As you will note in the indictment prosecutors referenced a formal FEC complaint that was filed in April of 2015. With a near 100% degree of confidence I believe this is the aforementioned FEC Complaint MUR-6930

For those of you who are not well versed in the FEC’s various databases, it can be a daunting task to figure out where and what database to search in. That said the FEC has a legacy database, which I personally find easier to navigate. Case in point this FEC Link will take you to the entire MUR #6930 docket.

And once again I’m disgusted that not a single MSM outlet properly reported or even caught that in 2016 and 2017 respectively that the FEC, specially Matthew S Petersen, actually ruled that this “straw donor” issue wasn’t illegal. Oh you think I’m making that up?

Here are your actual FEC receipts:


04/01/2016 Chairman Matthew S. Petersen and Commissioners Caroline C. Hunter and Lee E. Goodman
04/18/2016 Chairman Matthew S. Petersen and Commissioners Caroline C. Hunter and Lee E. Goodman



The incompetence of both the FEC and the Trump Administration is utterly astounding. See the FEC February 2016 “certification” whereby the FEC dismissed the complaint and essentially found “no wrong doing”

It is vexing to me that not a single news outlet caught this, especially given the most awkward and cringeworthy Senate Judiciary hearing involving Petersen, whom Trump nominated for a lifetime judicial appointment. Here’s a novel idea, how about Petersen resigns from his FEC post, forthwith. And he gets off the tax payer funded payroll because this is just a naked issue of blatant incompetence. I’m not a reporter, I’m not paid a penny to write or research for this blog yet somehow I wonder if it is too much to demand better and more accurate reporting. For example, there is one newspaper I have both a paper and digital subscription, that’s the Washington Post. Case in point they have quietly maintained a rolling database of Trump’s PAS (senate required confirmation) vacancies. Did you know that Donald J Trump (sorry for yelling) STILL HAS FIVE FEC VACANCIES?


I can not help but wonder if or when Congress will ask Don McGahn the following series of questions (with respect to the FEC vacancies):

At any time did you advise president Trump about the FEC vacancies?
Were there any discussion of how to “defang” the FEC and/or limit their enforcement powers?
What is the vetting process for both PAS, specifically FEC and Judicial nominations?
Did you instruct the president to keep the FEC vacancies open and/or to utilize the FVRA to fulfill positions, particularly in “acting: roles?
Did you liaise or communicate (in any form, both orally and written) with the DOJ and/or improperly limit the DOJ’s scope of this indictment to 2012?
Did you or anyone in the White House officially or unofficially (improperly) intervene in a separate but related Case 1:18-cv-02795 or Case 2:19-cv-01327 which involves the same defendants? 



The Defendant Properties consist of:

a. $37,564,565.25 in bank funds seized from Account Number XXXXXXXX9515 at Morgan Stanley, held in the name of Anicorn, LLC (“ANICORN ACCOUNT”), on March 9, 2018, pursuant to a federal seizure warrant issued upon a finding of probable cause by the Honorable Robin Meriweather of the U.S. District Court for the District of Columbia;

b. $21,113.21 in bank funds seized from Account Number XXXXXX9537 at Wells Fargo Bank, N.A., held in the name of Artemus Group, LLC (“ARTEMUS ACCOUNT”), on July 2, 2018, pursuant to a federal seizure warrant issued upon a finding of probable cause by the Honorable G. Michael Harvey of the U.S. District Court for the District of Columbia ;

c. $25,002,568.63 in bank funds seized from Account Number XXXXXX1078 at Citibank, held in the name of Higginbotham Law P.C. (“HIGGINBOTHAM 1078 ACCOUNT”), on January 10, 2018, and February 27, 2018, pursuant to a federal seizure warrant issued upon a finding of probable cause by the Honorable Deborah A. Robinson of the U.S. District Court for the District of Columbia; and

d. $11,314,205.00 in bank funds seized from Account Number XXXXXX9974 at Citibank, held in the name of Higginbotham Law P.C. (“HIGGINBOTHAM 9974 ACCOUNT”), on January 10, 2018, pursuant to a federal seizure warrant issued upon a finding of probable cause by the Honorable Deborah A. Robinson of the U.S. District Court for the District of Columbia.


So when I randomly make a clear reference to other “cases”, you need to understand there’s nothing random about my reference or various questions. Although admittedly it is entirely frustrating having to redo my research because some bitter twitter trolls love to target any account I control. They do realize that’s not going to stop me from research, right? That only hardens my resolve to drop as many files and receipts that I can find, case in point I now refer you to page 4 of the aforementioned case, which reads in part:


Low Taek Jho (JHO LOW) funneled tens of millions of dollars into the United States to pay individuals to lobby high-level U.S. government officials to influence, inter alia, an ongoing U.S. Department of Justice (DOJ) criminal investigation of JHO LOW and related civil forfeiture proceedings over numerous of JHO LOW’s assets.


On page 4 of the aforementioned assets forfeiture, I now refer you to paragraph 8. At first read you wouldn’t know who Individual 1 or Individual 2 are.


And then comes the AHA moment. Again if you’ve spent any decent amount of time researching this incredibly complex matter then it’s rather easy to make an informed deduction of who’s who:

Because once you know what the “dollar amount” and Ts & Cs of the “agreed upon” letter of engagement or consultation agreement it becomes crystal clear that on page 6 its Elliot & Robin Broidy and it certainly makes sense why the Government only prosecuted George Higginbotham to a single criminal count. Higginbotham played a pivotal role in the conspiracy and now he’s playing the “cooperating witness role”



At the time you might recall in June of 2017, the DOJ-OPA release which reads in part:

The Justice Department announced today the filing of civil forfeiture complaints seeking the forfeiture and recovery of approximately $540 million in assets associated with an international conspiracy to launder funds misappropriated from a Malaysian sovereign wealth fund. Combined with civil forfeiture complaints filed in July 2016, seeking more than $1 billion, and civil forfeiture complaints filed last week seeking approximately $100 million in assets, this case represents the largest action brought under the Kleptocracy Asset Recovery Initiative. Assets now subject to forfeiture in this case total almost $1.7 billion.


The accompanying 207 page filing in Case 2:17-cv-04438, note the various assets bound for forfeiture, for example:


PALANTIR STOCK: All right and interest in 2,500,000 shares of Series D Preferred Stock in Palantir Technologies held by Tarek OBAID (“PALANTIR STOCK”).


I could be wrong but as I read the aforementioned case number. The 2012 and 2014 dates are critical. Meaning on page 8 and 9 of the filing (embedded above) become a plausible explanation of the motive of why the defendants made such schemes and took great care to hide the origins of the funds donated to Obama’s re-election campaign. The defendants intent was to “buy political influence” and to put their finger on the scale at the DOJ and more broadly the past and current administration. At least that’s how I read it, given the totality and complexity of this matter.


Again it’s plausible that I’m off the mark but given how much time I’ve allocated researching and reading hundreds of pages regarding the 1MBD matter, I still maintain that it is simply a matter of time for this political shitstorm to rain down on the GOP and specifically Mr & Mrs Broidy. Given many of us (non reporters) have said since 2017 when is Broidy’s barrel time? And let’s not forget Former Rep Royce...I spent a decent amount of time tracking down the Broidy donations and Royce’s whiplash on Qatar. From April 2018.

And it’s not like I haven’t embedded various FEC filings, Court Filings, FARA statements and/or House/Senate LDA filings...or taken the time to read various court transcripts, specifically Higginbotham’s hearing. But yeah I don’t have a LinkedIn Account nor can I retweet the various twitter threads which was the result of countless hours of my free time trying to unravel one of the more complex criminal enterprises I’ve encountered. Did it occur to you that my singular focus on 1MBD had more to do with connecting the various dots?


For example I am surprised that only a few realized that Kyle Feeney, formerly with the Special Counsel’s office was one of the lead trial attorneys in Case 2:17-cv-04438,


Or that George Nader played a pivotal role in connecting Broidy with the two Defendants in the May 10, 2019 Indictment. Nader also brought the UAE in on the investment of 1MBD. Nader subsequently thereafter played a primary role in connecting Eric Prince & RDIF meeting. He’s mentioned repeatedly in the Special Counsel’s Report. Moreover starting on page 147 Nader 

George Nader’s importance can not nor should not be overlooked. By all measures it appears Nader seems to be the nexus of 1MBD, UAE, Russia, Broidy and Eric Prince. And clearly I’m not the only one in DC who has reached this conclusion. Given on April 30, 2019 the HPSCI made a criminal referral to the DOJ. In which Chairman Schiff argued in his 20 page referral accompanied with Prince’s HPSCI transcript. The deviation from Prince’s HPSCI interview and that of the Special Counsel’s, it paints a pretty cut and dry portrait that Prince lies his face off during his House testimony. As detailed by the HPSCI April 30, 2019 Press Release, found here.

 The HPSCI referral notes the following:

The aforementioned false statements were material to the Committee’s investigation.  They impaired the Committee’s understanding of Russia’s attempts to contact and influence the incoming Trump Administration, concealed Mr. Nader’s role as an intermediary, and stymied the Committee’s ability to request relevant documents and testimony from Mr. Prince, Mr. Nader, Mr. Bannon, and other individuals who may have information about the Seychelles meeting(s), among other matters of interest to the Committee.  As a result, Mr. Prince’s false statements hindered the Committee’s ability to fully understand and examine foreign efforts to undermine our political process and national security, develop appropriate legislative and policy remedies to counter future malign influence operations targeting campaigns and presidential transitions, and inform the American public, as appropriate.


And yes I know it’s hard to follow the dots but what you need to know is in the Spring of 2017 it was largely reported (mainly by Asian News) that Prince and Jho Low had a lunch meeting in Hong Kong. Moreover that Prince’s Hong Kong based Frontier Group was awarded an incredibly lucrative Contract, see article here.

At any rate I hope this entry was informative. Given the copious embedded links to various Court Filings, FEC matters and DOJ actions. Which means you can read the same documents I have and draw your own conclusions. -Spicy Out

ps Happy Mother’s Day I hope you had/have a wonderful day, mine started out super fun. Because nothing says Happy Mother’s Day like “here’s a puke bucket” and cries of “my throat is on fire” at the moment I am presently locked in one of my walk in closets with blasting EDM or Fugeesvia my skull candy headphones and shoving goldfish in my mouth...hoping my family hasn’t figured out I’m hiding from them. It’s okay Pras, we will always have:


Ready or Not here I come...




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