TheSanityAnnex
05-12-2016, 12:59 PM
This deserves it's own thread
http://charlesortel.com/
Follow-up Letter to Donors, Charity Regulators, Investigative Journalists and
Citizens Worldwide
2 May 2016
Dear Friends,
First, a thank you to Kathleen Willey, Clarice Feldman, and Thomas Lifson1 for bringing
attention to yesterday’s letter.
Interest is finally building in piercing smokescreens that Clinton family members and allies still attempt to spread, claiming that a 20 year pattern of escalating, cross border abuses involving the Bill, Hillary, and Chelsea Clinton Foundation and multiple affiliated “charities” is a
“nothingburger”2.
For example, few who are even modestly familiar with applicable charity laws believe Bill
Clinton’s latest false assertion3 that investigation into the private email server is merely “a game”--as he will soon discover, the “email scandal” is part of much larger “records scandal”
over which he has little control4.
Major donors to charities are required under various laws to retain records that demonstrate the rationale for making donations. These records ordinarily prove that trustees and government officials took reasonable steps to ensure the charities receiving contributions and government grants were duly organized and lawfully operated.
Many important records not controlled by the Clintons--tens of thousands of pages, or more--are available in the public domain. I have been studying this body of information since February
2015.
What I shall start doing with this follow-up letter is pointing you to key subjects and documents, including items the Clintons and their allies have intentionally attempted to hide, and help you reach your own informed conclusions about the true Clinton Foundation record.
What Close Review of the Clinton Foundation Public Record Reveals
As you will soon establish for yourselves, not one of the many Clinton Foundation “charities”
has ever been lawfully constituted anywhere for more than an instant.
If our Internal Revenue Service were not captured by political partisans, charters to operate many
Clinton Foundation “tax-exempt” organizations would have been revoked years ago.
Donors who took deductions on federal tax returns for their contributions to Clinton Foundation entities would then be dunned for the tax benefits they received as well as for interest and
penalties.
The Internal Revenue Service would investigate U.S. charities identified as contributors to see how much money they gave to Clinton Foundation entities when these entities were not lawfully operated, and use discretion to assess appropriate penalties.
In addition, the Internal Revenue Service might conclude that Clinton Foundation entities were operating as taxable corporations rather than as tax-exempt charities.
In this event, the Internal Revenue Service would assess corporate income taxes, interest, and penalties back to whatever year they deemed each entity to have fallen afoul of applicable laws
and regulations.
The False Hope for Presidential Pardons
Though legal and financial downsides appear large, based on informed ongoing review of available records, the Clintons and their allies may believe they are protected in that either President Obama or Hillary Clinton (should she become the nominee and win the general
election) will issue blanket pardons.
Beyond the flaming political firestorms that surely would then ensue, there is a major problem with this kind of thinking--a U.S. president may only pardon federal crimes as I noted5 on 24
February 2016: “Key Finding #10: President Obama does not have Legal Authority to Issue Pardons for Most
Apparent Illegal Acts Involving Trustees, Executives, Agents, and Clinton Foundation Entities.The U.S. President’s pardon powers extend to federal crimes, and not to state crimes as the U.S. Department of Justice6 makes plain on its website:
“Does the President have authority to grant clemency for a state conviction?
No. The President’s clemency power is conferred by Article II, Section 2, Clause 1 of the Constitution of the
United States, which provides: “The President . . . shall have Power to grant Reprieves and Pardons for Offenses against the United States, except in Cases of Impeachment.” Thus, the President’s authority to
grant clemency is limited to federal offenses and offenses prosecuted by the United States Attorney for the District of Columbia in the name of the United States in the D.C. Superior Court. An offense that violates a state law is not an offense against the United States. A person who wishes to seek a pardon or a commutation of sentence for a state offense should contact the authorities of the state in which the conviction occurred. Such state authorities are typically the Governor or a state board of pardons and/or paroles, if the state
government has created such a board.”
Moreover, decisions to prosecute and/or to pardon crimes against foreign laws are the exclusive province of foreign governments, over which, in this case, the U.S.federal government may have only marginal
influence.”
Those who believe the Clintons and their co-conspirators have escape hatches in the form of
presidential pardons7 are mistaken.
Additional Pressure Points: State and Foreign Criminal Offenses
When I first studied public records pertaining to the Clinton Foundation, I concentrated upon their filings with the Internal Revenue Service8--though these filings remain materially false and misleading even after recent amendments9, it took me a while to realize important things.
U.S. states and foreign countries also have strict laws concerning operating and soliciting for charities that wish to offer their donors the benefit of making tax-deductible contributions. In most states and foreign countries, charities including the Clinton Foundation must make truthful
filings, many of which are readily accessible.
In the United States, states (and the District of Columbia) require charities to register before they solicit contributions, and to submit periodic reports--some of these filing requirements are easy
to satisfy while others are demanding.
In all cases, charities are required to provide complete and truthful disclosures, particularly
concerning trustees, executives and, in many cases, regarding “those who are in position to exercise significant influence”, whether or not they are named as trustees or executives.
In coming days, I will show in detail how Clinton Foundation entities submitted numerous false and materially misleading filings, or failed to submit disclosures to authorities within New York State and the State of Georgia, respectively. Infractions in both of these states (to name just two)
started in 2001 and continue to the present.
Please note that disclosure failures in a single state can queer registrations and reports in other states (and foreign countries), particularly when these failures are willful and persistent.
Outside the United States, there are wide variations in registration and annual filing
requirements.
Starting in 2001, Bill Clinton and, later, Ira Magaziner as well as others, held themselves out as acting in the name of the Clinton Foundation when these individuals were not trustees or
officers.
Only in-depth examination of board minutes and other nonpublic information will confirm what arrangements these individuals negotiated, and whether trustees acted responsibly to protect the
interests of the Clinton Foundation.
Numerous and substantial donations were solicited many places, inside and outside the United States, in theory, to pursue charitable good works in the name of the Clinton Foundation
internationally.
Yet, few of these international operations were registered, none of these international operations were effectively controlled from a U.S. base (as is strictly required under U.S. laws10), and no registration or annual report in any location concerning these operations accurately described the many disqualifying defects inherent in these arrangements and activities.
Like U.S. laws governing charities, foreign laws in many countries whose legal system is modeled on U.K.11 statutes and legal precedents are also strict--general principles include that organizations wishing to be deemed “tax-exempt” must pursue only purposes that actually are
“charitable” and that these organizations cannot be operated to create collective private gain.
Moreover, trustees, executives and related parties are forbidden to derive any private gains12.
Whether a charity is operating in compliance with law can be determined from the outside by looking at two main sources of information: (1) public filings and (2) independent certified financial audits that ordinarily serve as an outside check on submissions by charity trustees and
their executives.
As I shall continue to demonstrate in detail, federal, state, and foreign filings for the Clinton Foundation remain replete with errors and therefore are false and materially misleading.
Moreover, no Clinton Foundation entity ever procured a compliant financial audit, A Brief Comment on Clinton Foundation Use of “Expert” Opinions
When public concerns mount about the status of Clinton Foundation operations, the Clintons and their allies use a tactic perfected over decades--they obtain supposedly independent reports from experts, and characterize the results of these reports as exonerating most vexing issues.
In 2013, Bill Clinton13 and others described work by Simpson Thacher & Bartlett: and in 2015, Donna Shalala and others described work by DLA Piper14 and accounting firm CohnReznick as supporting the contention that Clinton Foundation entities were operated appropriately.
Each of these firms is staffed with professionals of the highest caliber, many of whom are experts on the subject of operating charities in compliance with state, federal, and foreign laws. However, the general public was never offered a view of the complete analysis performed by any
firm, So, because the Clinton Foundation has not seen fit to disclose, in particular, work performed by
CohnReznick, we are left to speculate how circumscribed their “independent” reviews may have
been.
To date, “independent” review of Clinton Foundation public disclosures has led to numerous
restatements and amendments of filings covering calendar years 2010 through 2013, inclusive.
That said, federal filings for the period 1997 through 2009, inclusive, have not, as yet been amended, nor has the Clinton Foundation seen fit to share state and foreign filings for any period
through their main website.
Set forth below are 40 topics dealing with the reporting period 1997 through 2010 that I believe experts likely did not consider in appropriate depth in the course of performing their work on behalf of Clinton Foundation entities and their trustees. Selected Topics to be Covered in Detail in Forthcoming Exhibits
Exhibit Topic 1 Fundraising Activities in the Name of the Clinton Foundation--October 1997 through January 2001
2 Fundraising Activities in the Name of the Clinton Foundation for the William J. Clinton Peace Centre
in Enniskillen, Northern Ireland, Starting After 1998
3 Undisclosed Administrative Proceedings Against Persons Who Exercised Significant Influence Over
Clinton Foundation Activities
4 Fundraising Activities in the Name of the Clinton Foundation for the William J. Clinton Scholars Program at American University in Dubai, Starting After 2000
5 Undisclosed Activities in the Name of American india Foundation Allegedly Providing Earthquake
Relief in Gujarat, India Starting in January 2001 6 Undisclosed Activities Working With MindSpirit LLC, Rajat Gupta, and InfoUSA After January 2001
7 Undisclosed Activities Organizing, Helping to Operate, and Fundraising for International AIDS Trust
Starting Around January 2001
8 Undisclosed Activities in the Name of the Clinton Foundation Allegedly Fighting HIV/AIDS
Internationally Starting in July 2002 9 Undisclosed Activities Working With Ron Burkle and Yucaipa Companies Starting in 2002
10 False and Materially Misleading Organization and Operation of Clinton Foundation HIV/AIDS
Initiative, Inc. (“Old CHAI”), Starting in March 2004
11 Submission of False and Materially Misleading Disclosures to Government Authorities Concerning
2003 and Prior Years
12 False and Materially Misleading Accounting for Construction of the Presidential Library and for a Donation to the National Archives and Records Administration on 18 November 2004
13 False and Materially Misleading Accounting for Loans Secured During 2004 to Fund Construction of
the Little Rock, Arkansas Complex
14 Illegal Operation and False, Materially Misleading Disclosures Concerning Old CHAI During 2005
15 Fundraising Operations in the Name of the Clinton Foundation Allegedly Providing Tsunami Relief,
Starting in January 2005
Selected Topics to be Covered in Detail in Forthcoming Exhibits (Continued)
Exhibit Topic 16 Unauthorized and Illegal Operation of Alliance for a Healthier Generation Starting in May 2005 17 Unauthorized and Illegal Operation of Bush Clinton Katrina Fund Starting in August 2005 18 Unauthorized and Illegal Operation of Clinton Global Initiative Starting by September 2005
19 Submission of False and Materially Misleading Disclosures to Government Authorities Concerning
2004 and Prior Years
20 Arrangement of “Sham” Merger of Old CHAI into the Clinton Foundation Effective 31 December
2005
21 Unauthorized and Illegal Operation of Clinton Hunter Development Initiative, Starting in 2006 22 Unauthorized and Illegal Operation of Clinton Climate Initiative Starting in August 2006 23 Deceptive Procurement of Strategic Partnership with UNITAID by September 2006
24 Submission of False and Materially Misleading Disclosures to Government Authorities Concerning
2005 and Prior Years
25 Unauthorized and Illegal Operation of Clinton-Giustra Sustainable Growth Initiative, Starting in June
2007
26 Unauthorized and Illegal Operation of William J. Clinton Foundation UK, Starting in July 2007
27 Submission of False and Materially Misleading Disclosures to Government Authorities Concerning
2006 and Prior Years
28 Unauthorized and Illegal Operation of Gulf Coast Recovery Fund Starting September 2008
29 Deceptive Procurement of a Memorandum of Understanding with President Obama’s Transition Team
Starting in November 2008
30 Submission of False and Materially Misleading Disclosures to Government Authorities Concerning
2007 and Prior Years
31 Unauthorized and Illegal Operation of William J. Clinton Foundation Corporation (Florida) starting in
June 2009
32 Unauthorized and Illegal Operation of Clinton Global Initiative, Inc. Starting in September 2009
33 Unauthorized and Illegal Operation of Clinton Health Access Initiative, Inc. Starting in September
2009
34 Submission of False and Materially Misleading Disclosures to Government Authorities Concerning
2008 and Prior Years
35 Unauthorized and Illegal Operation of Clinton Bush Haiti Fund Starting in January 2010
36 Unauthorized and Illegal Operation of Alliance for a Healthier Generation, Inc. Starting in February
2010
37 Undisclosed Activities Working With Laureate Education Inc, Starting in 2010
38 Submission of False and Materially Misleading Disclosures to Government Authorities Concerning
2009 and Prior Years
39 Unauthorized and Illegal Operation of Clinton Health Access Initiative-UK Starting in November
2011
40 Submission of False and Materially Misleading Disclosures to Government Authorities Concerning
2010 and Prior Years
Each of the topics mentioned above affects financial and operating results reported for calendar years 2011, 2012, 2013, 2014 that now are on file and in the public domain--after I complete the process of sharing and explaining Exhibits 1 through 40 above, I will move on to consideration
of subsequent years.
As you will soon discover, information in the Exhibits draws chiefly on publicly available
information and is extensive.
Rather than publish hundreds of pages at once, I decided to release the analysis in smaller, “bite-size” chunks, so that you will have a chance to absorb the material, check it for yourselves, and
then reach your own conclusions. In addition to the above-mentioned materials, I also will publish a series of supporting Appendices containing links to helpful background material intermittently through the process of
releasing the Exhibits.
Thank you for your interest and support.
Sincerely,
Charles
http://charlesortel.com/
Follow-up Letter to Donors, Charity Regulators, Investigative Journalists and
Citizens Worldwide
2 May 2016
Dear Friends,
First, a thank you to Kathleen Willey, Clarice Feldman, and Thomas Lifson1 for bringing
attention to yesterday’s letter.
Interest is finally building in piercing smokescreens that Clinton family members and allies still attempt to spread, claiming that a 20 year pattern of escalating, cross border abuses involving the Bill, Hillary, and Chelsea Clinton Foundation and multiple affiliated “charities” is a
“nothingburger”2.
For example, few who are even modestly familiar with applicable charity laws believe Bill
Clinton’s latest false assertion3 that investigation into the private email server is merely “a game”--as he will soon discover, the “email scandal” is part of much larger “records scandal”
over which he has little control4.
Major donors to charities are required under various laws to retain records that demonstrate the rationale for making donations. These records ordinarily prove that trustees and government officials took reasonable steps to ensure the charities receiving contributions and government grants were duly organized and lawfully operated.
Many important records not controlled by the Clintons--tens of thousands of pages, or more--are available in the public domain. I have been studying this body of information since February
2015.
What I shall start doing with this follow-up letter is pointing you to key subjects and documents, including items the Clintons and their allies have intentionally attempted to hide, and help you reach your own informed conclusions about the true Clinton Foundation record.
What Close Review of the Clinton Foundation Public Record Reveals
As you will soon establish for yourselves, not one of the many Clinton Foundation “charities”
has ever been lawfully constituted anywhere for more than an instant.
If our Internal Revenue Service were not captured by political partisans, charters to operate many
Clinton Foundation “tax-exempt” organizations would have been revoked years ago.
Donors who took deductions on federal tax returns for their contributions to Clinton Foundation entities would then be dunned for the tax benefits they received as well as for interest and
penalties.
The Internal Revenue Service would investigate U.S. charities identified as contributors to see how much money they gave to Clinton Foundation entities when these entities were not lawfully operated, and use discretion to assess appropriate penalties.
In addition, the Internal Revenue Service might conclude that Clinton Foundation entities were operating as taxable corporations rather than as tax-exempt charities.
In this event, the Internal Revenue Service would assess corporate income taxes, interest, and penalties back to whatever year they deemed each entity to have fallen afoul of applicable laws
and regulations.
The False Hope for Presidential Pardons
Though legal and financial downsides appear large, based on informed ongoing review of available records, the Clintons and their allies may believe they are protected in that either President Obama or Hillary Clinton (should she become the nominee and win the general
election) will issue blanket pardons.
Beyond the flaming political firestorms that surely would then ensue, there is a major problem with this kind of thinking--a U.S. president may only pardon federal crimes as I noted5 on 24
February 2016: “Key Finding #10: President Obama does not have Legal Authority to Issue Pardons for Most
Apparent Illegal Acts Involving Trustees, Executives, Agents, and Clinton Foundation Entities.The U.S. President’s pardon powers extend to federal crimes, and not to state crimes as the U.S. Department of Justice6 makes plain on its website:
“Does the President have authority to grant clemency for a state conviction?
No. The President’s clemency power is conferred by Article II, Section 2, Clause 1 of the Constitution of the
United States, which provides: “The President . . . shall have Power to grant Reprieves and Pardons for Offenses against the United States, except in Cases of Impeachment.” Thus, the President’s authority to
grant clemency is limited to federal offenses and offenses prosecuted by the United States Attorney for the District of Columbia in the name of the United States in the D.C. Superior Court. An offense that violates a state law is not an offense against the United States. A person who wishes to seek a pardon or a commutation of sentence for a state offense should contact the authorities of the state in which the conviction occurred. Such state authorities are typically the Governor or a state board of pardons and/or paroles, if the state
government has created such a board.”
Moreover, decisions to prosecute and/or to pardon crimes against foreign laws are the exclusive province of foreign governments, over which, in this case, the U.S.federal government may have only marginal
influence.”
Those who believe the Clintons and their co-conspirators have escape hatches in the form of
presidential pardons7 are mistaken.
Additional Pressure Points: State and Foreign Criminal Offenses
When I first studied public records pertaining to the Clinton Foundation, I concentrated upon their filings with the Internal Revenue Service8--though these filings remain materially false and misleading even after recent amendments9, it took me a while to realize important things.
U.S. states and foreign countries also have strict laws concerning operating and soliciting for charities that wish to offer their donors the benefit of making tax-deductible contributions. In most states and foreign countries, charities including the Clinton Foundation must make truthful
filings, many of which are readily accessible.
In the United States, states (and the District of Columbia) require charities to register before they solicit contributions, and to submit periodic reports--some of these filing requirements are easy
to satisfy while others are demanding.
In all cases, charities are required to provide complete and truthful disclosures, particularly
concerning trustees, executives and, in many cases, regarding “those who are in position to exercise significant influence”, whether or not they are named as trustees or executives.
In coming days, I will show in detail how Clinton Foundation entities submitted numerous false and materially misleading filings, or failed to submit disclosures to authorities within New York State and the State of Georgia, respectively. Infractions in both of these states (to name just two)
started in 2001 and continue to the present.
Please note that disclosure failures in a single state can queer registrations and reports in other states (and foreign countries), particularly when these failures are willful and persistent.
Outside the United States, there are wide variations in registration and annual filing
requirements.
Starting in 2001, Bill Clinton and, later, Ira Magaziner as well as others, held themselves out as acting in the name of the Clinton Foundation when these individuals were not trustees or
officers.
Only in-depth examination of board minutes and other nonpublic information will confirm what arrangements these individuals negotiated, and whether trustees acted responsibly to protect the
interests of the Clinton Foundation.
Numerous and substantial donations were solicited many places, inside and outside the United States, in theory, to pursue charitable good works in the name of the Clinton Foundation
internationally.
Yet, few of these international operations were registered, none of these international operations were effectively controlled from a U.S. base (as is strictly required under U.S. laws10), and no registration or annual report in any location concerning these operations accurately described the many disqualifying defects inherent in these arrangements and activities.
Like U.S. laws governing charities, foreign laws in many countries whose legal system is modeled on U.K.11 statutes and legal precedents are also strict--general principles include that organizations wishing to be deemed “tax-exempt” must pursue only purposes that actually are
“charitable” and that these organizations cannot be operated to create collective private gain.
Moreover, trustees, executives and related parties are forbidden to derive any private gains12.
Whether a charity is operating in compliance with law can be determined from the outside by looking at two main sources of information: (1) public filings and (2) independent certified financial audits that ordinarily serve as an outside check on submissions by charity trustees and
their executives.
As I shall continue to demonstrate in detail, federal, state, and foreign filings for the Clinton Foundation remain replete with errors and therefore are false and materially misleading.
Moreover, no Clinton Foundation entity ever procured a compliant financial audit, A Brief Comment on Clinton Foundation Use of “Expert” Opinions
When public concerns mount about the status of Clinton Foundation operations, the Clintons and their allies use a tactic perfected over decades--they obtain supposedly independent reports from experts, and characterize the results of these reports as exonerating most vexing issues.
In 2013, Bill Clinton13 and others described work by Simpson Thacher & Bartlett: and in 2015, Donna Shalala and others described work by DLA Piper14 and accounting firm CohnReznick as supporting the contention that Clinton Foundation entities were operated appropriately.
Each of these firms is staffed with professionals of the highest caliber, many of whom are experts on the subject of operating charities in compliance with state, federal, and foreign laws. However, the general public was never offered a view of the complete analysis performed by any
firm, So, because the Clinton Foundation has not seen fit to disclose, in particular, work performed by
CohnReznick, we are left to speculate how circumscribed their “independent” reviews may have
been.
To date, “independent” review of Clinton Foundation public disclosures has led to numerous
restatements and amendments of filings covering calendar years 2010 through 2013, inclusive.
That said, federal filings for the period 1997 through 2009, inclusive, have not, as yet been amended, nor has the Clinton Foundation seen fit to share state and foreign filings for any period
through their main website.
Set forth below are 40 topics dealing with the reporting period 1997 through 2010 that I believe experts likely did not consider in appropriate depth in the course of performing their work on behalf of Clinton Foundation entities and their trustees. Selected Topics to be Covered in Detail in Forthcoming Exhibits
Exhibit Topic 1 Fundraising Activities in the Name of the Clinton Foundation--October 1997 through January 2001
2 Fundraising Activities in the Name of the Clinton Foundation for the William J. Clinton Peace Centre
in Enniskillen, Northern Ireland, Starting After 1998
3 Undisclosed Administrative Proceedings Against Persons Who Exercised Significant Influence Over
Clinton Foundation Activities
4 Fundraising Activities in the Name of the Clinton Foundation for the William J. Clinton Scholars Program at American University in Dubai, Starting After 2000
5 Undisclosed Activities in the Name of American india Foundation Allegedly Providing Earthquake
Relief in Gujarat, India Starting in January 2001 6 Undisclosed Activities Working With MindSpirit LLC, Rajat Gupta, and InfoUSA After January 2001
7 Undisclosed Activities Organizing, Helping to Operate, and Fundraising for International AIDS Trust
Starting Around January 2001
8 Undisclosed Activities in the Name of the Clinton Foundation Allegedly Fighting HIV/AIDS
Internationally Starting in July 2002 9 Undisclosed Activities Working With Ron Burkle and Yucaipa Companies Starting in 2002
10 False and Materially Misleading Organization and Operation of Clinton Foundation HIV/AIDS
Initiative, Inc. (“Old CHAI”), Starting in March 2004
11 Submission of False and Materially Misleading Disclosures to Government Authorities Concerning
2003 and Prior Years
12 False and Materially Misleading Accounting for Construction of the Presidential Library and for a Donation to the National Archives and Records Administration on 18 November 2004
13 False and Materially Misleading Accounting for Loans Secured During 2004 to Fund Construction of
the Little Rock, Arkansas Complex
14 Illegal Operation and False, Materially Misleading Disclosures Concerning Old CHAI During 2005
15 Fundraising Operations in the Name of the Clinton Foundation Allegedly Providing Tsunami Relief,
Starting in January 2005
Selected Topics to be Covered in Detail in Forthcoming Exhibits (Continued)
Exhibit Topic 16 Unauthorized and Illegal Operation of Alliance for a Healthier Generation Starting in May 2005 17 Unauthorized and Illegal Operation of Bush Clinton Katrina Fund Starting in August 2005 18 Unauthorized and Illegal Operation of Clinton Global Initiative Starting by September 2005
19 Submission of False and Materially Misleading Disclosures to Government Authorities Concerning
2004 and Prior Years
20 Arrangement of “Sham” Merger of Old CHAI into the Clinton Foundation Effective 31 December
2005
21 Unauthorized and Illegal Operation of Clinton Hunter Development Initiative, Starting in 2006 22 Unauthorized and Illegal Operation of Clinton Climate Initiative Starting in August 2006 23 Deceptive Procurement of Strategic Partnership with UNITAID by September 2006
24 Submission of False and Materially Misleading Disclosures to Government Authorities Concerning
2005 and Prior Years
25 Unauthorized and Illegal Operation of Clinton-Giustra Sustainable Growth Initiative, Starting in June
2007
26 Unauthorized and Illegal Operation of William J. Clinton Foundation UK, Starting in July 2007
27 Submission of False and Materially Misleading Disclosures to Government Authorities Concerning
2006 and Prior Years
28 Unauthorized and Illegal Operation of Gulf Coast Recovery Fund Starting September 2008
29 Deceptive Procurement of a Memorandum of Understanding with President Obama’s Transition Team
Starting in November 2008
30 Submission of False and Materially Misleading Disclosures to Government Authorities Concerning
2007 and Prior Years
31 Unauthorized and Illegal Operation of William J. Clinton Foundation Corporation (Florida) starting in
June 2009
32 Unauthorized and Illegal Operation of Clinton Global Initiative, Inc. Starting in September 2009
33 Unauthorized and Illegal Operation of Clinton Health Access Initiative, Inc. Starting in September
2009
34 Submission of False and Materially Misleading Disclosures to Government Authorities Concerning
2008 and Prior Years
35 Unauthorized and Illegal Operation of Clinton Bush Haiti Fund Starting in January 2010
36 Unauthorized and Illegal Operation of Alliance for a Healthier Generation, Inc. Starting in February
2010
37 Undisclosed Activities Working With Laureate Education Inc, Starting in 2010
38 Submission of False and Materially Misleading Disclosures to Government Authorities Concerning
2009 and Prior Years
39 Unauthorized and Illegal Operation of Clinton Health Access Initiative-UK Starting in November
2011
40 Submission of False and Materially Misleading Disclosures to Government Authorities Concerning
2010 and Prior Years
Each of the topics mentioned above affects financial and operating results reported for calendar years 2011, 2012, 2013, 2014 that now are on file and in the public domain--after I complete the process of sharing and explaining Exhibits 1 through 40 above, I will move on to consideration
of subsequent years.
As you will soon discover, information in the Exhibits draws chiefly on publicly available
information and is extensive.
Rather than publish hundreds of pages at once, I decided to release the analysis in smaller, “bite-size” chunks, so that you will have a chance to absorb the material, check it for yourselves, and
then reach your own conclusions. In addition to the above-mentioned materials, I also will publish a series of supporting Appendices containing links to helpful background material intermittently through the process of
releasing the Exhibits.
Thank you for your interest and support.
Sincerely,
Charles