Election Databases Expose Extent of Trump-Bondi Connection, Updated With More Details

Republican presidential nominee Donald Trump walks in the rain with Florida Attorney General Pam Bondi, as he arrives at a ca
Republican presidential nominee Donald Trump walks in the rain with Florida Attorney General Pam Bondi, as he arrives at a campaign rally in Tampa on Aug. 24.

Surprises from deep dives in the databases, updated 09/24/16 for Iowa addition, 12/18/16 with more details.

Donald Trump surely* got early warning of New York Attorney General(AG) Eric Schneiderman’s 08/24/13 lawsuit against Trump University. Donald acted decisively following a long-established pattern of political contributions. He rapidly wrote hopeful “pay-to-play” checks to 7 politicians in 4 states where people had complained. Four checks were recorded on the same day, 07/15/13 and the others within 7 weeks.

The 7 recipients were Florida AG Pam Bondi, Texas AG Greg Abbott, Iowa Governor Terry Branstad and in New York, a District Attorney and 3 otjher Supreme Court Justices before Cynthia Kern was named. Table 1 records all relevant state contributions by Donald and Ivanka Trump. It exposes key transactions and events, but also highlights expected events that did not occur, as with Sherlock Holmes’ “The dog that didn’t bark in the night.” Of the 7 recipients, only the NY DA had received Trump contributions before. The other 6 were “new,” knowable only by checking the earlier records and not finding them there.

CA AG Kamala Harris was sent 3 donations during 2011-2014, but their timing seemed more related to the CA class action lawsuits initiated in 2011 and 2013, presumably trying to avoid CA AG participation The rapid timing of donations to FL, IA and TX indicates defensive measures against involvement with the NY AG case, which included complainants from all these states. Trump had already failed to deter the NY AG, so perhaps had to try the judges. While any single donation might have been innocent, the overall pattern was clear, by timing and selection of recipient in states with many and/or especially-vocal complainants. Donald has had vast experience with regular lawsuits, but would plausibly worry much more about serious AG investigations.

Recipients may have been surprised, paid little attention or donated money elsewhere, but Bondi called Trump. She seemed to leverage the implicit opportunity, not for small short-term funding, but to gain Trumps’ help in boosting her fundraising profile in the Florida Republican Party. More research exposed parts of the complex money maze shown in Figure 2.

After the NY AG’s filing. on 08/29/13 Florida newspapers contacted Bondi’s office about long-festering Floridian complaints, some inherited from the previous AG Bill McCollum, who Donald had previously funded, unlike Bondi. Starting 09/13 papers published articles on the continuing lack of action. By mid-October, Orlando Sentinel reporter Matthew Scott noticed that a Bondi group had received $25K from Donald 09/17. No action was taken by Bondi’s office despite intense media pressure.

Bondi said she had called Donald to solicit funds, but would not say exactly when. Donald’s check was printed Monday 09/09, recorded by Bondi’s group 09/17. Meanwhile, on 09/10, Bondi’s campaign recorded $500 from Ivanka, her first-ever state political donation in Florida, likely sent a few days earlier. Ivanka also donated to CA AG Harris in 2014. She was clearly involved in Trump University, as p.29 of NY AG document #1 says:

143. The sole signatories of the bank accounts of Trump University are Donald Trump himself, his three adult children, and Allen Weisselberg, Trump Organization's chief financial officer. None of these signatories were ever employees of Trump University LLC.

Donald’s story about clerical errors in check handling argues this was done in haste. How did Ivanka get involved? Does the same clerk handle Ivanka’s checks? Who is the clerk? Are these personal donations or really Trump Organization donations?

Bondi did not need $25K. Her campaign outraised her opponent 4:1, $3,752K to $949K. Donald’s $25K passed through several intermediate groups before landing in the Republican Party a year later. So, why?

Aspiring politicians need to prove they can raise money not just for themselves. It seems she added $430K to the Republican Party coffers, a real plus.

The NY lawsuit was in the news in New York and Florida. July’s events showed Trump was intensely aware of it. Bondi had no need to mention that explicitly. She might have said something like: I’m running for AG re-election, but thinking about the 2018 Gubernatorial race. You can increase your Florida influence by donating through key political groups I know, perhaps host key fund-raisers at Mar-a-Lago. We really should do more together.

That well describes later events. Through YE2014, the Trumps then donated $186K, compared to Donald’s $119K 2000-June 2013. Support included the high-profile fundraiser at Mar-a-Lago 03/14/14, whose In-Kind value is unclear, but might well exceed $100K, but the exposure for an ambitious politician was priceless. The $25K seems merely an “earnest money” deposit, paid in a hurry,

Rick Scott’s 2014 campaign for Governor raised $19,926K, so Bondi needed help to rise to that league. Given the intense criticism, it is surprising that she long refused to return the $25K, but maybe there is more to the story, yet to be discovered.

Review of background and press coverage

Long before Trump cash, Bondi showed no interest in complaints against seminars appeared 09/17/16 in the Tampa Bay Times. It (10/17/13, 09/08/16, 09/09/16) the Orlando Sentinel (09/13/13 and especially Scott Maxwelll’s 10/15/13, 09/06/16, 09/07/16, ) and the Miami Herald ( 10/17/13, 09/06/16, 09/13/16) have expressed concern over potential Bondi corruption or at least lack of attention to Floridians’ needs, compared to fundraising and participation in national lawsuits.

But the Trump-Bondi connection gained little national attention until David Fahrenthold’s investigation of the Donald J Trump Foundation publicized his illegal use of a Foundation check. That may well have been an innocent, if incompetent mistake. That matters less than the much larger potential corruption case, which does not depend on the funding sources, but involves Bondi plus both Donald and Ivanka. Their donations in Table 1 always label them as individual donors, not the Trump Organization.

In early 2015, Names emerging for 2018 governor’s race, highlighted Bondi, noting her fundraising. Now, Florida Newspapers Call For Investigation Of Trump-Bondi Connection (09/09/16). Experienced lawyer Dan Gelber argued strongly that Bondi needed to return the Trump donation.

How Donald Trump Bought, Squabbled And Sued His Way To Becoming A Force In Florida explains that history, with many examples of his tactics.

Political contributions, evidence from across the USA

Evidence emerged from wide searches of the Trumps’ state contribution records. Table 1 shows all results found for Florida, California, Illinois, Iowa and Texas, plus relevant New York recipients, with cross-checks via FollowTheMoney. These established clear behavioral patterns and key dates. Ivanka’s rare donations usually followed Donald’s lead, but the unexpected donations in Florida were key indicators of Donald’s intense focus on the problem.

They generally gave to locally-dominant parties, Republican (FL, TX) or Democrat (CA, Il, NY), but sometimes to competing candidates, followed by more to winners. That is not ideological funding, but business-style anticipatory pay-to-play, which may or may not have real benefits. For example, Trump gave to Schneiderman, but later called him a lightweight hack, and sued. His Foundation donated $100K to Citizens United, which unsuccessfully sued the AG.

Election records just show contributions, but allegations of wrongdoing require more. Good politicians avoid obvious conflicts of interest and no impropriety is alleged here against any politician but Bondi.

For example, some have speculated that the money to Greg Abbott was payoff for handling of earlier complaints, but the timing contradicts that, both in years’ delay, and in the July 2013 pattern. Donald was often willing to make anticipatory gifts as hopeful insurance, even in a state where he had never given before. It seems far more likely that he was worried that the NY AG effort would spread to TX.

Bondi’s groups - campaign, JFA, AJFA

Many articles confused Bondi’s own 3 groups. Pam Bondi for Attorney General (website), was her campaign committee, from 07/01/13 and on 07/15 received Donald’s $500 (the maximum). Its formation was followed on 08/16 by both Justice For All (JFA) and And Justice For All (AJFA), which thus did not exist when Donald first donated. It takes effort to identify their association with Bondi, but easy to find if she simply told Donald.

All shared the same Treasurer, Nancy Watkins of Tampa, also Treasurer for the PAC Innovate Florida, noticed only because Donald later donated. She is or has been Treasurer of 130+ such groups, search Watkins, Treasurer.

JFA is a Political Committee (PC or commonly PAC), but AJFA is an Electioneering Communication Organization(ECO). The organization types are explained Florida’s 2016 Handbooks: Candidate & Campaign Treasurer, and Political Committee (PC or PAC), Electioneering Communications Organization (ECO), whose pp.28-32 summarize the PC/ECO differences. Figure 1 below is p.32 annotated.

It seems to imply that ECOs cannot give money to PCs, but AJFA disbanded and left most of its funds to JFA. Other examples were found in the (thankfully well-designed, speedy) Florida database. In particular Rick Scott used a similar ECO / PAC pair, both called “Let’s Get to Work”. The ECO raised $49,279K, then transferred $27,395K to the PAC and shut down, leading to a complaint by the head of the Florida Democratic Party.

Perhaps this is lack of understanding on my part, but it seems odd that an ECO’s restrictions can be nullified by disbanding and passing most of the money to a PC, which can use it in ways forbidden to the ECO.

Bondi has Chaired other groups that have provided funding, RSLC and RAGA, described later.

Figure 1 - Differences between PC and ECO
Figure 1 - Differences between PC and ECO

Figure 2 is a timeline of money flows, communications and other events, necessarily complex, although likely just a fraction of Florida’s money maze. Direct contributions to campaigns are obvious, but others are not.

Donald’s $25K was sent to (1) AJFA, which kept it for a year, then sent most to (2) JFA, which then donated it to (3) the Republican Party, which either (4) spent it on In-Kind (INK) donations to Bondi’s campaign, or used it elsewhere.

The Party gave her campaign $1,452K in INK contributions, but she paid $107K, yielding a net direct cost of $1,345K, but JFA gave $1,640K to the Party, the Trumps gave $125K directly and perhaps $10K through Innovate Florida, for a rough total of $1,775K influenced by Bondi. As best as can be seen, the Party gained $430K.

Figure 2 is followed by detailed explanations in chronological order.

Figure 2 - Trump money and Bondi's money maze
Figure 2 - Trump money and Bondi's money maze

Phase 1 - pre-07/14/13 Donald gave $119K, most to GOVs & AGs, but nothing to Bondi.

01/03/06 , 10/28/06, 11/01/06 Donald gave $500 each to AG competitors, Walter “Skip” Campbell(D) and Bill McCollum(R), followed by $1,000 to McCollum’s ECO, Citizens Speaking Out Committee. McCollum won.

01/31/10 Mar-a-Lago hosted fundraiser for McCollum, then AG running for GOV, who lost the primary to Rick Scott. McCollum’s campaign spent $6,390 for $500/plate dinner. Bondi’s 2014 dinner was $3,000/plate.

11/02/10 Bondi was elected AG, raised $2,593K including $890K from Republican Party, but zero from the Trumps, odd given pervasive attention to AGs in various states. Donald gave $10K to the Party after the election. She is often portrayed as an old friend, but pre-2013 interactions with Trump seem hard to find in public records.

05/23/13 Pam Bondi Helping Lead New GOP Women’s Group and Pam Bondi, Lizbeth Benacquisto Selected for National GOP Leadership Roles explained that she was Co-Chairing the Right Women Right Now(RWRN) effort of the Republican State Leadership Committee (RSLC), to get more Republican women elected to state offices. Of the $1,545K it raised and distributed, $650K (42%) went to AJFA and JFA, and then got sent to the Party.

Phase 2- 07/15/13-09/17/13 Donald reacted quickly. After publicity, Bondi called

07/15/13 (Monday) Donald’s contributions were recorded by 3 new recipients, Bondi’s campaign ($500, the limit), NY Supreme Court Justices John Sweeny, Jr ($5K) and Mark Dillon ($5K), plus the only previous recipient, NY District Attorney Kathleen Rice ($600). Neither JFA nor AJFA existed at that time.

Did Trump learn of AG Schneiderman’s forthcoming lawsuit the week before and start writing checks? It is hard to imagine even these 4 a coincidence, but 2 more followed.

07/20/13 Texas AG Greg Abbott recorded $25K from Donald, his first-ever gift to a candidate in the Texas state database, followed later by $10K on 05/02/14. This seems a precaution in one of the large states with complainants, but unlike the others, not one where Donald has major developments.

08/06/13 Nancy Watkins formed And Justice For All (AJFA) and Justice For All (JFA).

08/09/13 NY Supreme Court Justice Daniel Angiolillo recorded $5K from Donald.

Including earlier entries in Table 1, Donald had now contributed to AGs in CA, FL and TX, plus 3 Justices and DA in NY, where he was feuding intensely with the AG.

08/24/13 Schneiderman filed the lawsuit, but Donald surely knew of it a month earlier. NY’s WebCivil Supreme lists the eFiled Documents for the case. Especially instructive are #1 (39p original filing) and #18 (4p Asst. AG Tristan Snell’s argument against delays, which notes that the respondents knew in January 2013 that there would be a filing unless the issue was resolved. Finally #10 is the 380p collection of affidavits by complainants from NY and other states. It is painful reading.

08/29/13 The Orlando Sentinel asked Bondi spokesperson Jennifer Meale about Florida complaints (NYTimes)

09/03/13 Donald donated $15K to Iowa Governor Terry Branstad(R), but nothing to long-serving AG Tom Miller(D), who had received at least one complaint found in the NY AG’s filing.

09/09/13 (Monday) Trump signed a $25K check from the Donald Trump Foundation to AJFA. Of course, this was an illegal donation through the Foundation, and that may have been mere incompetence. If the donation was intended to avoid prosecution, it is a serious problem regardless of the funding source.

09/10/13 Bondi’s campaign recorded a $500 contribution from Ivanka, her first ever in Florida. Would anyone believe this to be coincidental? Why did Donald think it worthwhile to involve her in this messy affair for $500?

09/11/13 A Bondi spokesperson responded to press inquiries, saying they had been reviewing the NY case and past FL complaints.

“In the weeks after the initial September 2013 article in The Sentinel, Ms. Bondi received daily emails from her staff to her personal Yahoo address with news reports about the Trump case. By mid-October, Scott Maxwell, a columnist for The Sentinel, had spotted Mr. Trump’s $25,000 donation in public filings and wrote that it smelled “awfully fishy.” His column set off days of critical coverage. “

Maxwell’s recent Bondi says Hillary Clinton 'bullied' her: Here are the facts gives details and says: “She personally asked Trump for the donation weeks before the Sentinel story ran.” See also this article.

09/17/13 Trump’s $25K was recorded at AJFA. Was the experienced Watkins unsurprised to receive an (illegal) contribution from a foundation, the only such in its list? Perhaps it burnished Bondi’s reputation for recruiting contributors, as seen next. Donald could have given to the Republican Party, RSLC, RAGA, Innovate Florida, or even JFA, but for some reason Bondi specified AJFA.

According to CBS News 09/16/16, “Garten said the series of errors began after Trump instructed his staff to cut a $25,000 check to the political committee supporting Bondi, called And Justice for All. Someone in Trump’s accounting department then consulted a master list of charitable organizations...”

This hints at hurried incompetence at best, but raises another issue. Checks might be written for (1) Donald himself, (2) Trump Foundation OR (3) perhaps Trump Organization, which seems to employ the (unnamed) clerk. Donalds numerous political contributions all seem to come from (1), but is that money separate from (3)?

Perhaps a coincicdence, this contribution almost seemed to trigger the next.

Phase 3 - 09/23/13-12/31/14 Trump helps Bondi raise her profile

09/23/13, 12/12/13, 01/28/14 A few days later, AJFA got $500K from the Republican State Leadership Committee - Florida PAC (RSLC), located in Washington, DC, Chaired by Bondi from 05/23/13. It repeatedly failed to file and paid fines. RSLC later sent $50K and $100K to JFA.

RSLC distributed 100% of its $1,545K contributions, $600K (39%) to the Republican Party of Florida, $500K (32%) to AJFA, and $150K (10%) to JFA, plus $195K to other Republican PACs. Most AJFA money later went to JFA and then to the Party. Perhaps these extra steps made sure Bondi got “credit”?

An old game’s “You Are In a Maze of Twisty Little Passages, All Alike” aptly describes the funding flows around Bondi, even those already known.

10/17/13 Bondi spokesperson Jennifer Meale told press that Florida was not pursuing complaints, as seen in The Tampa Bay Times’ Trump contribution to Pam Bondi's re-election draws more scrutiny to her fundraising.

“ Unlike New York, Florida has taken no action against Trump. Bondi couldn’t be reached for comment. Jenn Meale, a Bondi spokeswoman, suggested no action is necessary because the affected Florida consumers would be compensated if Schneiderman wins that case.”

03/14/14 The Republican Party paid $4.9K for a Bondi fundraiser at Mar-a-Lago, far less than Trump charged his own campaign, so it might be an unreported In-Kind (INK) donation. This was supposed to be 50 people at $3K/person, and there are many $3K contributions that day and the days before.

07/23/14, 07/31/14, 08/04/14 The Republican Party recorded Ivanka’s $25K, her only contribution to it, then $75K and $25K from Donald. This $125K burst exceeded all Trump contributions June 2000-June 2013.

08/07/14 JFA received $881K from AJFA, which had raised $1,028K, spent some, then disbanded 07/25/14.

09/08/14, 10/06/14 Donald gave $10K to Republican Attorneys General Association (RAGA), which sent $100K to the Party. Bondi had been involved already, but then was elected Chair around 11/17/14.

09/23/14, 09/28/14 Innovate Florida (PAC) recorded $10K from Donald, of the $1.9M it collected through YE2014, sent $100K to the Republican Party and money to many other PACs. Nancy Watkins is Treasurer.

09/17/14, 10/06/14, 10/17/14 JFA sent $1,000K to the Republican Party, received $100K from RAGA (Bondi Chair), and sent another $640K to the Party. Of $1,877K raised through YE2014, 87% went to the Party.

11/04/14 Pam Bondi was reelected AG over George Sheldon, 55% to 42% and outraised him $3,752K to $949K. She did not need the $25K from Trump, but the later contributions were helpful. Although the maze is obscure, it seems she added ~$430K to the Party’s coffers, as well as getting Donald more heavily involved.

Despite the challenges, at least modern election databases can be used to find obscure details. Fortunately, Florida’s is better than average. It is well-organized, responds quickly and offers flexible search queries.

California donations likely correlated with class actions, not NY AG case

Donald made 2 donations to CA AG Kamala Harris in 2011 and 2013, then Ivanka followed in 2014. These became issues for the 2016 election, although Harris had donated the money to charity. The 3 donations seem to correlate with discovery events in CA class action lawsuits (Makeff(Low) in 2011 and 2013, Cohen in 2014), but nothing is provable. These cases generated many events, including numerous delaying tactics.

Postscript and miscellaneous notes

All 3 children offered testimonials for the New York Real Estate Institute (NYREI), which hired Trump University instructor Stephen Gilpin, instructively interviewed here. His name appeared 80+ times in the NY AG complaint.

In 2012, a for-profit called the New York Real Estate Institute gave Trump’s foundation $10,000 just as it was launching a seminar taught by a Trump Entrepreneur Initiative teacher, Stephen Gilpin. Trump himself plugs Gilpin in a quote on the course’s webpage. Two of his children, Ivanka Trump and Donald Trump Jr., also provide the institute with glowing “testimonials” atop its homepage. A year after its first donation, the institute’s president, Richard Levine, appears to have personally donated another $10,000 to Trump’s foundation. Levine did not reply to multiple emails seeking confirmation of the donation details and a comment about the gifts.

J. Whitfield Larrabee filed several complaints, 06/29/16 (bribery) and 09/07/16 (violation of elections law), plus more described here.

11/18/16 Trump settled for $25M, or about 5X more than the $5M profit he’d made.


Donald and Ivanka exhibited a clear pattern of donations seemingly targeted to avoid spread of NY AG suit or CA class actions to other AGs, but only Pam Bondi visibly responded. The strong pattern is truly seen only by checking all the relevant states and finding that most such donations were made to “new” recipients.

Update history

09/24/16 Update: Contribution to Iowa’s Terry Branstad was overlooked in 09/19/16 post, now integrated, plus more information from the actual court documents.

12/19/16 Update: Add more court details, more links, discussion of events in CA, replace earlier version.

* Inferences, speculations and rhetorical questions are Italicized.

Table 1 - Trumps' contributions and key events, by state
Table 1 - Trumps' contributions and key events, by state
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