We Are Submitting Criminal Referrals to State Attorneys General Over The Freedom 250 Charity Fraud Allegations
Investigation requests went to the District of Columbia and New York, and a charter cancellation request went to Delaware. The White House controls none of the three offices.
On July 2, 2026, Democratic staff on the House Natural Resources Committee published a report alleging that the President’s fundraisers redirected donations meant for America250, the congressionally chartered anniversary foundation, into Freedom 250, an entity the White House controls, by giving donors Freedom 250’s routing and account numbers.
Wire fraud is a federal crime, and only federal prosecutors can charge it. The President whose fundraising operation the report’s authors describe appoints those prosecutors. The report supplies the evidence, and the evidence needs a prosecutor the President cannot control and criminal prosecutions that cannot be pardoned by Trump.
So myself and the Existentialist Republic team drafted three citizen referral letters, the kind of letter any member of the public can send to a prosecutor asking the office to request they open an investigation. Each letter states the law the conduct violates, the publicly available facts that connect the conduct to that office, the office’s own record in similar cases, and the first documents to demand.
The District of Columbia letter is first because the entity is registered there. Most crimes in the District are prosecuted by a federal appointee the President selects, but charity fraud is an exception: the elected DC Attorney General prosecutes charitable solicitation violations himself. His office already recovered $750,000 from the Trump inaugural committee.
The New York letter goes with it, because Freedom 250’s fundraising reached New York and the office that obtained the Trump Foundation’s dissolution runs the state’s Charities Bureau. New York adds a reason to act first. The state has its own double jeopardy law: once a federal prosecution for the same acts finishes, New York loses the power to bring its own case, with narrow exceptions. The courts dismissed the Manafort prosecution under that law in 2019 because the Manhattan District Attorney waited for the federal case to finish, and a protective federal plea, a narrow case the Department of Justice could file and settle fast, would end a Freedom 250 case the same way.
Delaware chartered the LLC, and Delaware law lets its Attorney General ask the Court of Chancery, Delaware’s business court, to cancel the charter, the document that gives the company its legal existence, and to appoint a receiver, a neutral officer the court places in control of the company and its records. A receiver in control of the records can produce the donor lists that every other office needs and that Freedom 250 keeps secret.
The three letters are dated July 3, 2026. No law requires me to notify federal prosecutors or to ask their permission. The Virginia letter comes next, once a subpoena identifies the bank that received the misdirected wires, because Virginia law lets a fraud case be tried in any county where any part of the scheme happened, and receiving the money qualifies.
Four more states can open their own investigations the moment a resident or company inside the state is identified among the deceived donors: California, Washington, Illinois, and Minnesota. The donor lists demanded in the first three letters are the documents that would identify those donors. A deceived donor can also act directly: a person or company that wired money to Freedom 250 while intending America250 can contact their state attorney general, and that one contact gives the state its case.
Every other finding in the report can be enforced only by federal agencies the President controls: the money Congress appropriated and the White House diverted, the contracts steered to the President’s operatives, the donations corporations left off their lobbying disclosures, and the fundraising from foreign companies. The President appoints none of the three officers above.
The letters state the limits: the report is a staff draft the full committee has not voted on, the central allegation comes from witnesses who spoke to committee staff confidentially, the report’s authors name no donor and state no amount, and Freedom 250 calls the report “a partisan smear.” Each letter asks for one thing, an investigation that uses subpoenas, the court-backed orders that compel documents and testimony, to test what the witnesses said.
The checkpoints are public. Whether Freedom 250 registered to solicit donations in the District is a record anyone can request. A District prosecution would appear in the Superior Court’s public filings, and a New York subpoena fight would appear in the state court’s public records. A Delaware petition to cancel the charter would appear in the Court of Chancery’s records. A referral requires no law license and no court filing, and any reader can send their own, as can any organization. If you are a member of any organizations with an interest in fighting corruption, this is a fantastic way to influence the system towards justice. If you can share this article with any news organizations, more coverage is always helpful.
The three letters follow in full, so the record of what each office received is public from the start.
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July 3, 2026
The Honorable Brian L. Schwalb Attorney General for the District of Columbia Office of the Attorney General 400 6th Street NW Washington, DC 20001
Re: Request for investigation of Freedom 250 LLC and its fundraisers under the District’s charitable solicitation law
Dear Attorney General Schwalb:
This letter is a citizen referral of publicly documented conduct for investigation under District law. I write as a journalist and legal scholar, the author of Oppositional Federalism: A Taxonomy of State Constitutional Postures Under Authoritarian Capture and of The American Reformation, and the publisher of The Existentialist Republic. This referral applies the taxonomy’s central claim: state offices hold enforcement authority that federal capture does not reach. Every factual statement below is linked to its source.
Democratic staff of the House Natural Resources Committee released an interim oversight report on July 2, 2026 describing the fundraising conduct of Freedom 250 LLC, a Delaware limited liability company registered in the District as a wholly owned subsidiary of the National Park Foundation. The company began transacting business in the District on November 18, 2025. Its District filing lists the Foundation’s mailing address and names a senior Foundation official as sole beneficial owner.
The report’s principal allegation concerns donors who intended to give to the congressionally chartered America250 Foundation. Those donors were given wire instructions containing Freedom 250’s banking information, “including its routing number and account number,” so the contributions would go to Freedom 250 instead, according to confidential disclosures the drafters describe. The drafters name Meredith O’Rourke, a National Park Foundation board member and the President’s lead 2024 campaign fundraiser, among the fundraisers who misled donors. The drafters write that the conduct could constitute “charitable solicitation violations under the laws of the District of Columbia, where Freedom 250 is registered and operates as an LLC.” The Washington Post reported the release and the allegations, and Ranking Member Jared Huffman told the Post: “I know the elements of fraud, and there is evidence of all those elements here.”
District law places this conduct within your office’s authority. Section 44-1703(a) of the DC Code states that no person shall solicit in the District of Columbia without a valid certificate of registration. Section 44-1711 prohibits a solicitor from using the name of another person or organization without consent, and the solicitation forms the drafters describe carried America250’s name. Under Section 44-1712, violations of the chapter are punishable offenses, subsection (b) assigns the prosecutions to your office in the name of the District, subsection (c) provides subpoena authority with Superior Court enforcement, and subsection (d) preserves civil fines as alternative sanctions. Your office has already litigated the misuse of nonprofit funds by a Trump-controlled entity and recovered $750,000 from the 58th Presidential Inaugural Committee.
I ask your office to take five steps. First, confirm whether Freedom 250 LLC, Meredith O’Rourke, and O’Rourke’s firm hold certificates of registration, a same-day public records check. Second, issue document preservation demands to Freedom 250 and the National Park Foundation immediately, since the entity could dissolve or transfer its records after the July 4, 2026 anniversary. Third, subpoena Freedom 250 and the Foundation under Section 44-1712(c) for donor lists, gift agreements, sponsorship materials, and every version of wire instructions provided to any prospective donor since October 28, 2025. Fourth, subpoena the bank identified by the routing number on those wire instructions for the account records, which will establish whether any misdirected transfer was completed and where the affected donors reside. Fifth, ask America250 whether it consented in writing to any use of its name in solicitation and for its records of donors who reported confusion, records America250 can produce voluntarily.
This referral states the record’s limits plainly. The report is an interim staff product that the full committee has not adopted, and the drafters base the principal allegation on confidential disclosures to committee staff. The drafters identify no donor by name and state no dollar amount. Freedom 250, through spokeswoman Danielle Alvarez, called the report “a partisan smear”. The request is an investigation that tests the disclosures with the compulsory process your office already holds, and the whistleblowers who spoke to committee staff can speak with your investigators through the committee minority.
One timing point deserves statement. Only federal prosecutors can charge federal wire fraud, and the administration that created Freedom 250 appoints them. No rule requires your office to refer the conduct to the Department of Justice, to notify federal prosecutors, to await a federal charging decision, or to pause if a federal investigation is announced. A deconfliction request, if one arrives, creates no legal obligation.
The underlying documents are compiled: the report, the sponsorship packages published by The American Prospect, the entity’s District and Delaware registration details, and the press record. I will provide the set on request.
Thank you for your attention to this referral.
Christopher Armitage
July 3, 2026
The Honorable Letitia James Attorney General of the State of New York Charities Bureau 28 Liberty Street New York, NY 10005
Re: Request for investigation under Article 7-A and Executive Law Section 63(12) of charitable solicitation by Freedom 250 LLC directed into New York
Dear Attorney General James:
This letter is a citizen referral of publicly documented conduct for investigation under New York law. I write as a journalist and legal scholar, the author of Oppositional Federalism: A Taxonomy of State Constitutional Postures Under Authoritarian Capture and of The American Reformation, and the publisher of The Existentialist Republic. This referral applies the taxonomy’s central claim: state offices hold enforcement authority that federal capture does not reach. Every factual statement below is linked to its source.
Democratic staff of the House Natural Resources Committee released an interim oversight report on July 2, 2026 describing the fundraising conduct of Freedom 250 LLC, a Delaware limited liability company operating from Washington as a wholly owned subsidiary of the National Park Foundation. Donors who intended to give to the congressionally chartered America250 Foundation were given wire instructions containing Freedom 250’s banking information, “including its routing number and account number,” so the contributions would go to Freedom 250 instead, according to confidential disclosures the drafters describe. The drafters name Meredith O’Rourke, a National Park Foundation board member and the President’s lead 2024 campaign fundraiser, among the fundraisers who misled donors. The Washington Post reported the release and the allegations, and Ranking Member Jared Huffman told the Post: “I know the elements of fraud, and there is evidence of all those elements here.”
The New York connection is documented and confirmable. Mastercard, headquartered in Purchase, New York, appears on the National Park Foundation’s list of confirmed Freedom 250 cash contributors, so solicitation reached New York. The drafters also describe outreach calls to America250’s corporate sponsors, a roster that includes companies headquartered in New York, and the calls confused executives about which organization was asking. A subpoena would establish whether any New York donor received the misdirected wire instructions.
New York law places this conduct within your office’s authority. Article 7-A of the Executive Law requires registration with your Charities Bureau before soliciting contributions in New York and prohibits fraudulent or misleading solicitation. Executive Law Section 63(12) authorizes investigation before any suit is filed. Penal Law Section 190.65 defines scheme to defraud in the first degree, a class E felony, as a systematic ongoing course of conduct with intent to defraud more than one person by false pretenses, in which property is obtained from at least one victim. Your office has already litigated the misuse of charitable assets by a Trump-controlled entity, and the Trump Foundation case ended with the foundation dissolved and a $2 million damages order.
I ask your office to take five steps. First, confirm whether Freedom 250 LLC, Meredith O’Rourke, and O’Rourke’s firm registered under Article 7-A before soliciting in New York, a records check that requires no process. Second, issue document preservation demands to Freedom 250 and the National Park Foundation immediately, since the entity could dissolve or transfer its records after the July 4, 2026 anniversary. Third, issue subpoenas under Section 63(12) for donor lists, gift agreements, solicitation communications, and every version of wire instructions provided to any prospective donor since October 28, 2025. Fourth, subpoena the bank identified by the routing number on those wire instructions for the account records, which will establish whether any misdirected transfer was completed and where the affected donors reside. Fifth, refer any completed misdirected wire from a New York donor to the appropriate District Attorney for evaluation under Penal Law Section 190.65.
Timing decides whether New York keeps this case. Criminal Procedure Law Section 40.20 bars a separate state prosecution after a completed federal prosecution based on the same act unless a statutory exception applies, and the courts applied the bar in People v. Manafort. The trial court dismissed the Manhattan indictment on December 18, 2019, and the First Department unanimously affirmed the dismissal, 187 A.D.3d 612 (2020), with leave to appeal denied in February 2021. The 2019 amendment, Section 40.51, covers pardoned conduct and does not cover a protective federal guilty plea to a narrow count. A minimal federal case ending in a fast plea could therefore bar New York’s charges. Acting before any federal filing protects the state case, and no rule requires your office to refer the conduct to federal prosecutors, to notify them, to await their charging decision, or to pause if a federal investigation is announced.
This referral states the record’s limits plainly. The report is an interim staff product that the full committee has not adopted, and the drafters base the principal allegation on confidential disclosures to committee staff. The drafters identify no donor by name and state no dollar amount. Freedom 250, through spokeswoman Danielle Alvarez, called the report “a partisan smear”. The request is an investigation that tests the disclosures with the compulsory process your office already holds, and the whistleblowers who spoke to committee staff can speak with your investigators through the committee minority.
The underlying documents are compiled: the report, the sponsorship packages published by The American Prospect, the entity’s District and Delaware registration details, and the press record. I will provide the set on request.
Thank you for your attention to this referral.
Christopher Armitage
July 3, 2026
The Honorable Kathleen Jennings Attorney General of the State of Delaware Delaware Department of Justice 820 N. French Street Wilmington, DE 19801
Re: Request that the office evaluate a petition under 6 Del. C. Section 18-112 concerning Freedom 250 LLC
Dear Attorney General Jennings:
This letter is a citizen referral of publicly documented conduct for evaluation under Delaware law. I write as a journalist and legal scholar, the author of Oppositional Federalism: A Taxonomy of State Constitutional Postures Under Authoritarian Capture and of The American Reformation, and the publisher of The Existentialist Republic. This referral applies the taxonomy’s central claim: state offices hold enforcement authority that federal capture does not reach. Every factual statement below is linked to its source.
Freedom 250 LLC was formed in Delaware on October 28, 2025, with Harvard Business Services as its registered agent, and it operates from Washington as a wholly owned subsidiary of the National Park Foundation. Democratic staff of the House Natural Resources Committee released an interim oversight report on July 2, 2026 describing the entity’s fundraising conduct. Donors who intended to give to the congressionally chartered America250 Foundation were given wire instructions containing Freedom 250’s banking information, “including its routing number and account number,” so the contributions would go to Freedom 250 instead, according to confidential disclosures the drafters describe. The Washington Post reported the release and the allegations, and Ranking Member Jared Huffman told the Post: “I know the elements of fraud, and there is evidence of all those elements here.”
Delaware law gives your office a distinct role. Under 6 Del. C. Section 18-112, the Court of Chancery, on your motion, may cancel the certificate of formation of a Delaware limited liability company “for abuse or misuse of its limited liability company powers, privileges or existence,” and the court may appoint a trustee or receiver to administer the winding up. The section requires no Delaware victim, and it addresses the misuse of a Delaware entity wherever the conduct occurred. Your office used the section against Backpage.com LLC in 2018 and again in two 2019 petitions, one concerning the Michael Cohen entities used for the 2016 nondisclosure payments and one concerning entities tied to Paul Manafort and Rick Gates in Jennings v. LOAV Ltd., as Bloomberg Law’s analysis of the provision documents. In each matter the underlying misconduct occurred outside Delaware, and the Delaware charter supplied the basis for your action.
I ask your office to take four steps. First, evaluate a Section 18-112 petition on the existing public record, which now includes a congressional staff report describing the entity as the receiving instrument for misdirected charitable wires. Second, issue document preservation demands to the entity and its registered agent, since the entity could dissolve or transfer its records after the July 4, 2026 anniversary. Third, if the petition proceeds, seek a trustee or receiver so the donor records and gift agreements come under a neutral officer’s control, since receivership would supply the records that Freedom 250 now withholds from every investigating office. Fourth, coordinate with the attorneys general for the District of Columbia and New York, whose subpoena power over the entity and its parent foundation can identify the affected donors.
This referral states the record’s limits plainly. The report is an interim staff product that the full committee has not adopted, and the drafters base the principal allegation on confidential disclosures to committee staff. The drafters identify no donor by name and state no dollar amount. Freedom 250, through spokeswoman Danielle Alvarez, called the report “a partisan smear”. The request is an evaluation that tests the disclosures against your office’s own precedents, and no rule requires your office to refer the conduct to federal prosecutors, to notify them, to await their charging decision, or to pause if a federal investigation is announced.
The underlying documents are compiled: the report, the sponsorship packages published by The American Prospect, the entity’s District and Delaware registration details, and the press record. I will provide the set on request.
Thank you for your attention to this referral.
Christopher Armitage
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Only the Trump organization could turn a national celebration into a federal grift. I think plenty of people caught on to it including the attempt to relabel events. All the entertainers who pulled out of events were wise to it. I know that there was genuine excitement about the bicentennial in 1976 including special models of cars and commemorative coins. None of that excitement is evident this year. I hope there are legal consequences for this illegal hijacking of a national celebration. This is not Trumpnation.
Thank you so much. There’s no way I could ever properly express my gratitude.