DOJ ASAC Data & Policy Audit 2

Forensic Audit of DOJ ASAC Data Ingestion and Municipal Policy Coordination (FY 2025–2026) 1. Administrative Ingestion & Telemetry Logs The flow of automated civil rights reports into federal and municipal law enforcement systems relies on a structured, multi-tier data pipeline designed to translate unstructured campus grievances into actionable regulatory and legal investigations. This pipeline leverages generative artificial intelligence and programmatic data injection to bypass standard bureaucratic bottlenecks, establishing a high-frequency reporting loop that exerts administrative pressure on targeted institutions. Automated Complaint-Generation Systems and API Integrations The primary technical engine of this automated pipeline is Reportify, a generative AI application engineered by Danielle Sobkin (UC Berkeley) and Hannah Levin (Stanford). Developed under the InnovatED Track of the Adir Challenge rapid-prototyping incubator, Reportify is designed to ingest unstructured qualitative narrative inputs—including raw text descriptions, screenshots, and electronic logs—and automatically output standardized, legally formal Title VI civil rights complaints. The application utilizes specialized" automated portal injection APIs" to bypass manual reporting administrative bottlenecks and maximize administrative friction. This mechanism is engineered to simultaneously flood higher education compliance portals and federal databases, establishing a continuous flow of high-volume complaints to trigger formal investigations. A forensic gap remains within the available administrative records regarding the exact system integration specifications linking Reportify directly to the Department of Justice (DOJ) Civil Rights Division's public-facing portal (civilrights. justice. gov). The precise API endpoints, data transmission schemas, and metadata fields utilized to pass automated Title VI telemetry directly into federal databases are currently designated as outstanding forensic targets for stage-two OSINT investigation. The systemic effect of this integration is the creation of an automated administrative loop that converts campus political friction into formal civil rights investigations. Federal Advisory Telemetry and Compliance Initiatives Under the regulatory mandates of Executive Orders 13899 and 14188, the Department of Justice established the Anti-Semitism Advisory Committee (ASAC). The committee is structurally positioned to deploy a 15-city National Awareness & Action Tour. This initiative functions to inject automated civil rights compliance guidelines and enforcement standards directly into local school districts, teacher unions, and municipal law enforcement agencies. The tour is managed administratively by Designated Federal Officer (DFO) Mary Margaret Bush, while DOJ ASAC Chair Leo Terrell operates as senior counsel and legal lead. The operational records of the ASAC and the correspondence files of DFO Mary Margaret Bush present a critical administrative gap. Specifically, the exact metrics used to calculate municipal compliance, alongside internal communication logs detailing the withholding of federal grants from targeted municipal corridors—including New York, Chicago, Los Angeles, San Francisco, Philadelphia, and Washington, D. C. under Mayor Muriel Bowser—are currently unavailable in the retrieved files and represent active forensic requirements. However, the broader operational framework of the committee relies on the threat of Title VI non-compliance and subsequent federal funding freezes to enforce administrative and educational rules. System Component Entity / Registry Primary Operators Known Operational Schema Outstanding Forensic Gaps Reportify AI Platform Adir Challenge (EIN 99-0583740) Danielle Sobkin, Hannah Levin Automated ingestion of unstructured text and screenshots; programmatic translation into standardized Title VI complaints. Active API endpoints, JSON metadata payload fields, and system integration documentation for civilrights. justice. gov. DOJ ASAC Node civilrights. justice. gov Leo Terrell (Chair), Mary Margaret Bush (DFO) Dissemination of federal civil rights enforcement guidelines to local education and law enforcement bodies. Local compliance metrics; internal correspondence regarding federal grant withholding for NY, Chicago, LA, SF, Philly, and DC. 2. Interlocking Personnel Communication Logs The alignment of federal civil rights investigations with private, high-frequency litigation is maintained through an interlocking network of public interest law firms, corporate defense counsel, and advisory committee leadership. This network coordinates legal strategies and shares human capital to maximize legal pressure on academic and municipal institutions. Interlocking Legal Networks and Strategic Coordination The primary legal firms executing high-frequency litigation are the Louis D. Brandeis Center for Human Rights Under Law and Consovoy McCarthy Park PLLC. These organizations operate in close coordination, regularly sharing counsel and aligning their civil filings. This programmatic alignment is demonstrated in the landmark civil action Matthew Weinberg et al. v. National Students for Justice in Palestine, where the plaintiffs are represented by a joint team of attorneys from both firms: ● Consovoy McCarthy Park PLLC: Thomas R. McCarthy, Julius I. Kairey, and Zachary P. Grouev. ● Louis D. Brandeis Center: Richard A. Rosen and Omer Wiczyk. The integration of these entities is further reinforced through shared talent networks. For example, Andrea Arellano, an alumna of the Philos Leadership Institute, serves as a Research Associate at Consovoy McCarthy Park PLLC, highlighting the pipeline connecting private advocacy programs with litigation firms. Communications and Foreign Strategy Gaps Despite the documented cooperation between Consovoy McCarthy Park PLLC and the Louis D. Brandeis Center, a critical gap exists in the retrieved electronic records. The files contain no direct communications, electronic logs, or scheduling records linking DOJ ASAC Chair Leo Terrell, Assistant Attorney General Harmeet K. Dhillon, or Associate Attorney General Stanley Woodward with external legal leads at the Brandeis Center (such as Kenneth L. Marcus, Robin Pick, and Denise Katz-Prober) or counsel at Consovoy McCarthy. Consequently, records detailing the pre-coordination of private Title VI complaints prior to the execution of formal federal civil rights investigations remain an outstanding forensic requirement. Additionally, there are active gaps regarding foreign strategic coordination. The retrieved logs do not contain travel records, expense disclosures, or coordination briefs regarding Leo Terrell's participation in the January 2026" Generation of Truth" conference in Jerusalem, hosted by Israeli Minister Amichai Chikli, or any directives derived from his receipt of the Israeli Government's Award of Honor. However, the structural alignment between these domestic entities and foreign state organs is demonstrated by the Combat Antisemitism Movement (CAM). Sima Vaknin-Gil, a former IDF Chief Censor and former Director-General of the Ministry of Strategic Affairs, sits on CAM's board, directly coordinating informal U. S. advocacy strategies via Voices of Israel Ltd.. The operational synchronicity of this network is highlighted by CAM’s execution of global media campaigns to support policies of the Ministry of Diaspora Affairs and Combating Antisemitism, such as the February 2026 campaign defending the suspension of Oxfam's operations in Gaza. Interlocking Entity Key Personnel Documented Legal Actions / Roles Talent & Organizational Overlaps Consovoy McCarthy Park PLLC Thomas R. McCarthy, Julius I. Kairey, Zachary P. Grouev Joint counsel in Matthew Weinberg et al. v. NSJP. Employs Andrea Arellano (Philos Leadership Institute alumna; Research Associate). Louis D. Brandeis Center Richard A. Rosen, Omer Wiczyk Joint counsel in Matthew Weinberg et al. v. NSJP. Collaborates with Consovoy McCarthy on coordinated, high-frequency Title VI litigation. Combat Antisemitism Movement (CAM) Leo Terrell (Counsel), Sima Vaknin-Gil (Board Member) Targets academic institutions to trigger Title VI funding freezes. Sima Vaknin-Gil coordinates U. S. advocacy strategies via Voices of Israel Ltd.. 3. Municipal Index Execution & Data Ingest Loops The localized enforcement of speech constraints and public safety policies is coordinated through the Combat Antisemitism Movement’s (CAM) Mayors Advisory Board via the Municipal Antisemitism Action Index. This policy tool functions as an extra-legislative framework to insert the International Holocaust Remembrance Alliance (IHRA) working definition of antisemitism directly into local municipal bureaucracies, bypassing standard legislative processes. Extra-Legislative Administrative Modifications Across targeted municipal corridors, the execution of the Municipal Index modifies three primary administrative sectors: 1. K-12 Education & Teacher Union Compliance: The index drives the integration of compliance clauses directly into collective bargaining and labor contracts. These clauses subject public school teachers to administrative discipline or termination if their classroom instruction or off-duty political speech is determined to violate IHRA standards. 2. Law Enforcement Investigative Scope & Telemetry Ingestion: Local police training modules are modified to require that non-violent political expression, anti-Zionist slogans, and peaceful protest assemblies be officially logged as" bias incidents". A forensic gap exists in the retrieved files regarding the exact operational data flow and technical protocols through which this telemetry is structurally routed from local police departments to CAM's centralized Antisemitism Research Center (ARC) database. This technical pipeline is designated as an active intelligence target. 3. Zoning, Procurement, & Anti-BDS Pledges: Zoning regulations are utilized to enforce strict anti-masking ordinances and establish designated" bubble zones" around religious and educational institutions to systematically dismantle political demonstrations. Concurrently, municipal procurement departments insert compliance clauses that disqualify commercial vendors who refuse to sign pledges certifying they do not engage in boycotts of Israeli commerce. Regional Implementation Corridors The Municipal Index has been deployed across four key regional corridors, driven by local municipal executives: ● New England Flagship: Providence Mayor Brett Smiley chairs CAM's Mayors Advisory Board, positioning Providence as the primary administrative engine for regional index deployment. ● LA Metro Corridor: Beverly Hills Mayor Sharona Nazarian and Riverside Mayor Patricia Lock Dawson hosted the North American Mayors Summit. They utilized the forum to deploy strict campus policing standards and municipal speech rules, leveraging the DOJ’s Statement of Interest in Frankel v. UCLA to justify local interventions. ● South Florida Corridor: Mayors Scott Singer (Boca Raton), Larisa Svechin (Sunny Isles Beach), Howard Weinberg (Aventura), Alix Desulme (North Miami), and Margaret Brown (Weston) established the Jewish Mayors and Municipal Leaders Association (JMMLA) to implement the Index. This network organized a regional municipal forum to honor DOJ ASAC Chair Leo Terrell, financed by local donors Ezra and Lilly Gontownik. ● Atlanta Metro Suburbs: Sandy Springs Mayor Rusty Paul and Union City Mayor Vince Williams convened a closed-door" Georgia Mayors Roundtable on Antisemitism" in January 2026. The roundtable focused on injecting the Municipal Index directly into local public safety codes and school board administrative rules. Regional Corridor Key Municipal Executives Coordinating Mechanism Specific Policy Actions & Implementations New England Mayor Brett Smiley CAM Mayors Advisory Coordinates regional Regional Corridor Key Municipal Executives Coordinating Mechanism Specific Policy Actions & Implementations (Providence) Board (Chair) deployment of the Municipal Index and local policy alignment. Los Angeles Metro Mayor Sharona Nazarian (Beverly Hills), Mayor Patricia Lock Dawson (Riverside) North American Mayors Summit Deployed campus policing rules and speech limitations, citing Frankel v. UCLA. South Florida Former Mayor Scott Singer (Boca Raton), Mayor Larisa Svechin, Mayor Howard Weinberg, Mayor Alix Desulme, Mayor Margaret Brown Jewish Mayors and Municipal Leaders Association (JMMLA) Implemented anti-BDS procurement pledges; hosted Gontownik-funded forum honoring Leo Terrell. Atlanta Metro Mayor Rusty Paul (Sandy Springs), Mayor Vince Williams (Union City) Closed-door Georgia Mayors Roundtable (Jan 2026) Injected Index standards into K-12 school board administrative rules and public safety guidelines. 4. Financial Linkages & Donor Shield Networks To sustain domestic lobbying and operational campaigns without triggering registration under the Foreign Agents Registration Act (FARA), the network utilizes a multi-layered financial clearing structure. This framework relies on domestic public charities, donor-advised funds (DAFs), and structured banking clearinghouses to mask the origin and destination of transnational funds. │ (Donor-Advised Funds) (Vanguard Charitable / Schwab Charitable) │ ▼ [Central Fund of Israel (CFI)] (501(c)(3) Pass-Through Node) │ ┌────────────────────────┼────────────────────────┐ │ (Dime Community Bank) │ (Flagstar Bank) │ (CFI 2017 Grant) │ Account: 5000221843 │ Account: 1503426427 │ $700,000 │ │ │ ▼ ▼ ▼ Projects] Beneficiaries via (State Matching Pool) Wire Memo Codes] (VOI Ltd.) │ ┌─────────────────┼─────────────────┐ │ │ │ ▼ ▼ ▼ (Eden Center) (Regavim PBC) (Sela) Transnational Pass-Through Clearing Mechanics The primary clearinghouse for U. S. tax-deductible capital moving into foreign initiatives is the Central Fund of Israel (CFI), a New York-registered 501(c)(3) public charity. CFI is run out of Marcus Brothers Textiles on Sixth Avenue in Manhattan, with day-to-day operations executed from the West Bank settlement of Efrat by its president, Jay Marcus. CFI operates as a pass-through entity, allowing U. S. donors to secure tax deductions while routing millions to overseas initiatives. The public reporting on CFI's IRS Form 990 lists the organization as the sole recipient, which prevents the direct tracking of ultimate beneficial owners (UBOs) and final destinations. CFI relies on bank clearing accounts and a system of alphanumeric beneficiary codes to route earmarked funds: ● Dime Community Bank (Hauppauge, NY): CFI’s primary domestic and international wire clearing channel. ● Flagstar Bank (Woodmere, NY): CFI’s alternative routing pipeline. Donors must include specific codes in the wire transfer description or memo field to route capital to targeted foreign NGOs. These codes include: ○ EDC761: Routes funds to the Eden Center. ○ REGAVIM: Routes funds to Regavim, a public benefit company. ○ Sela: Routes funds to the Sela organization. Historically, CFI has routed funds to nationalist and settler organizations, including Im Tirtzu, Ateret Cohanim, the Israel Land Fund, Honenu, Women in Green, and the Od Yosef Chai Yeshiva. In 2017, CFI was identified as the largest private donor to Kela Shlomo (the predecessor to Voices of Israel Ltd.), transferring $700,000, which was matched dollar-for-dollar by the Israeli state. Clearing Bank Account Title / Number Routing / SWIFT Alphanumeric Memo Code Targeted Foreign NGO Dime Community Bank (Hauppauge, NY) Central Fund of Israel Account No: 5000221843 ABA: 021406667 SWIFT: BHNBUS3B N/A (Primary CFI Operating Account) Multi-destination pass-through clearing. Flagstar Bank (Woodmere, NY) Central Fund of Israel Account No: 1503426427 ABA: 026013576 SWIFT: SIGNUS33 EDC761 The Eden Center. Flagstar Bank (Woodmere, NY) Central Fund of Israel Account No: 1503426427 ABA: 026013576 SWIFT: SIGNUS33 REGAVIM Regavim (Public Benefit Company). Flagstar Bank Central Fund of ABA: 026013576 Sela Sela. Clearing Bank Account Title / Number Routing / SWIFT Alphanumeric Memo Code Targeted Foreign NGO (Woodmere, NY) Israel Account No: 1503426427 SWIFT: SIGNUS33 Donor-Advised Funds and Shielding Mechanisms To prevent federal regulators and public audits from tracing the original sources of advocacy capital, the network routes funds through major domestic Donor-Advised Funds (DAFs). Because DAFs are legally structured to shield the identity of individual contributors, they allow donors to maintain anonymity while routing capital through pass-through clearinghouses like CFI. In the fiscal year 2024, anonymous DAF benefactors routed $3,353,601 through Vanguard Charitable to the Central Fund of Israel for" Exempt Purpose Support". Concurrently, Schwab Charitable (DAFgiving360) routed $1,968,124 to CFI under the designation" International / Foreign Affairs". This capital routing allows domestic non-profits to certify that their lobbying operations are funded entirely by domestic philanthropic capital, even when policy initiatives align with a foreign state. Corporate Registrations and Inbound Funding Loops The domestic administrative front is managed by a network of public charities and social welfare organizations that maintain an integrated corporate structure: 1. Combat Hate Foundation (EIN 84-2208774; Moundridge, KS): This 501(c)(3) public charity serves as the operational and administrative cutout managing the Combat Antisemitism Movement (CAM). The foundation is integrated with and managed by executive personnel from Berexco LLC, a Midwestern oil and gas firm. The key personnel include Adam E. Beren (President of Berexco, founder of CAM, and member of the U. S. Holocaust Memorial Council), Donna Stucky (CFO of Berexco and record-keeper, under whose name the foundation was registered to obscure Beren's involvement), Jonathan Oller (Berexco executive and treasurer), and Mikhail (Misha) Galperin (Executive Director). For FY 2024, the foundation reported total assets of $1,859,706, revenues of $9,857,892, and expenses of $11,943,380. Its primary funding source is the Beren Sea Foundation (Adam Beren's family charity), which has injected over $13.1 million into the Combat Hate Foundation since 2020 ($2,000,000 in FY 2020; $1,500,000 in FY 2021; $3,125,000 in FY 2022; $3,592,222 in FY 2023; and $2,775,000 in FY 2024). Additional funding is provided by the Israel Henry Beren Charitable Foundation ($500,000 in FY 2024), the Ric & Suzanne Kayne Foundation ($500,000 in FY 2024), and Vanguard Charitable ($305,000 in FY 2024). 2. Vine & Fig Tree Action Inc. (EIN 99-3826844; Connecticut Credential No. CHR.0069974): Structured as an IRC Section 501(c)(4) social welfare organization, this entity functions as the politically active lobbying arm of the broader Vine & Fig Tree network. It operates from a consolidated administrative headquarters at 207 W 25th St, Floor 9, New York, NY 10001. Operational and narrative alignment is maintained through an interlocking directorate where Michael Davis simultaneously serves as the Chairman and President of Vine & Fig Tree Action Inc., the Vine & Fig Tree Institute I Inc. (the network's 501(c)(3) public charity node), and the Vine & Fig Tree Fund Inc.. Davis draws no reported compensation, which minimizes public financial disclosure. The 501(c)(3) node (Vine & Fig Tree Institute I Inc.) accumulates tax-deductible contributions from institutional donors and DAFs, dispersing funds internally through downstream nodes like the Vine & Fig Tree Fund Inc., which contributed a $250,000 grant in FY 2024 to the Combat Hate Foundation for program support. │ │ $13.1M Since 2020 $250,000 (FY 2024) │ │ ▼ ▼ ┌─────────────────────────────────────────────────┐ │ Combat Hate Foundation │ │ (501(c)(3) Administrator) │ │ │ └───────────────────────┬─────────────────────────┘ │ ┌──────────────────────┼──────────────────────┐ │ │ │ $75,000 (2022) $15,000 (2022) $35,000 (2020) │ │ │ ▼ ▼ ▼ Washington] Tracking) (Federal Lobbying) Lobbying Allocations and Policy Injection Points As a 501(c)(4) social welfare organization, Vine & Fig Tree Action Inc. is legally permitted to engage in unlimited lobbying and political advocacy, provided lobbying does not become its primary purpose. The network presents its advocacy under classical American historical themes—specifically referencing President George Washington's 1790 letter to the Hebrew Congregation of Newport—to secure bipartisan credibility and introduce foreign policy-aligned initiatives under the guise of core American founding values. Its lobbying efforts target four primary domestic policy and funding points: 1. The U. S. National Strategy to Counter Antisemitism: Coordinated a public and private pressure campaign to compel the executive branch to officially adopt the IHRA definition of antisemitism as the benchmark for federal civil rights enforcement. 2. Platform Censorship Campaigns: Utilized research produced by allied 501(c)(3) entities, such as the Network Contagion Research Institute (NCRI) (which received a $75,000 grant from the Combat Hate Foundation in 2022), to pressure social media platforms (including Meta and X) to implement content moderation policies to ban specific categories of political speech. 3. Targeted Federal Appropriations: Successfully lobbied for federal funding and legislative integration, securing appropriations for: ○ The Countering Antisemitism Act (establishing a permanent federal coordinating structure). ○ State Department Special Envoy Funding (securing millions for the Office of the Special Envoy to Monitor and Combat Antisemitism). ○ The Nonprofit Security Grant Program (NSGP) (directing Department of Homeland Security funds to local non-profit partners). 4. Algorithmic Research Grants: Secured a $10 million appropriation directed to the National Institute of Justice to study and develop federal policies to combat" algorithmic amplification of dangerous content". FARA Circumvention and Foreign Strategic Buffers The principal legal objective of this multi-entity architecture is to coordinate domestic policy advocacy in alignment with a foreign principal—the State of Israel and its Ministry of Diaspora Affairs and Combating Antisemitism—while remaining exempt from the registration and disclosure mandates of the Foreign Agents Registration Act (FARA). Under FARA, an agency relationship is established if the domestic entity acts" at the order, request, or under the direction or control of a foreign principal". To avoid this threshold, the network’s legal strategists utilize specific contractual language to document third-party relationships as" cooperative and goal-aligned"" independent contractors" rather than partnerships, joint ventures, or agency relationships. Because the relationship is defined as" cooperative" rather than" controlled, " unregistered domestic non-profits like Vine & Fig Tree Action Inc. and CAM can execute narrative campaigns that match foreign state objectives. If challenged by regulators, they can claim their activities are purely independent and mission-driven, bypassing FARA scrutiny. This structure is supported by Voices of Israel Ltd. (VOI) (formerly operating as Kela Shlomo and Concert - Together for Israel ), an Israeli Public Benefit Company (PBC) and state-directed joint venture established in Tel Aviv in 2018. VOI functions to channel Israeli government grants to international organizations that execute advocacy campaigns aligned with foreign state interests, serving as a FARA mitigation strategy. VOI operates on a state-directed matching fund model where the Government of Israel allocates state capital to a matching pool that is released when matched dollar-for-dollar by private donors or pro-Israel organizations. In 2021, Minister Yair Lapid earmarked a four-year budget of NIS 100 million for the company, and in November 2023, the matching program was deployed as an emergency initiative to double the operational budgets of civilian organizations for global information campaigns. VOI distributes funds to global public relations, advocacy, and monitoring programs, including Hasbara Fellowships, Conexión Israel, Leaders of Tomorrow, and the European Leadership Network. It also shares leadership ties with CyberWell, an anti-disinformation group that utilizes big data and AI to monitor social media and flag content violating the IHRA definition. Domestic Entity Corporate Taxonomy Interlocking Control Nodes Primary Inbound Capital Streams Primary Outbound Allocations Combat Hate Foundation 501(c)(3) Public Charity (EIN 84-2208774) Adam E. Beren, Donna Stucky, Jonathan Oller, Mikhail Galperin Beren Sea Foundation ($13.1M since 2020); Vine & Fig Tree Fund ($250K, FY 2024). $75K to NCRI (2022); $35K to Winning Strategies Washington (2020). Vine & Fig Tree Action Inc. 501(c)(4) Social Welfare Org (EIN 99-3826844) Michael Davis (Chairman & President) Routed through DAFs and Vine & Fig Tree Institute I Inc. Lobbying for the Countering Antisemitism Act and $10M Domestic Entity Corporate Taxonomy Interlocking Control Nodes Primary Inbound Capital Streams Primary Outbound Allocations algorithmic research grants. Adir Challenge Foundation (EIN 99-0583740) Rapid-prototyping incubator node Domestic and international philanthropic capital. Funded Danielle Sobkin and Hannah Levin to develop Reportify AI. Voices of Israel Ltd. (VOI) Israeli Public Benefit Company (PBC) Ministry of Diaspora Affairs and Combating Antisemitism NIS 100M state matching pool; private DAF donations via CFI. Hasbara Fellowships; Conexión Israel; CyberWell social media monitoring. 5. Intelligence Synthesis and Strategic Recommendations The operational integration of the DOJ ASAC, municipal policy instruments, and private non-profit networks reveals a highly structured, self-reinforcing pipeline that leverages private capital and automated technologies to shape civil rights enforcement. Through Reportify’s automated portal injection APIs, qualitative student grievances are programmatically converted into formal Title VI complaints. This automated influx creates an artificial baseline of regulatory volume, establishing a pretext of institutional non-compliance. The DOJ ASAC and allied private legal groups like Consovoy McCarthy and the Brandeis Center utilize this baseline to trigger formal civil rights investigations and threaten the suspension of federal funding. Concurrently, CAM's Mayors Advisory Board bypasses federal and state legislative scrutiny by embedding the Municipal Antisemitism Action Index directly into local public safety guidelines, K-12 teacher contracts, and public procurement regulations. This administrative loop is sustained by domestic donor-advised funds (DAFs), which shield the identity of ultimate beneficial owners, and pass-through entities like the Central Fund of Israel, which route earmarked capital to foreign organizations under FARA-exempt cooperative contracts. To resolve the identified forensic gaps and establish definitive proof of administrative and financial coordination, the following targeted investigation pathways are recommended: ● Subpoena of Reportify API Metadata: Initiate state-level administrative subpoenas or discovery motions targeting Reportify's system integration records. Specifically, request JSON payload schemas, API endpoints, and transmission logs to civilrights. justice. gov to determine if the platform has been granted privileged access or direct data-ingestion pipelines by federal IT administrators. ● FOIA Audit of DOJ ASAC Communications: Submit targeted Freedom of Information Act (FOIA) requests to the DOJ Civil Rights Division targeting DFO Mary Margaret Bush and Chair Leo Terrell. The requests should isolate correspondence containing the terms" compliance metrics, "" grant withholding, " and specific target municipalities (specifically targeting New York, Chicago, Los Angeles, San Francisco, Philadelphia, and Washington D. C.). ● Deposition of Interlocking Counsel: In active Title VI civil actions, pursue deposition pathways targeting Andrea Arellano, Richard A. Rosen, and Omer Wiczyk. Focus questioning on the pre-coordination of private complaints with the Brandeis Center and Consovoy McCarthy prior to formal federal civil rights investigations or Joint Task Force site visits. ● Deposition and State-Level FARA Audits of 501(c)(4) Nodes: File petitions with the Connecticut and New York Attorneys General to audit Vine & Fig Tree Action Inc.’s (EIN 99-3826844) compliance with state public charity regulations and lobbying disclosure laws. Investigate Michael Davis’s simultaneous control of the network’s 501(c)(3) and 501(c)(4) nodes to trace the internal routing of tax-deductible donor-advised fund capital into active political lobbying campaigns. ● Municipal Public Records Requests: Deploy state-level public records requests (such as California's Public Records Act and Florida's Sunshine Law) targeting local law enforcement agencies enrolled in CAM’s training. Request all communications, training manuals, and data-sharing agreements linking municipal police databases to CAM's centralized Antisemitism Research Center (ARC) to determine the technical protocols used to log peaceful political protests and anti-Zionist slogans as" bias incidents".