- More than $327,000 in payments to the Trump Hotel Collection and Mar-A-Lago Club since the 2020 election.[200]
- An "event sponsorship fee" of $165,937.50 to American Conservative Union,[201] the Chairman of which is Matt Schlapp. Schlapp and his wife have offered to pay the legal fees of witnesses called to testify before the January 6th Committee and have extensive ties with former President Trump.
- A little over $140,000 to National Public Affairs, LLC,[202] a consulting company started by former Trump Campaign Manager Bill Stepien and Deputy Campaign Manager Justin Clark.[203] Stepien testified that he knew the claims of voter fraud were false, that he didn't think what was happening was necessarily honest, and that he was stepping away from the Trump Campaign.[204] However, he continues to work and receive hundreds of thousands of dollars consulting for President Trump and several other congressional candidates who continue to spread false voter fraud claims related to the 2020 election.[205]
C. Payments to 2M Management LLC
As described above, the Trump Campaign, after paying off its general election debt, raised millions of dollars that flowed into a segregated recount account ("Recount Account") by encouraging donors to help pay for legal challenges to the election results. Pursuant to the FECA, the Trump Campaign could only spend these funds on a few limited purposes (e.g., for actual recounts and election-contest expenses or, in the case of surplus funds, donations to charitable organizations or transferring the funds to a national party committee's separate, segregated account for election recounts).[206]
Justin Clark told the Select Committee that he understood that, "[a]fter election day, . . . you can raise money for a recount and to pay off debt,"[207] and that "[t]he money going into the campaign, principal campaign committee, at that point, [after the election] was dead money. It couldn't be spent on things."[208] Alex Cannon agreed.[209] That's why, after the election, the Trump Campaign set up the Recount Account—"a segregated restricted account [held] by the campaign"[210]—and raised money for the Recount Account through TMAGAC.[211]
In February 2021, the Trump Campaign was converted into MAGA PAC.[212] In March 2021, MAGA PAC began disclosing on required FEC forms that it was paying millions of dollars to an eDiscovery vendor called 2M Document Management & Imaging LLC ("2M Management") for what MAGA PAC described as "recount" and "Recount: Research Consulting."[213]
Although the MAGA PAC reported that 2M Management was being paid for recount-related expenses, 2M Management was primarily processing and reviewing documents slated to be produced by the National Archives
