WikiLeaks: Citigroup Exec Gave Obama Recommendation of Hillary for State, Eric Holder for DOJ

By Pam Martens and Russ Martens: October 21, 2016

Michael Froman

Michael Froman

If there is any truth to the allegation that Russia is behind the hacking of emails being released by WikiLeaks, then the American public owes Russia a huge debt of gratitude. At a time when the American people are sharply focused on how the leader of the free world is chosen, WikiLeaks is giving us an unprecedented, historical opportunity to understand how corporate money in politics has corrupted everything we believe in as a democracy.

This week, for example, emails from WikiLeaks show that President Obama, using the email address of, was communicating directly with Michael Froman of Citigroup in 2008, who fed Obama lists of recommended appointments to his cabinet. In an email from Froman dated October 6, 2008, with Froman using his Citigroup email address of, Hillary Clinton shows up on Froman’s list for Secretary of State or head of the U.S. Department of  Health and Human Services (HHS). In a separate list attached to the email, Eric Holder was recommended for U.S. Attorney General at the Department of Justice or as White House Counsel. (See the email and the attachments here.)  In less than a month after Obama’s election as President on November 4, 2008, Obama had nominated Clinton to be his Secretary of State and Holder as his Attorney General. Despite the unprecedented corruption rooted out on Wall Street by regulators, Holder failed to prosecute any of Wall Street’s top executives for the crimes that led to the greatest financial crash since the Great Depression.

Froman had served as Chief of Staff to Robert Rubin when Rubin was Secretary of the Treasury in the Bill Clinton administration. Rubin led the effort to repeal the Glass-Steagall Act, which barred investment banks and brokerage firms on Wall Street from merging with commercial banks that held FDIC insured deposits for savers. The Glass-Steagall Act had been in force since 1933, after Congress had conducted three years of hearings showing the recklessness and corruption of the major Wall Street banks. Rubin left the Treasury Department and promptly took a job at Citigroup, the primary beneficiary of the repeal in 1999. Over the next decade, as Citigroup was serially charged by its regulators for abusing the public trust, Rubin collected compensation of $126 million.

Froman followed Rubin to Citigroup where he served as Chief Operating Officer of Citi Alternative Investments and later as Managing Director of Citi Infrastructure Investors, a unit of Citi Alternative Investments. The latter is the division that blew up the bank in the same month that Obama was elected President. Froman had been a major bundler for Obama, raising funds that USA Today placed at $200,000 to $500,000.

Just seven days after Froman sent his Hillary and Holder recommendations to Obama in 2008, Citigroup received $25 billion in a bailout. Other Wall Street banks received similar amounts. But what happened just 19 days after Obama’s election was unprecedented in the annals of U.S. financial history. Citigroup received an additional infusion of $20 billion in equity from the government, assets guarantees on more than $300 billion of its toxic assets, and, it was secretly receiving billions of dollars in low-cost loans from the Federal Reserve – an amount that would cumulatively add up to $2.5 trillion from 2007 to 2010. This is how we reported in November 2008 on Citigroup’s teetering status as the President-Elect was secretly receiving his personnel marching orders from one of Citi’s executives:

“Citigroup’s five-day death spiral last week was surreal. I know 20-something newlyweds who have better financial backup plans than this global banking giant.  On Monday came the Town Hall meeting with employees to announce the sacking of 52,000 workers.  (Aren’t Town Hall meetings supposed to instill confidence?)  On Tuesday came the announcement of Citigroup losing 53 per cent of an internal hedge fund’s money in a month and bringing $17 billion of assets that had been hiding out in the Cayman Islands back onto its balance sheet.  Wednesday brought the cheery news that a law firm was alleging that Citigroup peddled something called the MAT Five Fund as ‘safe’ and ‘secure’ only to watch it lose 80 per cent of its value. On Thursday, Saudi Prince Walid bin Talal, from that visionary country that won’t let women drive cars, stepped forward to reassure us that Citigroup is ‘undervalued’ and he was buying more shares. Not having any Princes of our own, we tend to associate them with fairytales. The next day the stock dropped another 20 percent with 1.02 billion shares changing hands. It closed at $3.77.”

Matt Taibbi of Rolling Stone would report that “In January 2009, just over a month after the bailout, Citigroup paid Froman a year-end bonus of $2.25 million. But as outrageous as it was, that payoff would prove to be chump change for the banker crowd, who were about to get everything they wanted — and more — from the new president.” Jack Lew, who worked in the same division at Citigroup as Froman and had also worked in the Bill Clinton administration, received a bonus from Citigroup of $940,000 following its massive bailout. An insolvent bank, existing on a lifeline from the taxpayer, was paying those bonuses. Lew became U.S. Treasury Secretary in Obama’s second term, following Obama’s appointment of Tim Geithner as U.S. Treasury Secretary in his first term. Geithner was President at the New York Fed at the time it was funneling much of the secret $2.5 trillion in loans to Citigroup. (See related articles below.)

Froman was not just involved in recommendations on top level cabinet posts, he was also overseeing rank and file positions. In an email dated Saturday, October 18, 2008, Froman, again using his official Citigroup email address, sent the following email to Obama’s advisers:

“Review Teams

“Attached is the latest version of the Agency Review teams. It is a closely held document, so please treat it with the same sensitivity as ours. If you all could take a quick look at the lists for the agencies in your area, that would be helpful. I think the hope is that, while there are no guarantees, some of the people on these lists might make their way into the agencies ultimately. Our role, therefore, is to check whether there is much overlap between the names here and the names were seeing/generating for sub-cabinet positions in each agency. There doesn’t need to be total overlap, but if there is a total disconnect, it would probably be better to rectify that now vs. later.

“I hate to ask, since I just send you another long spreadsheet to check, but if you could do this tomorrow and get back to Lisa (copied here) and myself, that would be great. Thanks.”

Early in Obama’s first term, Froman was appointed as Deputy Assistant to the President and Deputy National Security Adviser for International Economic Affairs. Today, Froman is U.S. Trade Representative and the man behind the highly controversial and highly secretive Trans-Pacific Partnership trade deal.

This is how Politico sums up how trade deals are being deliberated under Froman’s command:

“If you want to hear the details of the Trans-Pacific Partnership trade deal the Obama administration is hoping to pass, you’ve got to be a member of Congress, and you’ve got to go to classified briefings and leave your staff and cellphone at the door.

“If you’re a member who wants to read the text, you’ve got to go to a room in the basement of the Capitol Visitor Center and be handed it one section at a time, watched over as you read, and forced to hand over any notes you make before leaving.”

If Russia is behind these leaked emails and keeping Americans informed on how their government actually works behind the scenes, then it’s not a smear against Russia but a smear against how miserably corporate media has failed in this job.

Related Articles:

Democrats Disgrace Themselves With Jack Lew Confirmation for Treasury Secretary

Was the U.S. Justice Department Sold to the Highest Bidder

As Citigroup Spun Toward Insolvency in ’07- ’08, Its Regulator Was Dining and Schmoozing With Citi Execs

Goldman Sachs Top Lawyer Is Part of a Secret Banking Cabal as CEO Blankfein Denies One Exists

By Pam Martens and Russ Martens: October 20, 2016

CNBC's David Faber Asks Goldman Sachs CEO Lloyd Blankfein If There's a Secret Banking Cabal, October 19, 2016

CNBC’s David Faber Asks Goldman Sachs CEO Lloyd Blankfein If There’s a Secret Banking Cabal, October 19, 2016

There’s a new mantra making the rounds of Washington and Wall Street. No matter how big the lie you’re caught in, no matter how much documented evidence exists against you, just deny, deny, deny. That’s how Democratic National Committee Interim Chair Donna Brazile handled the email released by WikiLeaks showing that she leaked a debate question to Hillary Clinton; that’s how Hillary Clinton handled revelations about sending classified government material over an unclassified server in the basement of her home; and that’s how Goldman Sachs CEO Lloyd Blankfein is handling the widespread public perception that there’s a banking cabal meeting in secret to plot its continued dominance over the interests of the average U.S. citizen.

Yesterday, CNBC’s David Faber interviewed Blankfein and asked about the suggestion that Donald Trump had made on October 13 in a speech in West Palm Beach, Florida that there is an international banking conspiracy undermining the sovereignty of the United States. Faber asked Blankfein: “So am I to take it that you weren’t meeting in secret with international banks and Hillary Clinton to plot the destruction of U.S. sovereignty?” Blankfein responded: “We could parse that clause by clause, but to every clause, the answer is no, we weren’t doing it. We weren’t meeting in secret and we certainly weren’t plotting destruction.”

The first half of Blankfein’s answer is flatly false and he knows it. The big Wall Street banks do meet in secret and have been doing it for decades. His own General Counsel, Gregory Palm, part of the Management Committee at Goldman Sachs, is part of the secret cabal.

Just five days before Blankfein made his false denial, Bloomberg News’ reporters Greg Farrell and Keri Geiger had landed the bombshell report that the top lawyers of the biggest Wall Street banks had been meeting secretly for two decades with their counterparts at international banks. At this year’s secret May meeting at a posh hotel in Versailles, the following were among the big bank lawyers in addition to Palm according to the Bloomberg report: Stephen Cutler of JPMorgan (a former Director of Enforcement at the SEC); Gary Lynch of Bank of America (also a former Director of Enforcement at the SEC); Morgan Stanley’s Eric Grossman; Citigroup’s Rohan Weerasinghe; Markus Diethelm of UBS Group AG; Richard Walker of Deutsche Bank (again, a former Director of Enforcement at the SEC); Robert Hoyt of Barclays; Romeo Cerutti of Credit Suisse Group AG; David Fein of Standard Chartered; Stuart Levey of HSBC Holdings; and Georges Dirani of BNP Paribas SA.

The Bloomberg report indicates that the meetings are secret and that this is the first time their existence has been reported to the public. But this is hardly the first time there have been reports of Wall Street banks huddling in secret.

Just this past July we raised the question as to whether the CEO of JPMorgan Chase, Jamie Dimon, was violating anti trust law by meeting secretly with competitors following a February 1 report in the Financial Times of  “secret summits.” As we reported at the time:

According to guidelines published by various trade associations and law firms, the following rules must be followed when conducting meetings between competitors to avoid the perception, or actual charges, of antitrust violations:

– Meetings must be regularly scheduled and should never be secret.

– A properly designated Chairman shall prepare and follow a formal agenda which should be reviewed in advance by legal counsel.

– Legal counsel should be present at all meetings.

– Formal written minutes of meetings should be taken and archived.

– Properly instituted bylaws should be followed.

– A Board of Directors should be properly instituted.

– Any company meeting the requirements of the bylaws should be allowed membership in the group.

Secret summits that are by invitation-only, have no boards or bylaws, no public minutes would certainly appear to be both violations of anti trust law as well as fueling the public perception of conspiratorial meetings.

The top Federal regulator of the Wall Street bank holding companies, the Federal Reserve, has also fueled the perception of banking cartels by allowing the New York Fed to sponsor its own bank groups like the Foreign Exchange Committee, which has been operating for the past 38 years and whose members, JPMorgan Chase and Citigroup, each pleaded guilty on May 20, 2015 to a felony count brought by the U.S. Justice Department for – wait for it – engaging in rigging foreign exchange markets. The New York Fed-sponsored group, among other things, writes best practices rules for Wall Street.

The New York Fed also bizarrely sponsors the Financial Markets Lawyers Group. Its web site is an extension of the New York Fed’s web site. Members of the group are from the same Wall Street banks whose General Counsels are meeting secretly in posh hotels once a year.

While the New York Fed sponsored groups (see its latest one here) have regularly scheduled meetings, bylaws and minutes, it’s an affront to common sense to suggest that Wall Street banks serially charged with crimes against the public should be writing their own best practices rules. This Ayn Randian concept that businessmen will do what’s best for the public interest without any interference from government has twice in the past century nearly bankrupted the United States – in the Great Depression when Wall Street banks were allowed to hold savings deposits and again in 2008 when the Wall Street banks crashed with the taxpayer on the hook for the trillions of insured savings deposits they held, thanks to the mass de-regulation of Wall Street in 1999 under the Bill Clinton administration.

We don’t believe that Wall Street banking executives have ever plotted the destruction of the United States. We believe the majority want their children and grandchildren to grow up in a socially stable America. But we also believe they have been blinded by their greed, their multi-million dollar bonuses, their mansions in Greenwich, their yachts and penthouses, from consciously acknowledging that their actions brought us to the brink and continue to endanger America’s economy and future.

Congress has known for some time that the structure of Wall Street and its Federal regulators is contributing to egregiously harmful cartel activity. In August 1976, the House of Representatives Committee on Banking, Currency and Housing released a report titled: Federal Reserve Directors: A Study of Corporate and Banking Influence.  The report drills down to one of the ongoing problems today:

“The big business and banking dominance of the Federal Reserve System cited in this report can be traced, in part, to the original Federal Reserve Act, which gave member commercial banks the right to select two-thirds of the directors of each district bank.  But the Board of Governors in Washington must share the responsibility for this imbalance. They appoint the so-called ‘public’ members of the boards of each district bank, appointments which have largely reflected the same narrow interests of the bank-elected members. The parochial nature of the boards affects the public interest across a wide area, ranging from monetary policy to bank regulation.  These are the directors, for example, who initially select the presidents of the 12 district banks—officials who serve on the Federal Open Market Committee, determining the nation’s money supply and the level of economic activity. The selection of these public officials, with such broad and essential policymaking powers, should not be in the hands of boards of directors selected and dominated by private banking and corporate interests.”

Following the financial crash in 2008, the Federal Reserve battled in court for years to avoid providing details of the money it funneled to the Wall Street banks and their global brethren during the years of the crisis. When the Federal Reserve lost that court battle, the Government Accountability Office (GAO) eventually issued a detailed report in 2011 that chronicled the mind-boggling secret Fed loans, all of which had been made at super low interest rates, many below 1 percent, without any public disclosure or authorization from Congress. The final tally came to $16.1 trillion in cumulative loans. (See Table 8 below from the GAO report.) It was not just Wall Street banks that got the bailout but their foreign competitors as well, as millions of families in the U.S. were foreclosed on by the same banks.

Since the crisis, the U.S. national debt has skyrocketed from $9 trillion to $19.5 trillion, more than doubling in just eight years while the $9 trillion took 232 years to accumulate while financing major wars and the Great Depression. In no small part, that debt growth came from the fiscal stimulus needed to shore up the economy as a result of the Wall Street-fueled financial collapse.

America needs to get its house in order before it loses its credit rating and its international reputation as a sane, well-managed country. Denying that we have a serious banking cartel problem is not going to get the job done.

GAO Data on Secret Emergency Lending Programs During  Financial Crisis

GAO Data on Secret Emergency Lending Programs During Financial Crisis

Update: This article has been updated to reflect that Richard Walker of Deutsche Bank was also a former Director of Enforcement at the SEC. Are you noticing a pattern here?

Coca-Cola Marketing Guru Secretly Worked Behind the Scenes to Brand Hillary as a Super Hero

By Pam Martens and Russ Martens: October 19, 2016

Wendy Clark Appears at a Fortune Magazine Forum, October 2016

Wendy Clark Appears at a Fortune Magazine Forum, October 2016

Emails released by WikiLeaks have led to the outing of an elaborate scheme to scour, buff and shine the decades of scandals attached to Hillary and Bill Clinton using the marketing, branding and messaging tricks employed by corporations to resuscitate a stale, discredited or sagging brand. We’ve also learned that at least one of those re-branders, Wendy Clark, had to sign a non-disclosure agreement with the Clinton camp, agreeing not to divulge details of her work. Clark acknowledged that agreement at a recent Fortune Magazine forum.

Clark is widely considered a corporate branding genius, having been responsible for the “Share a Coke” campaign at Coca-Cola which featured folksy names on the side of their cans and bottles. In January of 2015, it was reported that Clark was taking a three-month leave of absence from her demanding and high-level position as President of sparkling brands and strategic marketing in North America for the Coca-Cola Company. On April 6, 2015, a week before Hillary Clinton announced that she was a candidate for President, Coca-Cola announced that Clark was returning to her post at the company. (Clark is now CEO at DDB Worldwide, North America, a global advertising agency.)

But emails released by WikiLeaks show that Clark was consulting with the Clinton team before she took her leave from Coca-Cola. In this email dated December 8, 2014, long-time Clinton attorney and adviser Cheryl Mills writes to Clark about polling and branding. Mills indicates that Clark will be playing a major role, writing: “The process memo you are working on for today will help as I assume it will speak generally to the research you would need to do the branding or need to have done with you shaping it.”

In a February 14, 2015 email to a broad swath of corporate marketers, branders and polling experts that were already actively engaged in the Clinton campaign (despite the fact that Clinton had failed to alert the Federal Election Commission that she was conducting a campaign), Clark fleshes out more of her branding strategy. Clark writes:

“In the meeting last week the Secretary seemed to associate with what we had identified: fresh yet familiar, tenacity, resilience, empathy, creativity, action-oriented, future focused.”

In describing the logo, or “mark” that was in the works for the Clinton campaign, Clark writes in the same email:

“…the mark is, at the same time, anchored on the unassailable truth of Secretary Clinton’s life and career — being in service of others. It’s not about her, it’s about you…”

The logo, the “H” with the forward-facing arrow, was created by Michael Bierut, a partner at the international design firm, Pentagram. Bierut has worked on major corporate branding campaigns for Saks Fifth Avenue, Billboard Magazine, and the New York Jets, among numerous others.

Two of those copied on Clark’s February 14, 2015 email were Jim Margolis of GMMB and David Binder of David Binder Research. GMMB bills itself on its web site as follows:

“You may have a name. You may have a logo. But you move people with a brand…The road o building that brand can be loaded with emotional potholes, so we offer a proven process that gets everyone in your organization to a simple, inspiring idea to drive everything you do.”

The David Binder Research web site says it has “enjoyed a long-term ongoing partnership with President Barack Obama’s White House, providing award-winning messaging work and conducting research on a number of different initiatives.” Other clients, it says, include “large corporations.”

On March 26, 2015, Clark sent another email to Cheryl Mills and John Podesta, the man who would become Chair of the Clinton campaign. In it, she said there was more work to be done on “Humanizing Hillary with more films and avenues to do so.” Clark also included in this email a link to films that the Clinton team had reviewed that day, indicating that significant work on films and marketing had been done well in advance of Hillary Clinton filing with the Federal Election Commission to alert them that she was a fully functioning candidate for Federal office.

According to Federal election law, after a candidate spends $5,000 or more on their campaign, it must file a notification with the FEC and begin reporting contributions and disbursements. Hillary Clinton filed her notification with the FEC on April 13, 2015, but when her first quarterly filing was made, the FEC web site lists payments to Clark Advisory Services, LLC at the home address of Wendy Clark in Atlanta, Georgia in January 2015 and March 2015, when according to the FEC, there was no Hillary for America campaign account from which to make those payments, and another payment on April 14, 2015, one day after Clinton filed with the FEC. (The total of the three payments to Clark came to $49,998.)

FEC filings also show that Huma Abedin, a long time aide to Hillary Clinton, was paid from the Hillary for America campaign account at the rate of $6,769.25 every two weeks, beginning in January 2015 – three months before the campaign had established the Hillary for America campaign committee with the FEC.

Marc Elias at Perkins Coie is the lawyer for the Clinton campaign. Wall Street On Parade emailed him last evening to inquire how the campaign was able to make payments in January, February and March – when, according to the FEC, it didn’t exist. Thus far, we have not heard back from Elias. We will update this article should he choose to respond. (See related article below.)

Screen Shots from the Federal Election Commission for Payments Made by Hillary for America Campaign Committee

Screen Shots from the Federal Election Commission for Payments Made by Hillary for America Campaign Committee

Related Article:

Death of Shawn Lucas Brings Attention to DNC Role of Prestigious Law Firm

Why This Election Is All About Wall Street


By Pam Martens and Russ Martens: October 18, 2016 

Last Friday Senator Elizabeth Warren released a 12-page letter calling for President Obama to remove Securities and Exchange Commission Chair, Mary Jo White. For a female Senator and former Harvard Law professor to publicly humiliate a female Federal agency head and fellow lawyer is an extraordinary event. There is a code in Washington that women in power support other women in power. Warren didn’t just violate the code, she shredded it. 

Warren called Mary Jo White’s conduct as SEC Chair “brazen” and wrote that White was undermining the SEC’s central mission of investor protection. All of that is true as Wall Street On Parade repeatedly predicted it would be over three years ago. (See here and here.) Between White’s career at law firm Debevoise and Plimpton and her husband John W. White’s long term career at the international law firm Cravath, Swaine & Moore LLP, the two had represented every major Wall Street bank. John White went right on representing them after his wife took her seat as SEC Chair.

Of course, after Warren released her letter, President Obama was quick to reassure Wall Street that no change was coming. White House spokesman Eric Schultz promptly stated that “The president continues to believe that Chair White is the right leader for the Securities and Exchange Commission.”

In her letter, Warren had attempted to spin White’s derelict actions as an affront to the President’s wholesome agenda, writing that White is “undermining your Administration’s priorities….”

As our readers well know, we have never believed that President Obama has ever genuinely wanted to level the playing field for the average American. He could not have had that agenda and appointed the people he did to his cabinet and regulatory agencies.

Obama’s choice for U.S. Attorney General, Eric Holder, came from the law firm Covington & Burling which had fronted for Big Tobacco for decades and directly engaged in misleading the public about the devastating health impacts from smoking, according to a Federal court decision. (See Was the U.S. Justice Department Sold to the Highest Bidder.) Then Obama remained silent as the Justice Department failed to indict any Wall Street bank executives for the crimes leading up to the financial crash in 2008. As the PBS program Frontline reported, there were no subpoenas, no wiretaps, no investigations involving Wall Street banks at the Justice Department.

Less than three weeks after Obama had been elected to his first term, and before actually taking office, he announced his pick of Tim Geithner for U.S. Treasury Secretary. Geithner had been the head of the New York Fed and, unknown to the public at that time, had secretly funneled trillions of dollars in below-market rate loans to Wall Street and global banks without any authorization from Congress.

An equally scandalous appointment was Jack Lew as U.S. Treasury Secretary in Obama’s second term. Lew had been Chief Operating Officer in the very division of Citigroup that had imploded the bank, leading to the greatest financial bailout in U.S. history. While the bank was insolvent, Lew had accepted a $940,000 bonus from the firm. Lew, as part of his Citigroup perks, had invested in a fund in the Cayman Islands at the very street address that the President had called a tax scam.

Robert Scheer, writing at The Nation Magazine said at the time:

“I suppose that he can’t be much worse than Timothy Geithner, but that should be scant cause for cheer over the news that the president has nominated Jack Lew as Treasury secretary. Both championed the financial deregulation craze of the Clinton administration, and both are acolytes of Robert Rubin, the former Clinton Treasury secretary who unfettered Wall Street greed and then took his own considerable cut of the action.

“Rubin went to work at Citigroup, the world’s largest financial conglomerate whose legality was enabled by legislation he advanced while in government. He made off with a salary of $15 million a year during his decade at that bank, which specialized in toxic mortgage derivatives and had to be bailed out by taxpayers to avoid bankruptcy.”

We have been reporting on these and many other unsavory appointments by Obama throughout his two terms. After we unraveled the role that Wall Street banks and their lobbyists were playing in his election of 2008, there was little question as to how his administration would function in terms of Wall Street. (See Obama’s Money Cartel.)

Now that debate is over. With the release of emails by WikiLeaks showing that a Citigroup executive actually played an outsized role in staffing Obama’s administration, the public must accept the tragic reality that the President of the United States is little more than a titular figure head while the money men on Wall Street make all of the key decisions.

Why would Senators Elizabeth Warren and Bernie Sanders, both of whom have endorsed Hillary Clinton for President despite her labyrinthine money ties to Wall Street, think anything would be different this time around?

As WikiLeaks Access to Internet is Severed, New Clinton Email Bombshell Emerges


By Pam Martens  and Russ Martens: October 17, 2016

Robby Mook, Hillary Clinton's Campaign Manager

Robby Mook, Hillary Clinton’s Campaign Manager

According to the above statement from the WikiLeaks Twitter account, a state party has intentionally cut off access to the Internet for Julian Assange, the founder and Editor-in-Chief of WikiLeaks. This happened after the ninth consecutive day of releases of emails from the hacked account of John Podesta, the chair of Hillary Clinton’s presidential campaign committee. It also comes on the heels of a potentially serious campaign finance problem for the Hillary for America committee, the primary fundraising vehicle for Clinton, according to an email released by WikiLeaks just yesterday. This would be the second time in less than six months that the Clinton campaign’s finances have come under scrutiny.

In April and May of this year, Senator Bernie Sanders’ campaign charged the Clinton campaign with serious violations of campaign finance law, including “looting funds meant for the state parties to skirt fundraising limits on her presidential campaign,” and exploiting “the rules in ways that let her high-dollar donors like Alice Walton of Wal-Mart fame and the actor George Clooney and his super-rich Hollywood friends skirt legal limits on campaign contributions.”

The prior allegations play into the hands of the Trump camp which has consistently portrayed Hillary Clinton as someone who doesn’t care about fellow Americans but only herself and getting rich. The release of an email yesterday by WikiLeaks, together with others over the prior eight days, are making those charges harder to refute.

Robby Mook is Hillary Clinton’s Campaign Manager. According to numerous leaked emails, over many months in 2014 Mook was consulting and coordinating elaborate professional services for Hillary Clinton’s presidential campaign. Unfortunately, there were three major problems with this. Hillary Clinton had not told the Federal Election Commission that she was running a campaign; she wasn’t reporting contributions and expenditures; and Robby Mook, during this time, was being paid by Common Good PAC at the rate of approximately $10,000 per month. Common Good PAC is a Virginia Political Action Committee set up by Virginia Governor Terry McAuliffe, a long time Clinton loyalist. (The PAC had already been the target of negative publicity for offering private dinners with Governor McAuliffe and his wife in exchange for $100,000 donations, according to the Richmond Times-Dispatch.)

The deterrent for Hillary Clinton to set up the normal exploratory campaign vehicle was that throughout 2014 and into the spring of 2015, both Hillary Clinton and Bill Clinton were making millions of dollars giving paid speeches to global banks, corporations and corporate trade associations according to her financial disclosure report. Each of the Clintons received personal fees of typically more than $200,000 per speech. In an email dated November 18, 2014, long-time adviser to Clinton, Huma Abedin, wrote to other members of the Clinton camp: “We ended up locking in ALL her remaining paid speaking offers a few weeks ago. She reviewed them all with you at meeting so you know everything.” Those paid speeches for Clinton stretched into March of 2015, preventing her from declaring her candidacy without the need to dodge embarrassing questions on pay-to-play.

An October 7, 2014 speech that Hillary Clinton delivered on behalf of Deutsche Bank in exchange for a fee of $260,000 was particularly dicey. Just three months prior to this speech, the U.S. Senate’s Permanent Subcommittee on Investigations had conducted a hearing into how Deutsche Bank had engaged in a scheme with hedge funds to cheat the Internal Revenue Service out of billions of dollars in taxes. Just six months later, a unit of Deutsche Bank entered a guilty plea with the U.S. Justice Department for wire fraud and engaging in a price-fixing conspiracy.

In the email released by WikiLeaks yesterday, Mook decided to run his predicament by two campaign finance legal experts at the law firm Utrecht, Kleinfeld, Fiori, Partners on December 21, 2014. The two lawyers Mook wrote to, Lyn Utrecht and Eric Kleinfeld, had provided legal counsel to Hillary Clinton’s 2008 presidential campaign.

Mook titled his email: “Some questions – priviledged (sic).” Mook wrote:

“I am currently paid by a Virginia state political PAC which raises and spends unlimited and corporate. I will be re-locating to NYC the first week of January and will be assisting with preparation for a possible campaign. I want to make sure this won’t constitute any sort of in kind from the PAC.

“2. Vendors—payment

“My understanding is that vendors can begin work now but bill a committee when/if HRC decides to form one. Is that correct? If vendors need a deposit, or some sort of payment up front, would that be from HRC personally? Would the campaign then pay the full amount and that deposit be refunded back to her?

“3. Vendors—contracts

“If vendors start working on projects now and require a contract, who is named in the contract? Who is singing (sic) it…”

Mook’s prior leaked emails, however, show that campaign work started far earlier than December 2014. In an email dated March 22, 2014, Mook indicates that research has already apparently been ordered and is coming. Mook writes:

“The research coming should really help on this. I think her experience is part of the story since the research showed people see it as a strength but my guess is the key will be establishing her as a champion for the middle class and someone who can get the economy working for average people–and that will be shaped in contrast to her opponent. But the research will tell.”

On September 13, 2014, using the official email address of Terry McAuliffe, Mook sent an email and a 5-page attachment mapping out an intricate plan for setting up a campaign web site. The planned called for the following:

“Three designers will work on three mock-ups each: a ‘traditional/political’ look, a ‘modern/edgy’ look, and a look of the designer’s choosing.  We expect three rounds of revisions with the candidate participating in each one.”

The same email also indicated that “narrative messaging” was currently being worked on. Mook wrote:

“the biography section will feature videos, photos, and other pieces of content designed to share the candidate’s story. This will be based on the narrative messaging we’re working on now.”

By November 23, 2014, Mook emailed Hillary Clinton, her lawyer Cheryl Mills, and her soon to be campaign chair, John Podesta, three documents (see “attachments” tab) that outlined in great detail “early spending” needs, a “listening tour” and a “staffing timeline.”

The “early spending” memorandum, dated November 19 2014 indicated the following:

“This research program costs $2.1M and represents all polling, focus groups, and analytics that your team would have ideally completed by the time you officially announce you are running (i.e. at the end of your exploratory committee). This body of research should allow you to produce a well developed theory-of-the-case as to how you win the primary and general elections, with an especially detailed path in Iowa and New Hampshire.”

According to the Washington Post, as of December 11, 2014, Hillary Clinton had not set up an exploratory committee, the proper legal avenue for conducting all of these campaign activities. The Post reported:

“Clinton is also debating whether to establish an exploratory committee — a placeholder organization that would allow her to raise money to pay for consultants, office space and other operating expenses. But the move would trigger financial disclosures she can now avoid, and Clinton is getting a lot of advice against forming such a committee, two Democratic strategists said.

“An exploratory committee might also appear too coy for a previous candidate with obvious ambitions for a second try, according to several Democratic advisers, who, like others, spoke on the condition of anonymity because Clinton has not yet said she is running.”

None of the above prevented Mook from emailing Hillary Clinton and her advisers on January 29, 2015 that her first campaign hires had been completed. Mook wrote:

“Success! Madame Secretary, Congratulations–you have a very enthusiastic Communications Director and Deputy Communications Director. They are both charged up and ready for action. Kristina is ready to start next week and I’m working with Jen on a transition plan. They were both really positive about working with each other and you. As soon as we have COO, your core team will be in place! More to come…”

Hillary Clinton did not officially declare her candidacy for President of the United States until April 12, 2015. It was done via this youtube video. One day later, Clinton filed the required notification with the Federal Election Commission. Two days after that, Reuters sniffed out that the campaign had been in the works a lot longer than Clinton was acknowledging. The Clinton team was saying that this finely tuned video had been produced by an in-house team while the people in the video said they “were contacted, filmed and interviewed by Hardpin Media, a production company made up of filmmakers who worked on President Barack Obama’s 2012 re-election campaign.” Hardpin also shows the video as part of its “portfolio” on its web site. According to the first quarterly financial document filed with the FEC by Hillary for America, it paid Hardpin Media $53,646.45 on May 6, 2015 and another $18,588.13 on May 13, 2015.

According to Federal Election law, once an exploratory candidate spends more than $5,000 for campaign purposes, that individual is considered a functioning candidate for office under the law and is required to promptly file a Statement of Candidacy and Statement of Organization and begin filing regular donor and expense reports.

The Clinton campaign is now promoting the idea that when the other side goes low, it goes high. What actually seems to have happened repeatedly in this campaign is that the Clinton team goes covert.