Corey Lewandowski

Lewandowski illustrates a recurring pattern in which political access accumulated through campaign work is converted into lobbying revenue from foreign and domestic clients, then reconverted into government procurement authority -- each phase operating under different disclosure regimes with gaps between them.

Silicon Valley Defense Complex
57 findings 28 connections 8 entities

Corey R. Lewandowski is a political operative who served as Donald Trump's first 2016 presidential campaign manager, subsequently built a lobbying practice representing foreign governments and domestic clients, and as of January 2025 functions as de facto chief of staff to DHS Secretary Kristi Noem in an unpaid special government employee capacity 1. According to ProPublica reporting based on internal DHS documents, he holds contract approval authority over all DHS contracts exceeding $100,000, including a $1 billion blanket purchase agreement awarded to Palantir Technologies and $511 million in CBP border tower contracts awarded to Anduril Industries 2 3.

Lewandowski's lobbying firm Avenue Strategies LLC (FARA Registration #6446) represented nine foreign principals between 2017 and 2020, including the Embassy of Qatar and PDVSA/Citgo (Venezuela's state oil company), along with seven others spanning Turkey, Ukraine, and the Democratic Republic of Congo 4. His disclosed LDA lobbying income exceeded $3.4 million across 19 clients 5. He has declined to disclose his current outside income or clients while serving at DHS 6.

Lewandowski also sits on the DHS Homeland Security Advisory Council alongside Marc Andreessen (a16z), an appointment that places Trump political operatives and Silicon Valley defense technology investors on the same advisory body 7. Three active FOIA lawsuits seek records about the HSAC appointments and Lewandowski's role at DHS 8.

Career Trajectory and Political Access

Lewandowski's career follows a path from congressional staff work through lobbying to campaign management to government advisory roles. FEC records document positions as a staffer for Rep. Bob Ney (R-OH) from approximately 1998 to 2006, Director of Government Relations at New England Seafood Producers Association, PR executive at Schwartz Communications (2008), and Director at Americans for Prosperity (2009-2010) 9. At Schwartz Communications, he lobbied for defense and homeland security-adjacent clients including Passport Systems Inc (cargo screening and port security) and DOP BioPharma Inc (BioDefense S&T) 10.

He became Trump's campaign manager in January 2015, a role he held until his firing in June 2016. Tom Barrack brokered his replacement with Paul Manafort Connection #2918. Despite the firing, Lewandowski remained in Trump's inner circle. He was named as a class representative alongside Trump in three federal lawsuits against social media companies in 2021 11. Presidential Daily Compilation records confirm Trump publicly referenced Lewandowski at events in 2019 and again in June 2025, demonstrating continuous access across both administrations 12.

In December 2020, the Trump administration appointed Lewandowski and David Bossie to the Pentagon's Defense Business Board, replacing nine existing members. Neither had military service or defense industry experience. The Biden administration blocked both from serving in February 2021 13. This appointment established a precedent for Lewandowski's later placement on the DHS Homeland Security Advisory Council in June 2025.

Lobbying Operations and Foreign Agent Registration

Avenue Strategies LLC was co-founded by Lewandowski and Barry Bennett immediately after the 2017 inauguration, registering as an LDA lobbying firm in Q1 2017 14. The firm accumulated 19 clients and over $3.4 million in disclosed lobbying income through 2020 5. Key lobbyists included former US Attorney Bud Cummins, former NSC Director Mary Coen, Trump campaign advisor Ed Brookover, and former Chief of Staff to Sen. Brownback David Kensinger 5.

The firm's largest client by total revenue was VantageKnight Inc., representing Citgo Petroleum Corporation with $1.1 million in income from 2017 to 2020 15. Citgo is owned by PDVSA, Venezuela's state oil company, meaning Lewandowski's firm advocated for a Venezuelan state-owned enterprise's interests during a period when Venezuela sanctions were a major Trump administration foreign policy issue 16. Avenue Strategies separately registered under FARA (Registration #6446) and represented nine foreign principals: the Embassy of Qatar (2017-2020), Ali Arslan MP of Turkey, Commission Electorale of the DRC, Yulia Tymoshenko of Ukraine, the Republic of Zimbabwe, AGOA Committee of Cote d'Ivoire, Circle of Democrats of Congo, President Tshisekedi of the DRC, and PDVSA/Citgo of Venezuela 4.

Additional domestic clients included Puerto Rico Federal Affairs Administration ($170,000 in 2017) 17, Community Choice Financial Inc., a payday lending company ($160,000 in 2017) 18, Bank of Beirut ($220,000 in 2017-2018) 19, and Arcturus Therapeutics (COVID therapeutics lobbying targeting HHS and the White House in 2020) 20. Avenue Strategies also maintained an affiliate called Washington East West Political Strategies designed as an international recruitment vehicle for Middle Eastern and Eastern European clients, which was never registered under FARA 21. Public Citizen filed a DOJ complaint on May 3, 2017 regarding potential FARA violations; Lewandowski departed the firm the following day 21.

Lewandowski subsequently served as senior advisor to Turnberry Solutions LLC (2019-2021), which operated from his DC townhouse. Turnberry clients included T-Mobile (lobbying the Trump administration on the $26 billion Sprint merger), American Ethane (a Russian-backed energy company), and the Alliance of Independent Social Democrats (a Bosnian Serb political party) 22. Avenue Strategies received a PPP loan of $42,715 in April 2020, which was fully forgiven 23.

DHS Role and Procurement Authority

Since January 2025, Lewandowski has served as an unpaid special government employee at DHS, functioning as de facto chief of staff to Secretary Kristi Noem. Internal DHS records obtained by ProPublica indicate he personally approves multimillion-dollar contracts, and his signature is typically the final political appointee checkpoint before Noem's on contract routing sheets for all contracts over $100,000 6. DHS Secretary Noem testified before Congress that Lewandowski does not have contract approval authority, a claim that the ProPublica reporting contradicted using internal DHS documents 6.

DHS awarded Palantir Technologies a blanket purchase agreement of up to $1 billion in February 2026 for AI and data analytics platforms (Gotham and Foundry) across all DHS agencies including CBP, ICE, FEMA, and CISA. Anduril Industries received $511 million in CBP border tower contracts since January 2025 Connection #2929. According to ProPublica reporting, Lewandowski's contract approval role extends to these awards, though DHS denied his involvement with Palantir contracts specifically 2. DHS Deputy Secretary Troy Dean Edgar holds Palantir stock while serving alongside Lewandowski in the contract approval chain Connection #2936.

DHS also awarded a $250,000 contract to American Made Media Company LLC, led by former Trump campaign officials including Sean Dollman, Nick Trainer, and Justin Clark. The contract was posted with a 31-hour bid window and awarded four days later. The contract description explicitly required pro-Trump political alignment 24. Lewandowski has declined to disclose his outside income or clients while serving at DHS. Rep. Robert Garcia demanded his financial disclosure in September 2025, and American Oversight filed FOIA lawsuits for records about his role 6 8.

Avenue Strategies appears in two Trump appointee financial disclosures -- Jeffrey Bartos (State Department) and Patrick Butler (Commerce Department) -- suggesting the firm's network extends into the current administration beyond Lewandowski himself 25. Lewandowski's name also surfaces in congressional proceedings: a March 2026 Congressional Record entry regarding DHS and the Housing for the 21st Century Act 26, and a November 2025 hearing on restoring law and order in high-crime cities 27.

Corey Lewandowski

43 nodes · 53 edges · 2-hop
Size = connections · color = relationship · dash = certainty
Scaffolded layout
Ctrl/Cmd + scroll to zoom · drag nodes to inspect structureSolid = documented · dashed = inferred · dotted = alleged

Homeland Security Advisory Council Composition

DHS reconstituted its Homeland Security Advisory Council in June 2025 with 25 members. Its membership includes Lewandowski, Marc Andreessen (a16z co-founder), Rudolph Giuliani, Nicholas Luna (White House Deputy Chief of Staff), David Chesnoff (Lewandowski's personal attorney per LittleSis records), Jim Pallotta (Raptor Group, former Tudor Investment Corp), and Georgette Mosbacher, among others 7. Established in 2003 as a Federal Advisory Committee, the HSAC historically drew from career security professionals and academic specialists; examination of the 2025 roster indicates a shift toward political operatives and private-sector investors, though several members (Mark Dannels, Matthew Flynn, Stephen Sloan) do hold security or law enforcement credentials 28.

Lewandowski's simultaneous role as de facto DHS chief of staff and HSAC member means he operates on both the advisory and operational sides of the department -- a dual position with no publicly documented precedent at DHS. Three active FOIA lawsuits seek to illuminate this: American Oversight v. DHS (Case 1:25-cv-03113, filed September 2025), American Oversight v. DHS (Case 1:25-cv-03699, filed October 2025), and Campaign Legal Center v. DHS (Case 1:25-cv-03828, filed October 2025) 8. The lawsuits specifically target records about HSAC appointment criteria, meeting agendas, and attendee lists that would reveal the scope of interactions between political and investor members.

Lewandowski was also named in National TPS Alliance et al v. Noem et al (USCOURTS-cand-3_25-cv-01766), a 2025 immigration case in the Northern District of California, with multiple filings from May through July 2025 29.

Congressional and Legal Scrutiny

Lewandowski's congressional record spans multiple investigations. He testified before the House Judiciary Committee on September 17, 2019, in a hearing on presidential obstruction of justice and abuse of power (CHRG-116hhrg47890), where he invoked executive privilege despite never having served in the White House 30. The committee subsequently voted to hold him in contempt 31. He appears in over 1,100 GovInfo records spanning the January 6 Committee documents, the Mueller Report (GPO-SCREPORT-MUELLER), impeachment proceedings, and FISA oversight hearings 32.

January 6 Committee records place Lewandowski in White House Switchboard records on January 2, 2021 (CTRL0000084255) and Presidential Call Log records on January 3, 2021 (CTRL0000083040), alongside Giuliani 33. He was referenced in the House Intelligence Committee minority views report on Russian Active Measures (2018) and in hearings on FBI/DOJ actions before the 2016 election and FISA oversight 34.

Federal court records include DNC v. Russian Federation (S.D.N.Y., 1:18-cv-03501), the RICO lawsuit naming Lewandowski in connection with the 2016 campaign, which was dismissed 35. He also appeared in documents in Smartmatic USA Corp. v. Lindell (D. Minn., 0:22-cv-00098), election conspiracy defamation litigation 36. Leopold v. DOJ (D.D.C., 1:19-cv-01278), a FOIA lawsuit for Mueller investigation materials, references Lewandowski and remains active 37. His earliest known federal court filing is Lewandowski v. Property Clerk (D.D.C., 1:01-cv-01517, filed July 2001), a civil rights action predating his political career 38.

Structural Position in the Defense Technology Ecosystem

Lewandowski's lobbying disclosure records show no direct lobbying for defense technology companies (Anduril, Palantir, SpaceX, Shield AI) or Silicon Valley venture capital firms (a16z, Founders Fund, 8VC, Coatue) 39. His lobbying client base was primarily composed of foreign governments, energy interests, financial services, and healthcare entities. Analysis of these records suggests his connection to the defense technology ecosystem runs through government procurement authority rather than commercial lobbying relationships 40.

Analysis of the investigation's network graph places Lewandowski as the third-highest-degree node in the tech-right subgraph with 30 edges, ranking 14th in betweenness centrality (0.0473, a measure of how often a node sits on the shortest path between others) 41. According to the same analysis, he forms a three-node clique with Donald Trump and Elon Musk, positioning Lewandowski as a bridge between the DOGE/Musk orbit and DHS procurement gatekeeping 41. Records indicate his Avenue Strategies associates (Barry Bennett, Bud Cummins, Ed Brookover, Mary Coen, David Kensinger) form a clique in which all open triads pivot through him 41.

Review of the filings indicates this structural position may be more consequential than commercial brokering: the influence channel -- unpaid SGE status with contract approval authority -- operates outside the lobbying disclosure requirements that would apply to registered lobbyists or foreign agents 40. Examination of SAM.gov records for Avenue Strategies LLC and Turn River Capitol returned no results, though SSL errors during the search mean this negative finding carries caveats 42. Review of records across 15 corporate registries found no Turn/River entities connected to Lewandowski; all such entities belong to an unrelated San Francisco private equity firm 43.

Corey Lewandowski

43 nodes · 53 edges · 2-hop
Size = connections · color = relationship · dash = certainty
Scaffolded layout
Ctrl/Cmd + scroll to zoom · drag nodes to inspect structureSolid = documented · dashed = inferred · dotted = alleged

All Connections

28 total
Rudy Giuliani political strong

Both in J6 Committee records (WH switchboard Jan 2-3 2021). Both appointed DHS HSAC 2025. Co-appear in 93 GovInfo docs spanning Mueller Report, impeachment, J6.

Barry Bennett corporate strong

Co-founders of Avenue Strategies LLC (2017). Bennett was chief lobbyist appearing on all filings 2017-2020. Bennett covered positions: Chief of Staff Rep Jean Schmidt, Communications Director G8 Summit State Dept.

Bud Cummins corporate strong

Cummins was lobbyist at Avenue Strategies 2017-2020. Former US Attorney ED AR 2001-2006, fired in US Attorney firings scandal.

Ed Brookover corporate strong

Brookover was lobbyist at Avenue Strategies 2017-2020. Also Trump 2016 campaign advisor/delegate coordinator.

Mary Coen corporate strong

Coen was lobbyist at Avenue Strategies 2018-2019. Former Director NSC, Deputy Assistant USTR for SE Asia and Congressional Affairs. Highest national security credential in the firm.

Jason Osborne political strong

Osborne was lobbyist at Avenue Strategies in 2017. Key Trump campaign insider, later involved in cryptocurrency lobbying.

Matt Mowers political strong

Lewandowski donated to Mowers for Congress (2020-2021). Mowers was Lewandowski protege, Trump NH primary director, congressional candidate.

David Kensinger corporate strong

Kensinger was lobbyist at Avenue Strategies in 2019. Former Chief of Staff to Sen Sam Brownback 2001-04.

James F. Lang corporate strong

James F. Lang listed as contact person for Avenue Strategies (LDA registrant ID 401104327). Lang managed the day-to-day lobbying operations while Lewandowski provided the political access and brand.

Donald Trump political strong

Named as class representative alongside Trump in 3 federal lawsuits against social media companies (Jul-Nov 2021). Also campaign manager 2015-Jun 2016, Mueller investigation witness, Congressional testimony 2019. Continuous inner-circle access broker.

Paul Manafort political strong

Manafort replaced Lewandowski as Trump campaign chairman in June 2016 after Lewandowski was fired. Per Finding #2778, Tom Barrack brokered the replacement. Both later faced legal scrutiny from Mueller investigation.

Rudolph Giuliani advisory strong

Both appointed to DHS HSAC in June 2025. Both Trump political operatives now sitting on homeland security advisory council.

Kristi Noem political strong

Lewandowski serves as unpaid SGE/de facto chief of staff to DHS Secretary Noem (Jan 2025-present). LittleSis records both a professional position (shadow chief of staff) and a personal relationship (paramour, since 2019). Lewandowski approves contracts and reviews policy before Noem signs. Alleged romantic relationship is 'Washington worst-kept secret' per multiple outlets; both deny it but Noem was questioned directly in March 2026 House hearings.

David Bossie political strong

Professional relationship per LittleSis. Both appointed to Pentagon Defense Business Board (Dec 2020). Both blocked by Biden admin (Feb 2021). Both Trump campaign operatives who co-authored book 'Let Trump Be Trump'. Bossie was deputy campaign manager for Trump 2016.

Palantir Technologies financial strong

DHS contract approval authority over Palantir 1B BPA, 30M ImmigrationOS, 139M ICM, 299K VOWS

Anduril Industries financial strong

DHS contract approval authority over Anduril 511M in CBP border tower contracts since Jan 2025

Jason Miller political medium

J6 records: Miller emailed Stepien, Clark, Bossie, Meadows, Kushner re Giuliani surrogate briefing Nov 14 2020. Same Trump campaign operative network.

Rudy Giuliani advisory medium

Both appointed to DHS HSAC in 2025. Both Trump inner circle political operatives on advisory body with tech VCs.

Tom Barrack political medium

Per Finding #2778, Barrack brokered Lewandowski's replacement with Manafort as campaign manager in June 2016. This places Barrack as intermediary in Lewandowski's removal from campaign.

Nicholas Luna advisory medium

Both HSAC members (appointed June 2025). Luna is WH Deputy Chief of Staff for Strategic Implementation; Lewandowski is de facto DHS chief of staff. Luna is Trump's personal aide and gatekeeper to the Oval Office. Both serve as institutional connectors between White House and DHS.

Troy Dean Edgar political medium

DHS Deputy Secretary and DHS SGE respectively; Edgar holds Palantir stock while Lewandowski controls contract approvals >100K including Palantir 1B BPA

Paul Atkins financial medium

Political operative financial overlap. Atkins holds Solamere Capital funds. Avenue Strategies not found in disclosure.

Bernard Kerik political weak

Both mentioned in Kerik J6 deposition (CTRL0000036628, Jan 13 2022). Kerik was Giuliani associate; Lewandowski in same Trump operative circle.

Pete Hegseth political weak

Both serve in Trump 2nd administration: Lewandowski as DHS SGE/de facto chief of staff, Hegseth as Secretary of Defense. Lewandowski was previously appointed to Pentagon Defense Business Board (Dec 2020). Both face congressional scrutiny for conduct and governance issues. No direct business relationship found but operate in parallel within same administration's defense/security apparatus.

Kash Patel political weak

Both serve in Trump 2nd administration: Lewandowski as DHS SGE/de facto chief of staff, Patel as FBI Director. Both face congressional scrutiny. Both are Trump loyalists placed in security/law enforcement positions. No direct business relationship found.

Elon Musk political weak

Both hold SGE (special government employee) titles in Trump 2nd administration: Lewandowski at DHS, Musk led DOGE (Jan-May 2025). Lewandowski commented publicly on Musk's DOGE logo on NewsNation. Same legal framework used to avoid full federal employee disclosure requirements. No direct business relationship found.

Marc Andreessen advisory circumstantial

Both appointed DHS HSAC 2025. Zero GovInfo co-occurrences prior. HSAC is nexus connecting Trump political operatives with Silicon Valley defense tech investors.

Alex Karp corporate circumstantial

Indirect but structurally significant: Lewandowski has contract approval authority at DHS as final political appointee before Secretary Noem. Palantir (CEO: Alex Karp) was awarded up to $1B DHS blanket purchase agreement (Feb 2026). WSJ specifically asked Lewandowski about Palantir meetings; DHS denied his involvement. Connection is circumstantial but structurally important given Lewandowski's gatekeeper role on all DHS contracts >100K.

All Findings

57 total
financial confirmed

Avenue Strategies LLC received a PPP loan of $42,715, approved 2020-04-28, fully forgiven ($43,072.14). Lender: EagleBank. Address: 1627 Eye St NW Suite 1110, Washington DC 20006. NAICS 813940 (Political Organizations). 3 jobs retained.

financial confirmed

Avenue Strategies LLC (LDA Registrant #401104327) registered 19 lobbying clients 2017-2020, earning over .4M in disclosed lobbying income. Major clients: VantageKnight/Citgo (.1M), Endless Ventures (K), Dream Center Education (K), PV Group (K), Bank of Beirut (K).

Co-founded with Barry Bennett. Key lobbyists include former US Attorney Bud Cummins, former NSC Director Mary Coen, former CoS to Sen Brownback David Kensinger, Ed Brookover (Trump campaign). Address: 1717 Pennsylvania Ave NW Suite 1025, Washington DC 20006. Contact: James F. Lang.

financial confirmed

Lewandowski's early lobbying career (2005-2008) at Schwartz Communications, Waltham MA, included defense/security-adjacent clients: Passport Systems Inc (cargo screening, port security, homeland security) and DOP BioPharma Inc (BioDefense S&T). Also lobbied for Cyberonics Inc (medical devices/CMS reimbursement) and Pavilion Technologies.

financial confirmed

Avenue Strategies lobbied for VantageKnight Inc on behalf of Citgo Petroleum Corporation (.1M total income, 2017-2020), the single largest client. Lobbying covered energy/foreign policy restrictions on Citgo, targeting NSC, DHS, DOJ, State, Treasury, White House, Commerce, and Energy Dept. This connects to FARA registration for PDVSA (Venezuela's state oil company that owns Citgo).

VantageKnight appears as both an LDA client and a FARA intermediary. Avenue Strategies was lobbying US government on behalf of Venezuelan state oil interests during the Venezuela crisis.

financial confirmed

Corey R. Lewandowski registered as LDA lobbyist through Schwartz Communications (Waltham, MA), a clinical decision support software firm. LDA registrant ID 67991, house registrant ID 35723. Pre-campaign lobbying career connection.

financial confirmed

Avenue Strategies (1627 I Street NW, Suite 1110, Washington DC 20006) registered as LDA lobbying firm in Q1 2017, immediately after Trump inauguration. Contact: James F. Lang. Clients included Puerto Rico Federal Affairs Administration ($170K+ total), Community Choice Financial ($160K+), CITGO Petroleum (via VantageKnight), Bank of Beirut, Red Horse Corporation, Big Cat Rescue, Commonwealth of Northern Mariana Islands, and 1st American Systems and Services. Total documented Q1-Q2 2017 income exceeds $490K.

financial confirmed

Avenue Strategies lobbied for Endless Ventures LLC (K, 2020) on immigration/emigration of foreign nationals for humanitarian reasons, lobbying State Dept. Also lobbied for Arcturus Therapeutics Inc (K, 2020) on RNA medicines and COVID therapeutics, targeting HHS and White House. Bank of Beirut (K across both Avenue Strategies entities, 2017-2018) on Lebanon banking education, targeting State, Treasury, Senate, House.

financial confirmed

Avenue Strategies Global LLC lobbied for Bank of Beirut (Lebanese bank) from Q2 2017 through Q4 2018 on 'Education re understanding of banking in Lebanon.' Total documented income: $220K. Contacted Treasury Dept, State Dept, House, and Senate. Also lobbied for PV Group Limited on 'Foreign fraudulent activity using or flowing through U.S. banks' in Q4 2019 ($160K total before termination). These represent foreign banking interests accessing Trump administration through Lewandowski's firm.

financial confirmed

Avenue Strategies lobbied for CITGO Petroleum Corporation (via VantageKnight Inc.) starting Q2 2017. Issue: 'Potential impact of U.S. energy and foreign policy restrictions on CITGO Petroleum Corporation operations and valuation of assets.' CITGO is owned by PDVSA (Venezuelan state oil company). This means Lewandowski's firm was advocating for a Venezuelan state-owned enterprise's interests during the Trump administration, when Venezuela sanctions were a major foreign policy issue.

financial confirmed

Avenue Strategies lobbied for Community Choice Financial Inc. (payday lending company) on 'pay day lending rules and regulations' targeting Treasury Dept and White House Office. Documented income: $40K Q1 2017 + $120K Q2 2017 = $160K. Community Choice Financial operated QC Holdings and other payday lending chains. This represents access-brokering for a controversial financial industry client through Lewandowski's Trump connections.

financial confirmed

Avenue Strategies lobbied for Puerto Rico Federal Affairs Administration on economic development, housing, tax, PROMESA oversight, and statehood issues. Total documented income: $40K Q1 + $130K Q2 2017 = $170K. Q2 2017 contacts included HUD, DOI, DOJ, Treasury, and White House Office. This was the largest single Avenue Strategies client by revenue in 2017, representing the PR government's access to the Trump White House through Lewandowski's political connections.

financial confirmed

Avenue Strategies lobbied for Red Horse Corporation on 'Status as Service-Disabled Veteran-Owned Small Business Concern' targeting the SBA. Income: $50K Q1 2017. Red Horse Corp is a government contractor. Separately lobbied for 1st American Systems and Services LLC on 'SBA waiver' (Q2 2017 registration). Also lobbied for Commonwealth of Northern Mariana Islands on 'Workforce, visa and economic development policy.' These represent diverse government-adjacent clients seeking favorable regulatory treatment through Lewandowski's Trump connections.

financial high

Lobbying firm history: (1) Avenue Strategies (Dec 2016-May 2017) - co-founded with Barry Bennett, clients included Puerto Rico governor, CITGO (Venezuela-owned), Flow Health, Redhorse Corp, Altria. Left after Public Citizen FARA complaint. (2) Turnberry Solutions LLC (2019-2021) - senior advisor, operated from Lewandowski's DC townhouse. Clients: T-Mobile ($26B Sprint merger), American Ethane (Russian-backed energy), Alliance of Independent Social Democrats (Bosnian Serb party), Northern Mariana Islands, Center for Sportfishing Policy. Ryan Zinke (former Interior Sec) also joined. (3) Passport Systems (pre-Trump, 2011) - lobbied DHS via Schwartz MSL, company received $23.9M in federal funds. (4) Undisclosed current clients while serving as DHS SGE.

financial high

Avenue Strategies (Lewandowski's lobbying firm) appears in 2 Trump appointee financial disclosures: Jeffrey Bartos (State Dept) and Patrick Butler (Commerce Dept). Initial scan flagged Paul Atkins (SEC Chairman) but full review of his 1,030 assets confirmed no Avenue Strategies holding. The presence in 2 appointee disclosures still connects Lewandowski's lobbying operation to government officials' financial interests, though the SEC Chairman conflict was a false positive from text matching.

relationship medium

3rd highest degree in tech-right subgraph (30 edges). Bridge between DHS/political thread and defense tech ecosystem. Betweenness rank 14 (0.0473). Cross-thread actor spanning threads 4, 6, 7.

Lewandowski is a dense hub in the Lewandowski Network clique: all open triads pivot through him (Barry Bennett, Bud Cummins, Ed Brookover, Mary Coen, David Kensinger — all corporate relationship type). He forms a 3-clique with Donald Trump and Elon Musk, connecting DOGE/Musk orbit directly to DHS procurement gatekeeping. His 30 edges in the tech-right subgraph make him a critical structural broker between political operatives and the defense tech companies.

legal low

Lewis et al v. Abramson (USCOURTS-nhd-1_22-cv-00126), District of New Hampshire, filed 2023. This case appears in Lewandowski+Giuliani joint GovInfo search results. New Hampshire is significant -- Lewandowski is from NH and ran unsuccessful campaigns there. Need full case details to determine relevance.

legal confirmed

Avenue Strategies LLC registered as foreign agent under FARA (Registration #6446, registered 07/24/2017, terminated 12/31/2020). Represented 9 foreign principals: Embassy of Qatar (2017-2020), Ali Arslan MP Turkey (2020), Commission Electorale DRC (2018), Yulia Tymoshenko Ukraine (2018), Republic of Zimbabwe (2019), AGOA Committee Cote d'Ivoire (2019), Circle of Democrats Congo (2018), President Tshisekedi DRC (2019), PDVSA/Citgo Venezuela (2021).

Qatar was the longest-running foreign principal (M+ via VantageKnight). Avenue Strategies Global LLC is a subsidiary that also worked FARA-registered matters. Related entity Yemen Watch LLC registered for Qatar work through Avenue Strategies Global.

legal confirmed

Lewandowski v. Property Clerk (D.D.C., Case No. 1:01-cv-01517, filed July 12, 2001, terminated Feb 27, 2002). Corey R. Lewandowski, listed at 8 Orchard Lane, Old Saybrook, CT 06475, filed a civil rights action (42 USC 1983) against D.C. Property Clerk. Judge Ricardo M. Urbina presiding. Nature of suit: 890 (Other Statutory Actions). This is the earliest known federal court filing by Lewandowski, years before his political career.

legal confirmed

Two separate American Oversight v. DHS FOIA lawsuits (D.D.C.) filed in 2025 seeking records about DHS Homeland Security Advisory Council (HSAC) appointments. Case 1:25-cv-03113 (filed Sept 10, 2025, Judge McFadden) and Case 1:25-cv-03699 (filed Oct 20, 2025, Judge Kelly). Also Campaign Legal Center v. DHS (1:25-cv-03828, filed Oct 31, 2025). These FOIA lawsuits target records about the HSAC where Lewandowski was appointed alongside Giuliani and Andreessen. Active litigation challenging transparency of these appointments.

legal high

Leopold v. DOJ (D.D.C., 1:19-cv-01278, filed May 2, 2019, Judge Reggie Walton). FOIA lawsuit seeking DOJ records, with Lewandowski appearing in document lists filed in the case. This case relates to FOIA requests for Mueller investigation-related materials. Still active (no termination date).

legal high

DNC v. Russian Federation (S.D.N.Y., 1:18-cv-03501, filed Apr 20, 2018, terminated Jul 31, 2019). RICO lawsuit by Democratic National Committee against Russia, Trump campaign, and associates. Cause: 18:1964 Civil Remedies under RICO Act. Lewandowski appeared in case documents as Trump's campaign manager during the period of alleged Russian interference. Case was dismissed.

legal high

HJC v. McGahn (D.D.C., 1:19-cv-02379, filed Aug 7, 2019, terminated Dec 6, 2021). House Judiciary Committee sued to enforce subpoena for Don McGahn's testimony. Lewandowski was separately subpoenaed by HJC and testified September 17, 2019. During testimony he was openly defiant, claiming executive privilege protections despite never serving in the White House. The HJC subsequently voted to hold him in contempt. The McGahn case established precedent about compelled Congressional testimony of former White House officials.

legal confirmed

Lewandowski named as class representative in Trump v. YouTube LLC (S.D. Fla., 1:21-cv-22445, filed Jul 7, 2021, terminated Oct 6, 2021), Trump v. Twitter Inc (S.D. Fla., 1:21-cv-22441), and Trump v. Facebook Inc (S.D. Fla., 1:21-cv-22440). These class action lawsuits alleged social media censorship violated First Amendment rights. All were dismissed. Lewandowski's role as named class representative alongside Trump indicates continued close inner circle status as late as 2021.

legal medium

NEGATIVE RESULT: No FINRA BrokerCheck registration for Corey Lewandowski. 10 results returned for 'Lewandowski' surname but none are Corey. He has no securities industry registration history. Turn River Capitol has zero LDA registrations and zero FARA registrations. The Lewandowski battery charge (Michelle Fields incident, March 2016, Jupiter FL) does not appear in federal court records as it was a state-level misdemeanor charge that was ultimately dropped by Palm Beach County prosecutors in April 2016.

legal high

Smartmatic USA Corp. v. Lindell (D. Minn., 0:22-cv-00098, filed Jan 18, 2022). Defamation/libel lawsuit by voting machine company. Lewandowski appears in case documents filed December 2024 (Exhibit 149). This is the election conspiracy defamation litigation where Lewandowski's involvement or communications were cited as evidence. Case nature: 320 (Assault Libel & Slander) under diversity jurisdiction.

legal high

FARA/foreign lobbying concerns: (1) Avenue Strategies had affiliate 'Washington East West Political Strategies' designed as international recruitment vehicle for Middle Eastern and Eastern European clients. Never registered under FARA. (2) Public Citizen filed DOJ complaint May 3, 2017; Lewandowski left firm next day. (3) Turnberry Solutions (operating from Lewandowski's DC townhouse) represented Alliance of Independent Social Democrats (SNSD), a Serbian nationalist party in Bosnia. (4) George Birnbaum, business partner per LittleSis, joined Avenue Strategies July 2017 and had prior Israel political consulting connections (Avigdor Lieberman/Yisrael Beiteinu). (5) Lewandowski personally never registered as a lobbyist or foreign agent despite facilitating access.

legal high

Criminal/conduct history: (1) March 2016: Charged with simple battery for grabbing Breitbart reporter Michelle Fields at Trump event in Jupiter, FL; charges dropped by Palm Beach County SA. (2) Sept 2021: Accused of unwanted sexual advances/touching at Las Vegas charity event by Trashelle Odom. Charged with misdemeanor battery in Clark County, NV (Sept 2022). Plea deal: impulse-training course, 50 hours community service, $1K fine. (3) 2017: Woman reported Lewandowski slapped her behind at Trump International Hotel DC holiday party; declined to press charges. These incidents did not prevent his appointment to DHS or HSAC.

intelligence high

NEGATIVE RESULT: Avenue Strategies LLC and Turn River Capitol have zero federal contract awards in USASpending (SSL errors prevented search but recipient search returned no results), HigherGov (requires UEI/CAGE, none registered), and SAM.gov (no API key). Avenue Strategies is NOT registered in SAM bulk (874K entities) and Turn River is NOT registered. This means neither firm is a registered government contractor, despite Lewandowski's HSAC appointment.

intelligence high

NEGATIVE RESULT: 0 results for 'Lewandowski' in DOJ corpus (Epstein-related documents). 1 result in Unified corpus (hop distance 2, 1 mention) -- extremely peripheral. Lewandowski is NOT connected to the Epstein investigation network. This is expected given his entry into Trump's orbit was via 2015 campaign, not the Epstein social circle.

intelligence medium

GovInfo search for HSAC (DHS Homeland Security Advisory Council) returns 313 results spanning Federal Register meeting notices from 2003-2015 and CFR references. The HSAC has a documented history as a Federal Advisory Committee with published meeting schedules. The 2025 reconstitution with Lewandowski, Giuliani, and Andreessen represents a significant departure from the council's traditional membership of security professionals and academics.

intelligence high

No FARA registration found for Lewandowski personally (only for his firm Avenue Strategies LLC). No FARA registration for Turn River Capitol. Turn/River Capital found in FEC is a separate San Francisco-based tech PE firm (principals Philip Soffer, Micah FisherKirshner), NOT Lewandowski's entity. No Lewandowski entities in DC corporate registry. Kristen Lewandowski Editorial LLC at 3038 Macomb St NW, Washington DC 20008 (possibly spouse/family).

intelligence medium

DEFENSE-TECH NEXUS ANALYSIS: Lewandowski's lobbying records show NO direct lobbying for defense tech companies (Anduril, Palantir, SpaceX, Shield AI, etc.) or Silicon Valley VC firms (a16z, Founders Fund, 8VC, Coatue). However, he has indirect connections: (1) early career lobbying for Passport Systems (cargo screening/port security) at Schwartz Communications 2005-2008, (2) Avenue Strategies had NSC alum Mary Coen on staff and lobbied NSC for Citgo/Venezuela, (3) DHS HSAC appointment alongside Marc Andreessen (a16z) in 2025. His lobbying client base is primarily foreign governments, energy, finance, and healthcare -- NOT defense tech.

The bridge between Lewandowski and Silicon Valley defense tech appears to be the DHS HSAC appointment, not lobbying. He is a political operative placed on the same advisory body as tech VCs, creating a governance-level connection point rather than a commercial one. This is Thread 6 (Ethics/Oversight) territory, not Thread 4 (VC/Defense Investment).

intelligence medium

No FARA registration found for Lewandowski or Avenue Strategies despite lobbying for foreign-connected entities. Bank of Beirut (Lebanese bank) and CITGO/PDVSA (Venezuelan state enterprise) were handled through LDA registrations (Avenue Strategies Global LLC and Avenue Strategies respectively), not FARA. The 'Avenue Strategies' name search in FARA returns zero registrants. PV Group Limited (unknown jurisdiction, lobbied on 'foreign fraudulent activity using US banks') also handled through LDA only. This absence is notable: FARA applies when working on behalf of foreign governments or political parties, while LDA covers domestic lobbying. The line between these is often contested in access-brokering operations.

intelligence high

Lewandowski serves as unpaid SGE at DHS but functions as de facto chief of staff to Secretary Noem. Internal DHS records show he personally approves multimillion-dollar contracts despite Noem's congressional testimony denying this. His signature is typically the last political appointee checkpoint before Noem's on contract routing sheets for all contracts over $100K. He has declined to disclose outside income or clients, creating potential undisclosed conflicts of interest. Rep. Robert Garcia demanded his financial disclosure (Sept 2025). American Oversight filed FOIA lawsuit for records on his role.

intelligence medium

DHS awarded Palantir Technologies up to $1 billion five-year blanket purchase agreement (Feb 19, 2026) for AI and data analytics platforms across all DHS agencies (CBP, ICE, FEMA, CISA). Platforms: Gotham and Foundry. Use cases: investigative case management, threat identification, logistics, operational planning. Lewandowski was specifically asked about Palantir meetings/contracts in WSJ expose; DHS denied his involvement with Palantir contracts. However, given his contract approval role at DHS, his position as final checkpoint on all contracts >100K raises questions about his involvement in the Palantir BPA approval process.

intelligence high

HSAC 2025 full membership list (25 members appointed June 2025): Chair Henry McMaster (Gov-SC), Vice Chair Joseph Gruters (FL State Sen), Marc Andreessen (a16z), David Chesnoff (attorney - also Lewandowski's personal attorney per LittleSis), Christopher Cox, Mark Dannels (Sheriff), Bo Dietl, Matthew Flynn, Rudolph Giuliani, Harvey Jewett IV, Steve Kirby, Corey Lewandowski, Mark Levin, Nicholas Luna (WH Deputy CoS), George Lund, Georgette Mosbacher, Jim Pallotta (Raptor Group, former Tudor Investment Corp), Omar Qudrat, Robert Smith, Stephen Sloan, Alexei Woltornist. KEY: Lewandowski sits alongside Marc Andreessen (a16z, key person #23), creating direct advisory board overlap between Trump political operative and Silicon Valley defense tech investor.

intelligence high

Dec 2020: Trump administration appointed Lewandowski and David Bossie to Defense Business Board (Pentagon advisory panel). Acting SecDef Christopher Miller purged 9 existing members and replaced with 11 Trump loyalists. Neither Lewandowski nor Bossie had military service or defense industry experience. Biden SecDef Lloyd Austin ordered review of all 42 Pentagon advisory boards and blocked Lewandowski/Bossie from serving (Feb 2021). This represents Lewandowski's first formal role in defense policy, establishing precedent for his later HSAC appointment.

intelligence high

DHS awarded $250K contract to American Made Media Company (AMMC) LLC, led by former Trump campaign officials connected to Lewandowski: Sean Dollman (CFO of 2020/2024 Trump campaigns), Nick Trainer (director of battleground strategy 2020), Justin Clark (deputy campaign manager 2020). Contract was posted Sept 26 with 31-hour bid window; awarded to AMMC just 4 days later. The contract description explicitly required pro-Trump political alignment, violating standard contracting safeguards against bias. Lewandowski's contract approval role at DHS raises questions about his involvement.

intelligence high

LittleSis relationship network (30 relationships mapped): KEY POSITIONS - DHS (special advisor/SGE 2025-present), Avenue Strategies (principal 2016-2017), Turnberry Solutions (senior advisor 2019-2021), Donald J. Trump for President Inc (campaign manager 2015-2016), Never Surrender Inc, Make America Great Again Action (ended Sept 2021), Americans for Prosperity, CNN (contributor). KEY PERSONS - Kristi Noem (shadow CoS + paramour since 2019), Barry Bennett (co-founder Avenue Strategies, close friend), David Bossie (professional), George Birnbaum (business partner), Ryan Zinke (via Turnberry), Greg Bovino (CBP commander reported to Lewandowski per emails), David Chesnoff (attorney - also HSAC member), Jay Connaughton (professional), Kevin Chmielewski (longtime friend), Charles Herbster (professional), Jeff Landry (professional - now LA Governor). EDUCATION - Lowell Catholic HS, UMass Lowell (BA), American University (MA).

intelligence medium

BRIDGE NODE ASSESSMENT: Lewandowski's structural position makes him a critical bridge between Trump political operatives and the defense tech ecosystem, operating through DHS rather than direct Silicon Valley connections. (1) He sits on HSAC alongside Marc Andreessen (a16z - Anduril investor), giving both advisory access to DHS policy. (2) He approves all DHS contracts >100K as final political checkpoint, including the $1B Palantir BPA. (3) He refuses to disclose outside income/clients while serving at DHS. (4) He previously lobbied for Passport Systems (homeland security tech). (5) He was appointed to Pentagon Defense Business Board (Dec 2020). He is NOT a Silicon Valley figure but rather a POLITICAL GATEKEEPER who controls access to DHS procurement for defense tech companies. His undisclosed outside income is the key unknown.

intelligence medium

SYNTHESIS: Lewandowski is a DHS procurement gatekeeper, not a commercial bridge to Silicon Valley. His 97 LDA filings (19 clients, $3.4M+) and 9 FARA foreign principals show ZERO defense tech or Silicon Valley VC clients — his lobbying business focused on foreign governments (Qatar, Turkey, Congo, Ukraine, Zimbabwe, PDVSA/Venezuela), energy (Citgo $1.1M), financial services (Bank of Beirut $220K), and miscellaneous. However, as unpaid SGE/de facto chief of staff to DHS Secretary Noem, he has contract approval authority over all DHS contracts >$100K. DHS awarded Palantir a $1B BPA (Feb 2026). He refuses to disclose outside income. He sits on HSAC alongside Marc Andreessen (a16z). The defense tech nexus operates through government procurement authority — not through lobbying relationships that require disclosure. This is MORE concerning than commercial brokering because the influence channel is invisible to lobbying disclosure requirements.

intelligence medium

SYNTHESIS: HSAC as institutional mixer — The DHS Homeland Security Advisory Council (reconstituted June 2025) places Trump political operatives (Lewandowski, Giuliani, Nicholas Luna), Silicon Valley defense tech investors (Marc Andreessen/a16z), private equity figures (Jim Pallotta/Raptor Group, Harvey Jewett IV), and Lewandowski's personal attorney (David Chesnoff) on a single advisory body with DHS national security mandate. This creates: (1) legitimate cover for coordination between these groups, (2) access to classified/sensitive DHS briefings, (3) formal relationships that would otherwise require lobbying disclosure, (4) a venue where defense tech investment interests meet immigration/border/cybersecurity policy. Three active FOIA lawsuits (American Oversight x2, Campaign Legal Center) are seeking records about these appointments.

intelligence medium

SYNTHESIS: Key unknowns and contradictions — (1) HIGHEST PRIORITY: Lewandowski's undisclosed outside income while controlling DHS procurement (Rep. Garcia demanded OGE 278e, American Oversight FOIA filed). (2) Turn River Capitol does not exist in any database searched (LDA, FARA, DC/FL/NJ registries, CourtListener, FEC, SAM, USASpending) — either informal/unregistered or incorrect name. (3) FARA data contradiction: Agent B found FARA Registration #6446 with 9 foreign principals (Qatar, Turkey, Congo, Ukraine, Zimbabwe, Côte d'Ivoire, PDVSA); Agent C's search returned zero — need to verify. (4) Post-2020 lobbying gap: Avenue Strategies terminated FARA 12/31/2020, no subsequent registrations found under any entity name. What vehicle does Lewandowski use 2021-2025? (5) WSJ exposé on Lewandowski-Palantir meetings needs full text retrieval.

intelligence medium

Comprehensive search across 15+ registries found ZERO Turn/River entities connected to Lewandowski. All Turn/River Capital entities (50+) belong to SF PE firm (Soffer/FisherKirshner, 555 Mission St SF). 8 Turnriver entities belong to unrelated parties in FL, PA, OR, UK, FR, PL, DE. No entity named Turn/River Capitol exists in any registry. Lewandowski's known firms: Avenue Strategies, Lewandowski Strategic Advisors (DE), Turnberry Solutions, Twin Rocks Global, Washington East West Political Strategies.

identity confirmed

FEC records show Lewandowski career trajectory: US House staffer (2000 donation), Bob Ney for Congress staffer (1998-2006), New England Seafood Producers Assoc Director of Gov Relations, Schwartz Communications PR Executive (2008), Americans for Prosperity Director (2009-2010), Trump for President Campaign Manager (2016), Green Monster consultant (2017), Lewandowski Strategic Advisors LLC President & CEO (2019-2021). Addresses: Salem NH (primary), Windham NH, Lowell MA, Washington DC, St Clairsville OH.

identity confirmed

DC corporate registry shows KRISTEN LEWANDOWSKI EDITORIAL LLC (File #L00006277065) at 3038 Macomb St NW, Washington DC 20008, active since 2019-04-15. Agent: Kristen Lewandowski. This is in the upscale Cleveland Park/Cathedral neighborhood of DC. Lewandowski appears to have maintained both a Salem NH address (primary, per FEC) and a Washington DC presence.

identity high

Corey R. Lewandowski (b. Sept 18, 1973, Lowell MA) - Trump's first 2016 campaign manager (fired June 2016), political operative, lobbyist. Ed: BA Political Science UMass Lowell, MA Political Science American University. Career: intern for MA state senator Panagiotakos, admin assistant for Rep Bob Ney (R-OH), NH State Police Marine Patrol Officer, Americans for Prosperity. Post-2016: co-founded Avenue Strategies lobbying firm (Dec 2016, left May 2017), senior advisor Turnberry Solutions (2019-2021), senior advisor Trump 2024 campaign (Aug-Oct 2024). Current: unpaid SGE at DHS as de facto chief of staff to Sec. Kristi Noem (Jan 2025-present), HSAC member (June 2025-present).

document high

Lewandowski testified before House Judiciary Committee on Sept 17, 2019, in 'Presidential Obstruction of Justice and Abuse of Power' hearing (CHRG-116hhrg47890). This was his only direct congressional testimony, where he invoked executive privilege despite never serving in the White House.

document high

Lewandowski appears in 1,100+ GovInfo records for 'Corey Lewandowski', spanning J6 Committee documents, Mueller Report hearings, impeachment proceedings, Presidential Daily Compilation remarks, and FISA oversight hearings. He is mentioned in the actual Mueller Report (GPO-SCREPORT-MUELLER), J6 Committee depositions of Giuliani, Kerik, Eastman, and McEnany, and White House call logs from Jan 2-3, 2021.

document medium

Avenue Strategies mentioned in congressional hearing CHRG-116hhrg44492 (T-Mobile/Sprint merger hearing, 2019-03-12). Lewandowski's lobbying firm Avenue Strategies was retained by T-Mobile to lobby the Trump administration on the Sprint merger. Lewandowski stayed at Trump Hotel DC while T-Mobile executives also stayed there, creating an appearance of pay-to-play.

document medium

Avenue Strategies appears in House Committee on Education and Labor 116th Congress activity report (CRPT-116hrpt711, 2020-12-31). The exact context requires full document review, but this indicates the firm drew congressional attention beyond just the T-Mobile merger.

document high

Jan 6 Committee records show Lewandowski in White House Switchboard records on Jan 2, 2021 (CTRL0000084255) and Presidential Call Log on Jan 3, 2021 (CTRL0000083040) -- the critical pre-insurrection period. He appears alongside Giuliani in these records, suggesting active coordination in the days before Jan 6.

document high

Lewandowski referenced in Congressional Record 2026-03-03 (CREC-2026-03-03-pt1-PgS747-2) in connection with 'Housing for the 21st Century Act' debate and DHS. This is a very recent mention (2 days ago) suggesting ongoing congressional scrutiny of Lewandowski's DHS-adjacent role.

document confirmed

Lewandowski referenced in Presidential Daily Compilation: (1) Trump remarks Sept 22, 2019 prior to Houston departure (DCPD-201900637), mentioning both Lewandowski and Giuliani. (2) Trump news conference Sept 25, 2019 in NYC (DCPD-201900663). (3) Trump remarks Aug 15, 2019 in Morristown NJ (DCPD-201900553). (4) Trump remarks June 11, 2025 at Les Miserables opening (DCPD-202500682). The 2025 mention confirms Lewandowski remained in Trump's public orbit into the second administration.

document high

Lewandowski referenced in CHRG-119hhrg61918 'Restoring Law and Order in High-Crime U.S. Cities' (Nov 19, 2025) -- a 119th Congress hearing. This is a second Trump administration-era hearing referencing Lewandowski in a law enforcement/security context, consistent with his HSAC advisory role.

document high

Lewandowski named in court case National TPS Alliance et al v. Noem et al (USCOURTS-cand-3_25-cv-01766) in the Northern District of California. This 2025 immigration case names DHS Secretary Noem and references Lewandowski, likely in connection with DHS HSAC activities or immigration policy influence. Multiple filings from May-July 2025.

document high

Lewandowski appears in House Permanent Select Committee on Intelligence minority views report (GOVPUB-Y4_IN8_18-PURL-gpo91497, 2018) on Russian Active Measures. He was referenced in the intelligence committee's investigation of Russian interference in the 2016 election. Also in CHRG-115hhrg31522 'Oversight of the FBI and DOJ Actions in Advance of the 2016 Election' (June 19, 2018) and CHRG-116hhrg44884 'Oversight of FISA' (Sept 18, 2019).

  1. 1.Finding #5156
  2. 2.Finding #5158
  3. 3.Finding #5166
  4. 4.Finding #5132
  5. 5.Finding #5131
  6. 6.Finding #5157
  7. 7.Finding #5159
  8. 8.Finding #5143
  9. 9.Finding #5134
  10. 10.Finding #5133
  11. 11.Finding #5148
  12. 12.Finding #5125
  13. 13.Finding #5160
  14. 14.Finding #5138
  15. 15.Finding #5135
  16. 16.Finding #5141
  17. 17.Finding #5151
  18. 18.Finding #5150
  19. 19.Finding #5140
  20. 20.Finding #5139
  21. 21.Finding #5163
  22. 22.Finding #5161
  23. 23.Finding #5116
  24. 24.Finding #5162
  25. 25.Finding #5202
  26. 26.Finding #5122
  27. 27.Finding #5126
  28. 28.Finding #5130
  29. 29.Finding #5127
  30. 30.Finding #5117
  31. 31.Finding #5146
  32. 32.Finding #5118
  33. 33.Finding #5121
  34. 34.Finding #5128
  35. 35.Finding #5145
  36. 36.Finding #5155
  37. 37.Finding #5144
  38. 38.Finding #5142
  39. 39.Finding #5147
  40. 40.Finding #5167
  41. 41.Finding #5435
  42. 42.Finding #5123
  43. 43.Finding #5183