Personnel Policy Operations

PPO PASS-THROUGH STRUCTURE CONFIRMED: CPI granted 1.15M (2022) and 880K (2023) to PPO. PPO then granted 1.13M (2022) and 429K (2023) to Constitutional Rights Defense Fund, a 501c4 with no online presence. PPO spokesperson confirmed funds paid legal bills for Mark Meadows and Jeffrey Clark. This is a documented c3-to-c4 pass-through: CPI (c3) -> PPO (c3) -> CRDF (c4) -> defense attorneys. Both CPI and PPO share address at 300 Independence Ave SE DC 20003.

PPO COMPLETE FUNDING SOURCES (2022-2024): CPI 1.15M (2022) + 880K (2023) = 2.03M. Leandro P Rizzuto Foundation 1M (2024). Vanguard Charitable Endowment 500K (2024). Donor Advised Charitable Giving Inc 110K (2024) — same entity gave 160M to 85 Fund (Leonard Leo) in 2024. The Dunn Foundation (Tim Dunn) 87.5K (2024). Tree of Life Foundation 50K (2022). PPO revenue trajectory: 1.43M (2022), 2.05M (2023), 4.55M (2024). PPO is diversifying away from CPI dependence with new major donors.

PPO COURAGE UNDER FIRE LEGAL DEFENSE FUND — SPENT 3M+ DEFENDING TRUMP-ALIGNED OFFICIALS: Confirmed recipients include Mark Meadows (former WH Chief of Staff, indicted GA), Jeffrey Clark (former AAG, indicted GA), John Eastman (indicted GA, disbarred CA), Peter Navarro (convicted contempt of Congress), Mike Roman (former Trump campaign operative, indicted GA), and six Nevada fake electors (100K for legal fees, case dismissed on venue grounds). PPO spokesperson confirmed the pass-through to CRDF in 2022 went to Meadows and Clark defense costs. Washington Post reported 3M+ total spent and Tim Dunn helped seed the fund.

PPO IS PROJECT 2025 ADVISORY BOARD MEMBER AND SCHEDULE F IMPLEMENTATION VEHICLE: LittleSis confirms PPO is Advisory Board Member of Project 2025 (Heritage Foundation). PPO launched database to review federal employees for alignment with America First agenda. PPO founder Kloster returned to OPM as GC in Jan 2025 and OPM immediately began issuing memos to strip protections from career employees under Schedule Policy/Career (renamed Schedule F). PPO founder Hemenway was one of three heads of the Project 2025 team at Heritage. PPO thus serves dual function: (1) legal defense fund for indicted Trump allies and (2) personnel vetting pipeline for government placement.

PPO GOVERNMENT PLACEMENT PIPELINE — 3 OF 5 OFFICERS NOW IN TRUMP 2.0 GOVERNMENT: (1) Andrew Kloster: OPM General Counsel (Jan 2025), managing Schedule F implementation. (2) Joshua Whitehouse: PPO Treasurer, former WH liaison to DHS/DoD. (3) Matthew Buckham: HHS Chief of Staff under RFK Jr, previously WH liaison to HHS and oversaw political appointee recruitment. He previously co-founded American Accountability Foundation (CPI satellite). Also Alexei Woltornist appointed to Homeland Security Advisory Council (Jun 2025). Hemenway was Project 2025 senior advisor for personnel placement at Heritage. PPO is effectively a revolving door between conservative nonprofit sector and federal government personnel operations.

ACCOUNTABLE.US FILED DC AG COMPLAINT AGAINST CPI AND PPO (July 2024): Alleges CPI violated nonprofit status by funneling 1.2M through PPO to Constitutional Rights Defense Fund for Meadows legal defense. Complaint argues CPI has been operating exclusively for the benefit of the Republican Party. Seeks immediate dissolution of both organizations under DC law. CRDF has no online presence, no EIN found in IRS databases, filed a corporate income tax return rather than a nonprofit return. CRDF representative Thomas Datwyler described it as a nonprofit corporation but it was listed as 501c4 on PPO forms despite no IRS determination letter being found.

PPO LEADERSHIP — ALL THREE FOUNDERS FROM TRUMP PRESIDENTIAL PERSONNEL OFFICE, TWO RETURNED TO GOVERNMENT: (1) Troup Hemenway — President/Exec Director, former Associate Director of WH Presidential Personnel Office (defense/IC portfolio), then Heritage Project 2025 senior advisor for personnel placement. (2) Andrew Kloster — General Counsel, former Deputy GC then Acting GC of OPM, returned to OPM as General Counsel Jan 2025. (3) Joshua Whitehouse — Treasurer (from Feb 2024), former WH liaison to DHS and DoD, Special Assistant to President in PPO. Board also includes Matthew Buckham (Secretary, co-founder of American Accountability Foundation, former WH Presidential Personnel Office) and Alexei Woltornist (Treasurer until Feb 2024, former DHS Asst Sec for Public Affairs, now on Homeland Security Advisory Council).