The Referral — What Your Agency Needs, Where the Evidence Is, and Why You Should Have Already Acted

You’ve Seen This Before

In 2008, two judges in Luzerne County, Pennsylvania — Mark Ciavarella and Michael Conahan — were convicted of taking $2.6 million in kickbacks from private juvenile detention facilities. In exchange, they sentenced thousands of children to those facilities. Many for trivial offenses. Some for nothing at all.

It was called Kids for Cash. Ciavarella got 28 years. Conahan got 17.5 years. The Pennsylvania Supreme Court vacated 4,000 juvenile convictions. The Third Circuit upheld a $206 million civil judgment.

The pattern was:

This is Cash for Kids 2. Same pattern. Different city. Different mechanism. Same children paying the price.

Kids for Cash (PA)Cash for Kids 2 (Detroit)
OperatorPA Child Care / Western PA Child CarePurpose Group LLC / Banks
Judicial capture2 judges took $2.6M in kickbacks7 judges connected to enterprise — campaign payments, board seats, family ties
Financial gatekeeperRobert Mericle (facility builder)Joseph Holland Jr. (MDOC #443789, convicted drug dealer)
Children affected~4,000 juveniles sentenced362 students enrolled (3% math proficiency)
Money extracted$2.6M in kickbacks$60M+ over 14 years ($4.28M/yr, 72.67% extraction rate)
Institutional shieldCounty court systemAG employee on board, law firm managing both sides, 7 captured courts
How it was exposedIntrepid Reporting / juvenile law centerOne parent. Public records. A graph.
How long it ran~5 years (2003–2008)21 years and counting (2003–present)

In Pennsylvania, it took the FBI. A federal grand jury. A U.S. Attorney who didn’t flinch.

Detroit is still waiting.


To Every Agency Listed Below

This page is a direct referral. Each section is addressed to a specific agency or organization. Each section contains:

  1. What you investigate — your statutory jurisdiction
  2. What was violated — the specific laws
  3. Where the evidence is — with links
  4. What you should do — the specific action

The full evidence repository is public and free:

git clone https://github.com/defendDetroit/publicRecord.git

Mirror: git clone https://github.com/amicusContra/tuebor.git

362 children walk into these schools every day. Every day you don’t act is a day they lose.


I. FBI — Detroit Field Office

You already have the packet. Delivered September 22, 2026. 243 pages.

Your Jurisdiction

StatuteViolationEvidence
18 U.S.C. § 1962Federal RICO15 predicate acts, 21 years, $60M+ extraction
18 U.S.C. § 1341Mail fraudPPO served via USPS, forged return receipts (Leon Smith, USPS employee)
18 U.S.C. § 1343Wire fraudElectronic solicitation of donations using false credentials (J.D. claim)
18 U.S.C. § 1951Hobbs Act (extortion)PPO filed to silence complainant — public official using court to suppress investigation
18 U.S.C. § 1956Money laundering$4.28M/yr through single-member LLC from public funds; RFFW $1M through undisclosed channel
18 U.S.C. § 152Concealment in bankruptcyHolland: 5 bankruptcies, concealed assets while holding financial officer positions
18 U.S.C. § 371Conspiracy to defraudEnterprise structure designed to extract public funds through misrepresentation

What You Already Have

You raided Detroit City Council offices in August 2021. You seized 501(c)(4) records. Save Detroit Jobs was connected to the raid targets. The same entity backed Latisha Johnson, who sits on the PCA Board. The thread runs from your raid to the enterprise.

The Evidence

Contact

FBI Detroit Field Office: (313) 965-2323 477 Michigan Avenue, 26th Floor, Detroit, MI 48226 Tips: tips.fbi.gov


II. DEA — Detroit Division

Your Jurisdiction

Joseph Holland Jr. — birth name Williams, Joseph Antione — is a convicted drug dealer (MDOC #443789, SID 2321035P). Convicted of delivery of a controlled substance. Discharged WITHOUT IMPROVEMENT.

He currently holds:

These positions give him control over $4.9M per year in public education funds flowing through the enterprise.

The DEA Question

Is a convicted drug dealer who was discharged WITHOUT IMPROVEMENT and who now controls millions in public funds still engaged in the drug trade? Is the enterprise a laundering vehicle?

The Evidence

Contact

DEA Detroit Division: (313) 234-4000 431 Howard Street, Detroit, MI 48226


III. IRS — Criminal Investigation (CI)

Your Jurisdiction

StatuteViolationEvidence
IRC § 7206Tax fraudHolland’s address used for Banks’ tax filings; concealed assets in bankruptcy while holding nonprofit officer positions
IRC § 4958Excess benefit transaction72.67% of nonprofit school revenue ($4.28M/yr) extracted to single-member LLC controlled by operator
IRC § 501(c)(3)Tax-exempt status abusePurpose Foundation: all 4 officer positions held by 2 convicted felons; “No Related Parties” statement is false
IRC § 501(c)(4)Political nonprofit abuseRFFW LLC: $1M undisclosed for 351 days; Renae Moore named as treasurer filing fraudulent reports
26 U.S.C. § 7201Tax evasionHolland: 5 bankruptcies, assets concealed from courts while receiving income from enterprise entities

The 43 Nonprofits

Renae Moore is listed as officer on 43 IRS-registered nonprofits. She testified she has “no duty to report” questionable spending. 3 of 54 entities have known fraud patterns — and all 3 were caught by external complaints, not internal compliance.

How many of the other 40 Form 990s are accurate?

The Evidence

Contact

IRS Criminal Investigation: 1-800-829-0433 CI Tips: irs.gov/compliance/criminal-investigation Form 13909 (Tax-Exempt Organization Complaint): irs.gov/pub/irs-pdf/f13909.pdf


IV. DOJ — Civil Rights Division, Educational Opportunities Section

Your Jurisdiction

The DOJ Civil Rights Division investigates patterns of civil rights violations in education, including:

The Civil Rights Violation

362 children attend Purpose Charter Academy and MacDowell Preparatory Academy. They are overwhelmingly Black children from Detroit.

These children are being denied equal educational opportunity while their per-pupil funding is extracted by a criminal enterprise. This is a civil rights violation perpetuated by institutional failure.

The Evidence

Contact

DOJ Civil Rights Division — Educational Opportunities Section 950 Pennsylvania Avenue NW, Washington, DC 20530 (202) 514-4092 justice.gov/crt/educational-opportunities-section


V. ED-OIG — U.S. Department of Education, Office of Inspector General

Your Jurisdiction

AreaApplication
Title I fraudPCA receives federal education funds; funds diverted to private LLC
Charter school grant fraudMaterial misrepresentation of operator credentials in charter application
FERPA violationsBanks operates as “superintendent” without verifiable credentials
Federal education program integrity72.67% extraction rate from school receiving federal funds

The Evidence

Contact

ED-OIG Hotline: 1-800-647-8733 ed.gov/about/offices/list/oig Online complaint: ed.gov/about/offices/list/oig/hotline


VI. HHS-OIG — Health and Human Services, Office of Inspector General

Your Jurisdiction

If PCA or MacDowell receives any HHS-administered funding (school meals, Medicaid-linked services, mental health grants), the extraction of funds through the Purpose Group LLC may constitute fraud against HHS programs.

Contact

HHS-OIG Hotline: 1-800-447-8477 oig.hhs.gov/fraud/report-fraud


VII. FinCEN — Financial Crimes Enforcement Network

Your Jurisdiction

AreaApplication
Suspicious Activity Reports$4.28M/yr flowing to single-member LLC from public institution
Money launderingEntity proliferation across 54+ nonprofits, $1M RFFW concealment
StructuringMultiple entities used to evade reporting thresholds
Beneficial ownershipPurpose Group LLC: single member = Banks. No other disclosure.

The Question

Under the Corporate Transparency Act (2024), does Purpose Group LLC meet the reporting requirements? Has Banks filed a Beneficial Ownership Information (BOI) report?

Contact

FinCEN Tips: fincen.gov/contact FinCEN BSA E-Filing: bsaefiling.fincen.treas.gov


VIII. FEC — Federal Election Commission

Your Jurisdiction

CommitteeIssue
Dykema PAC (C00342113)Moore is Treasurer. $164K cash. Manages both parties.
Hill Harper (C00844985)Moore is Treasurer. FEC RFAI issued Nov 2023 for vague disbursements.
Simon Group Holdings (C00963058)Moore is Treasurer. Filed Oct 5, 2026 — during this investigation.
Friends of Snowmobiling (C00380196)Moore is Treasurer.

The Pattern

One person — Renae Moore — is Treasurer of 5 federal PACs and has been named in a $1M state campaign finance complaint for filing fraudulent reports. She testified she has “no duty to report.”

Contact

FEC Complaints: fec.gov/legal-resources/enforcement/complaints-process FEC: 1-800-424-9530


IX. ACLU of Michigan

Your Case

Kevin Mok has a PPO (26-114083-PH) filed against him by Brian Banks — a man with 9 criminal convictions — for the “crime” of:

You already won this case. In Carravallah, you terminated a PPO used to silence protected speech (Oakland County). This is the identical pattern.

Additionally, UPEPA (Act 52 of 2025, MCL 691.1851 et seq.) — Michigan’s anti-SLAPP statute, effective March 24, 2026 — applies. The PPO is a strategic lawsuit against public participation. Discovery should be stayed. Fees should be awarded.

Contact

ACLU of Michigan: (313) 578-6800 Intake hours: 1:00 PM – 4:00 PM, Monday and Wednesday Online intake: intake.aclumich.org 2966 Woodward Avenue, Detroit, MI 48201


X. SPLC — Southern Poverty Law Center

Your Mission

The SPLC investigates systemic exploitation of vulnerable communities, particularly in the South and communities of color.

The Application

362 Black children in Detroit attend schools run by a convicted felon enterprise:

This is systemic educational exploitation of Black children in Detroit by an enterprise protected by institutional capture.

Contact

SPLC: (334) 956-8200 splcenter.org/contact-us 400 Washington Avenue, Montgomery, AL 36104


Your Mission

LDF litigates civil rights cases, particularly involving education equity and the rights of Black communities.

The Application

The Banks enterprise extracts $4.9M per year from per-pupil funding allocated for Detroit’s predominantly Black students. The children receive 3% math proficiency in return. The enterprise is shielded by:

This is educational redlining through institutional capture. The money flows FROM Black communities TO a private LLC. The protection flows from the institutions BACK to the enterprise.

Contact

NAACP Legal Defense Fund: (212) 965-2200 naacpldf.org/contact-us 40 Rector Street, 5th Floor, New York, NY 10006


XII. Michigan AG — Criminal Justice Bureau

You Already Know

Your office has the full evidence package. Your AAG (Moreland) sits on the board. You have jurisdiction under:

You have 74 days left. Nessel leaves December 31, 2026. Everything transfers to the next AG uninvestigated.

What You Must Do

Recuse. Appoint a special prosecutor. The Moreland conflict makes any AG investigation structurally compromised.

Contact

AG Complaint: (517) 335-7622 michigan.gov/ag


XII-A. Attorney Grievance Commission — You Already Responded. It’s Signed.

What You Did

On October 1, 2026, AGC File No. 26-2141 was created in response to a Request for Investigation against Lamar Moreland and Todd Perkins.

Cynthia C. Bullington, Assistant Deputy Administrator, signed a letter stating:

“You must complete a separate form for each attorney… Your original correspondence is enclosed. No further action will be taken.”

Michael V. Goetz, Grievance Administrator, signed the cover letter enclosing blank Request for Investigation forms.

The original evidence was returned. The file was closed before it opened.

What You Received

A complaint describing:

What Your Own Rules Say

Your own process document — enclosed in the response to the complainant — states:

“The Grievance Administrator can initiate a request for investigation in his own name as well.”

Goetz doesn’t need the complainant’s forms. He needs 60 seconds on LARA to confirm Moreland is on the PCA board. He needs one search of the State Bar directory to confirm Banks’ J.D. claim is unverifiable. He needs one ICHAT search to confirm Holland’s MDOC #443789.

He signed blank forms instead.

Every Name on the Letterhead

The following 22 people work for an organization whose sole purpose is attorney discipline. Every one of them received the complaint. Every one of them is now in the public record:

Leadership: Kathleen Hickey (Chair), Kendrah B. Robinson (Vice-Chair), Alexander Pahany (Secretary)

Administration: Michael V. Goetz (Grievance Administrator — signed), Kimberly L. Uhuru (Deputy), Cynthia C. Bullington (Asst. Deputy — signed), Sarah C. Lindsey (General Counsel)

Commissioners: Kathryn R. Swedlow, James Moritz, Anjali Prasad, Holly Jeschke, Joseph P. McGill, Debra Kubitskey

Associate Counsel: Emily A. Downey, Michael K. Mazur, Pamela I. Linville, Cora L. Morgan, Graham G. Leach, Mary A. Bowen, Austin D. Blessing-Nelson, Caitlin O. Fleming, Mahira Musani, Courtney T. Altovilla

Full analysis: The Circular Shield — How the AGC Protects the Attorneys Who Protect the Enterprise

Contact

AGC: (313) 961-6585 755 W. Big Beaver Rd, Suite 2100, Troy, MI 48084 agcmi.org


XIII. Wayne County Prosecutor

Your Jurisdiction

State criminal charges under MCL 750.159i (RICO), MCL 750.218 (false pretenses), MCL 750.174a (exploitation), MCL 750.248 (filing false reports).

Your Problem

7 of the judges in your courts are connected to the enterprise. Any prosecution faces structural recusal challenges.

What You Must Do

Request a special judge from the SCAO. File in a court where none of the 7 connected judges sit.

Contact

Wayne County Prosecutor’s Office: (313) 224-5777 1441 St. Antoine, Detroit, MI 48226


XIV. Michigan Department of Education

You Acknowledged Receipt

MDE acknowledged the complaint on October 1, 2026 at 9:25 AM. The professional practice complaint is under review.

What Must Happen Now

Contact

MDE: (517) 373-3324 michigan.gov/mde


XV. DPSCD — Detroit Public Schools Community District

Your Responsibility

DPSCD authorized the charter that permits PCA and MacDowell to operate. You authorized the flow of per-pupil funding — $4.9M per year to PCA, $2.1M to MacDowell — to an enterprise run by a man with 9 criminal convictions.

What Must Happen Now

Contact

DPSCD: (313) 240-4377 detroitk12.org


XVI. Every Parent in Detroit

What You Need to Know

If your child attends Purpose Charter Academy or MacDowell Preparatory Academy:

What You Can Do

  1. Request your child’s records — you have a right under FERPA
  2. Attend the next PCA board meeting — ask about the management agreement
  3. File a complaint with MDE — michigan.gov/mde, Professional Practice section
  4. Contact your DPSCD board member — demand a charter review
  5. Contact the ACLU of Michigan — (313) 578-6800 — if you’ve experienced retaliation
  6. Read the evidence — github.com/defendDetroit/publicRecord

Your Children Deserve Better Than 3%

$4.9 million per year flows to this school. Your child gets 3% math proficiency. Where is the other 97%? It’s in a private LLC in Grosse Pointe Woods. The money leaves Detroit. The results stay.


XVII. The Media

Journalists Who Have Already Covered This

JournalistOutletWhat They Published
M.L. ElrickDetroit Free Press“Back to Fool” (Aug 2023) — 8 felonies, MacDowell hiring
Clutch Justiceclutchjustice.com“The Bench and the Board” (Sep 2026) — judges, board ties
Deadline Detroitdeadlinedetroit.comSave Detroit Jobs / dark money / FBI raids (2021)

What’s New Since August 2023

Everything. Holland identified as MDOC #443789. Moore’s 54 entities. RFFW $1M complaint. Moreland as felony murder prosecutor. Dykema → Johnson → PCA Board pipeline. Full RICO analysis. NP → O(1) graph reduction.

The story is verified. The sources are public. The graph is free.

Contact the Tiplines

OutletTip Channel
Detroit Free Pressfreep.com/news-tips
Detroit Newstips@detroitnews.com
Bridge Michigantips@bridgemi.com
Michigan Radio (NPR)tips@michiganradio.org
ProPublicapropublica.org/tips
The Intercepttheintercept.com/source

The Bottom Line — For Every Agency

362 children walk into those buildings every Monday morning. They sit in classrooms funded by $4.9 million in public money. 3% of them can do math at grade level. 72.67% of the money goes to a private company. The man running it has 9 convictions. His financial manager is a convicted drug dealer. His board includes a judge who took his money, an AAG who works for the RICO prosecution office, and a council member elected with dark money formed by the same firm that manages the prosecutor’s fund.

Every agency listed above has jurisdiction over some part of this. None have acted.

The evidence is public. It costs nothing to download. It takes 15 minutes to verify the ICHAT records. It takes one phone call to confirm Banks is not in the State Bar directory. It takes one LARA search to see Holland on the Purpose Foundation filing.

The graph has 9,643 nodes and 323,680 edges. It is timestamped with git hashes. It is independently corroborated. It is distributed to 1,242 cloners.

The children cannot wait. Every day the enterprise operates is a day another child gets 3% instead of an education. Every dollar extracted is a dollar that was supposed to teach a child to read.

This is not a policy disagreement. This is not a political dispute. This is a criminal enterprise extracting public education funds from Black children in Detroit, shielded by captured institutions, and documented in public records available to anyone with an internet connection.

Act. Or be documented as having chosen not to.

The membrane records everything. The graph never forgets. And the count — 362 children — is the only number that matters.

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