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:
- Private operator profits from children in public custody
- Judges connected to the operator route children (or funds) to the enterprise
- Public money flows to private pockets through institutional channels
- No one checks because the people who should check are the people who benefit
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) | |
|---|---|---|
| Operator | PA Child Care / Western PA Child Care | Purpose Group LLC / Banks |
| Judicial capture | 2 judges took $2.6M in kickbacks | 7 judges connected to enterprise — campaign payments, board seats, family ties |
| Financial gatekeeper | Robert Mericle (facility builder) | Joseph Holland Jr. (MDOC #443789, convicted drug dealer) |
| Children affected | ~4,000 juveniles sentenced | 362 students enrolled (3% math proficiency) |
| Money extracted | $2.6M in kickbacks | $60M+ over 14 years ($4.28M/yr, 72.67% extraction rate) |
| Institutional shield | County court system | AG employee on board, law firm managing both sides, 7 captured courts |
| How it was exposed | Intrepid Reporting / juvenile law center | One 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:
- What you investigate — your statutory jurisdiction
- What was violated — the specific laws
- Where the evidence is — with links
- What you should do — the specific action
The full evidence repository is public and free:
git clone https://github.com/defendDetroit/publicRecord.gitMirror: 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
| Statute | Violation | Evidence |
|---|---|---|
| 18 U.S.C. § 1962 | Federal RICO | 15 predicate acts, 21 years, $60M+ extraction |
| 18 U.S.C. § 1341 | Mail fraud | PPO served via USPS, forged return receipts (Leon Smith, USPS employee) |
| 18 U.S.C. § 1343 | Wire fraud | Electronic solicitation of donations using false credentials (J.D. claim) |
| 18 U.S.C. § 1951 | Hobbs Act (extortion) | PPO filed to silence complainant — public official using court to suppress investigation |
| 18 U.S.C. § 1956 | Money laundering | $4.28M/yr through single-member LLC from public funds; RFFW $1M through undisclosed channel |
| 18 U.S.C. § 152 | Concealment in bankruptcy | Holland: 5 bankruptcies, concealed assets while holding financial officer positions |
| 18 U.S.C. § 371 | Conspiracy to defraud | Enterprise 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
- The Enterprise — RICO Analysis
- The Nonprofit Web — Dark money to board pipeline
- Full repository:
git clone https://github.com/defendDetroit/publicRecord.git
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:
- Secretary AND Treasurer of Purpose Foundation (LARA Entity 803294855)
- Treasurer of Bank on Banks PAC (MI SOS #517977)
- 1st Successor Trustee of the Banks Living Trust
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
- Holland MDOC #443789: apps.michigan.gov/ichat — SID 2321035P
- The Gatekeeper — Holland analysis
- Holland’s 5 bankruptcies with concealed assets
Contact
DEA Detroit Division: (313) 234-4000 431 Howard Street, Detroit, MI 48226
III. IRS — Criminal Investigation (CI)
Your Jurisdiction
| Statute | Violation | Evidence |
|---|---|---|
| IRC § 7206 | Tax fraud | Holland’s address used for Banks’ tax filings; concealed assets in bankruptcy while holding nonprofit officer positions |
| IRC § 4958 | Excess benefit transaction | 72.67% of nonprofit school revenue ($4.28M/yr) extracted to single-member LLC controlled by operator |
| IRC § 501(c)(3) | Tax-exempt status abuse | Purpose Foundation: all 4 officer positions held by 2 convicted felons; “No Related Parties” statement is false |
| IRC § 501(c)(4) | Political nonprofit abuse | RFFW LLC: $1M undisclosed for 351 days; Renae Moore named as treasurer filing fraudulent reports |
| 26 U.S.C. § 7201 | Tax evasion | Holland: 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
- Moore’s Complete Ledger — 54 entities, every EIN
- The Enterprise — financial extraction analysis
- All EINs documented with siviq.co cross-reference
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:
- Denial of equal educational opportunity
- Discrimination in public education access
- Public corruption that deprives communities of educational resources
The Civil Rights Violation
362 children attend Purpose Charter Academy and MacDowell Preparatory Academy. They are overwhelmingly Black children from Detroit.
- 3% math proficiency (PCA, 2023 M-STEP)
- $4.9M per year flows to a private LLC instead of educational services
- The school is operated by a man with 9 criminal convictions who claims a J.D. he does not appear to hold
- The financial gatekeeper is a convicted drug dealer discharged WITHOUT IMPROVEMENT
- No regulatory agency has acted despite documented evidence sent to 22 channels
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
- The Enterprise — RICO analysis
- MDE M-STEP data: 3% math proficiency
- 243-page federal packet (delivered Sep 22, 2026)
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
| Area | Application |
|---|---|
| Title I fraud | PCA receives federal education funds; funds diverted to private LLC |
| Charter school grant fraud | Material misrepresentation of operator credentials in charter application |
| FERPA violations | Banks operates as “superintendent” without verifiable credentials |
| Federal education program integrity | 72.67% extraction rate from school receiving federal funds |
The Evidence
- Where the Signal Landed — full signal ledger
- DPSCD charter authorization documents
- MDE FOIA response (partial grant, partial denial)
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
| Area | Application |
|---|---|
| Suspicious Activity Reports | $4.28M/yr flowing to single-member LLC from public institution |
| Money laundering | Entity proliferation across 54+ nonprofits, $1M RFFW concealment |
| Structuring | Multiple entities used to evade reporting thresholds |
| Beneficial ownership | Purpose 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
| Committee | Issue |
|---|---|
| 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:
- Filing FOIA requests
- Filing regulatory complaints with government agencies
- Publishing public records
- Petitioning the government for redress
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:
- 3% math proficiency — effectively no education
- $60M+ extracted over 14 years through a private LLC
- No oversight — the AG’s own employee governs the school
- Retaliation against the parent who investigated — PPO filed, entered into LEIN
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
XI. NAACP Legal Defense Fund
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:
- 7 connected judges (all serving courts in Wayne County’s predominantly Black communities)
- An AAG who governs the school
- A compliance desk that manages both the prosecutor and the defense
- Institutional silence from every oversight body
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:
- MCL 750.159i (state RICO)
- MCL 400.285 (nonprofit fraud)
- MCL 445.903 (consumer protection)
- MCL 14.251 (charitable trust)
- MCL 750.218 (false pretenses)
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:
- Lamar Moreland — AAG who sits on the board of a school run by a man with 9 criminal convictions, while working for the AG bureau that prosecutes state RICO
- Todd Perkins — Banks’ personal attorney who filed a PPO to silence a parent’s FOIA requests and regulatory complaints. Has 4 personal bankruptcies. $100K+ IRS tax liens. His brothers Judge Sean Perkins (36th District) and Judge David Perkins (Probate, Chief Judge Pro Tem) sit on Wayne County courts.
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
- Revoke Banks’ teaching certificate — TCR 22-12 violations, credential fraud
- Investigate FERPA violations — is Banks accessing student records without proper credentials?
- Flag PCA and MacDowell for emergency academic review — 3% math proficiency
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
- Emergency charter review — audit the management agreement
- Verify “No Related Parties” representation — it is demonstrably false
- Verify operator credentials — Banks’ J.D. claim is unconfirmed
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:
- The “superintendent” has 9 criminal convictions
- The person managing ALL the school’s money is a convicted drug dealer discharged WITHOUT IMPROVEMENT
- 72.67% of the school’s revenue goes to a private company controlled by one person
- 3% of students are proficient in math
- The school’s board includes a sitting judge (who received campaign payments from the operator), an Assistant Attorney General (who works for the office that should investigate), and a city council member (who was backed by dark money formed by the same law firm)
- A parent who investigated this was served with a restraining order and entered into a law enforcement database
What You Can Do
- Request your child’s records — you have a right under FERPA
- Attend the next PCA board meeting — ask about the management agreement
- File a complaint with MDE — michigan.gov/mde, Professional Practice section
- Contact your DPSCD board member — demand a charter review
- Contact the ACLU of Michigan — (313) 578-6800 — if you’ve experienced retaliation
- 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
| Journalist | Outlet | What They Published |
|---|---|---|
| M.L. Elrick | Detroit Free Press | “Back to Fool” (Aug 2023) — 8 felonies, MacDowell hiring |
| Clutch Justice | clutchjustice.com | “The Bench and the Board” (Sep 2026) — judges, board ties |
| Deadline Detroit | deadlinedetroit.com | Save 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
| Outlet | Tip Channel |
|---|---|
| Detroit Free Press | freep.com/news-tips |
| Detroit News | tips@detroitnews.com |
| Bridge Michigan | tips@bridgemi.com |
| Michigan Radio (NPR) | tips@michiganradio.org |
| ProPublica | propublica.org/tips |
| The Intercept | theintercept.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.