# Auditor's Office FOIA Production R1, Milligan Custodian (FOIA Response 6-18-25) A 51-file production from the Milligan custodian within the ATRS R1 FOIA response. Total 139 pages. The materials cover the period 10/23/2024 through 6/9/2025 and were assembled by Milligan or his staff on 6/10/2025 in response to Mark White's 6/6/2025 board canvass. ## Production timeline and chain of custody Mark White on 6/6/2025 at 4:48 PM emailed the ATRS Board Members Group requesting that any board member identify Israel-Bonds-responsive emails for the Jennifer Lenow second FOIA request: "If you received or sent any emails from/to someone outside of ATRS staff in the last year regarding Israel Bonds, that email may be subject to the FOIA request. If you have an email that may qualify, please let me know. If the only email you have related to Israel Bonds is the one that I sent in advance of the Board meeting, you don't need to do anything." Forty-nine of the 51 files in this Milligan production are PDFs in Apple Mail format with export timestamps in the page header. Every Apple Mail PDF carries an export timestamp between 10:57 AM and 11:32 AM CDT on 6/10/2025. The production was assembled in approximately 35 minutes one morning, 4 days after White's canvass. The remaining two files (ISRAEL BONDS - 01.pdf and ISRAEL BONDS - 02.pdf) are in a different Outlook export format with "Jason Brady" in the page header, suggesting they were collected through a different process or workflow. The substantive content of ISRAEL BONDS - 01.pdf duplicates Freedom of Information Request - 6 june 2025.pdf with about 1 minute of timestamp drift, indicating two separate exports of the same Mark White email. The methodological consequence is that the universe of files in this batch reflects what Milligan or his staff judged responsive to White's canvass on 6/10/2025. The contents are accurate to that snapshot but may not be comprehensive: anything missed, deleted, or judged non-responsive would not appear here. Notably absent from the production: any email between November 2024 and 1/3/2025, the period in which the in-person November 2024 meetings between Lawrence Berman and the Auditor's office presumably occurred per Brady's 10/23/2024 outreach pitch. ## Files in three groups **Substantive operational correspondence (8 files).** Each adds new substantive evidence to the investigation. - ISRAEL BONDS - 01.pdf and Freedom of Information Request - 6 june 2025.pdf. Two exports of Mark White's 6/6/2025 board canvass for FOIA-responsive emails. Process document for this very production. - ISRAEL BONDS - 02.pdf. Brady's 1/3/2025 4:40 AM Outlook acceptance of "Israel Bonds - Private & Exclusive Economic Briefing," sent to Wendy Spadoni. First documented evidence that Auditor's office staff personally registered for DCI events. - Pre-Election Update from the States - 4 nov 24.pdf. From OJ Oleka, CEO of the State Financial Officers Foundation, to Dennis Milligan on 11/4/2024. Contains the Stacy Garrity Pennsylvania case study as the model investment narrative. See [[sfof-state-financial-officer-network]]. - Israel Bonds State of Israel Economic Summary - 18 feb 25.pdf. Stuart Garawitz's personally-addressed 2/18/2025 email to Dennis Milligan, with cc to Ana Torres. Closes "I look forward to speaking with you soon," indicating ongoing personal sales relationship. - RE Israel bonds - 23 oct 25.pdf. Amy Fecher's 3:58 PM reply to Brady's 10/23/2024 outreach, captured from Milligan's mailbox via cc. Same content as previously documented at Emails1.pdf p.2. - Re [EXTERNAL] Meeting Information - 11 april 25.pdf. Mark White's 4/11/2025 reply to Milligan accepting the 4/15/2025 Capitol meeting. Captured here from Milligan's mailbox. - Preview of June 2 Meeting - 22 may 25.pdf. White's 5/22/2025 Board preview email reaching Milligan as a Board Members Group recipient. Confirms Milligan personally received the email naming him as "Our Board colleague." - Communication with John Rollans - 9 june 2025.pdf. White's 6/9/2025 forward to the Board of his Westrock Coffee dialogue with retiree John Rollans. New substantive material about how investment decisions are framed for held positions versus new acquisitions. See [[westrock-procedural-asymmetry]]. **DCI promotional cluster (~42 files).** All addressed personally to Dennis Milligan. Standard DCI marketing templates that match the patterns documented in [[dci-promotional-pipeline]]. Date range 1/13/2025 (Zoom Link Private Israel Economic Briefing) through 6/8/2025 (the "$5 BILLION for Israel" milestone email). Cadence and content match the parallel pipeline that reached Mark White and Rod Graves at ATRS and Stuart Garawitz personally signed. Sample notable detail from "Lock in 5.72% on 10-Year Jubilee Bonds Today!" (2/20/2025): the standard FINRA disclosure footer states "Israel bonds are not rated." Sample notable detail from the 6/8/2025 milestone email: it claims that on June 4 DCI surpassed $5 billion in global investments since October 7. June 4 was two days after the ATRS Board action on June 2. The $50M ATRS authorization is approximately 1 percent of the $5 billion DCI milestone celebrated four days later. **Brady contact-acceptance file (1 file).** ISRAEL BONDS - 02.pdf is technically Brady's calendar acceptance routed to Wendy Spadoni, captured here in Milligan-folder custody. The Outlook export format with the Brady header and the placement in the Milligan folder suggest the production process may have aggregated some Brady-side responsive items into the Milligan response. ## What this batch establishes First, the existence of a national peer-to-peer political infrastructure promoting Israel Bonds adoption among state financial officers. The State Financial Officers Foundation (SFOF) newsletter to Milligan on 11/4/2024 made the Pennsylvania Stacy Garrity $20M Israel Bonds investment the featured case study, packaging the political-solidarity rationale ("to show our support at a time when the people of Israel are facing horrific terrorism") together with the financial gloss ("pay above-market returns and they've never defaulted"). This is broader than DCI's institutional sales; it is organized political activity. See [[sfof]] and [[sfof-state-financial-officer-network]]. Second, evidence that DCI's institutional sales operation worked Milligan personally. Stuart Garawitz's 2/18/2025 email is "Dear Dennis... I look forward to speaking with you soon." The cc to Ana Torres documents a DCI account-management structure around the Milligan relationship. Third, evidence that Auditor's office staff personally attended DCI events. Brady's 1/3/2025 calendar acceptance of the 1/15/2025 Rothenberg briefing is the first such confirmation in the documentary record. Fourth, the Westrock procedural asymmetry. White's 5/20/2025 reply to Rollans's Westrock dissent ("At ATRS our investment decisions are based on recommendations from our outside professional investment consultants") sits in tension with his 5/8/2025 directive on Israel Bonds ("they will not be making a formal recommendation"). Same executive director, same investment-decision frame, two procedural standards depending on whether buying or selling. See [[westrock-procedural-asymmetry]]. Fifth, the methodological clean record. Every file in this batch was produced via search of Milligan's mailbox in response to White's 6/6 canvass. The production was assembled in 35 minutes on 6/10/2025. The narrow time window suggests a focused search rather than a comprehensive review. Anything Milligan or his staff did not find, did not search for, or judged non-responsive is not here. ## What this batch does not contain No correspondence between November 2024 and 1/3/2025. This period covers the in-person November Berman meeting Brady's outreach was setting up, plus the December 2024 Mryyan FOIA response chain at ATRS. Milligan's office either had no Israel-Bonds correspondence in that period or did not produce it. No correspondence with the State Treasurer, State Bank Commissioner, or any other ATRS Board member outside the broadcast Board Members Group emails. The Investment Committee includes the State Treasurer and State Bank Commissioner ex officio (per BP1 Section XII), and Milligan as Operations Committee statutory member would have had occasion to coordinate with them on matters spanning both committees. None of that coordination appears in this production. No internal Auditor's office correspondence with Brady, Spadoni, or Wendy Spadoni about the Israel Bonds matter, despite the documented active involvement of Brady (Pennsylvania-style) in the 10/23/2024 outreach and the 4/11/2025 contact-point listing. Brady's Israel Bonds correspondence as captured in his own custodian production is also limited to the same 10/23/2024 chain. The intra-office working communications around the proposal are not represented in either the Brady or Milligan custodian productions to date. No Milligan correspondence with Lawrence Berman, Brad Young, Stuart Garawitz beyond the one Garawitz inbound email, or any other DCI representative. The institutional sales relationship implied by Garawitz's "look forward to speaking with you soon" closing produced no documented reply correspondence. No Milligan correspondence with the Arkansas General Assembly, the Governor's office, or other state officials about the Israel Bonds initiative. No Milligan correspondence about the BP4 amendment that the Board adopted on 6/2/2025 alongside Resolution 2025-22. ## Evidence > "We have received an FOI request from Jennifer Lenow as follows: 'I would like to request any/all emails of ARTRS staff and/or board members that include reference to Israel Bonds in the last year.' We are running a search of our systems to identify any emails sent or received by me or staff. If you received or sent any emails from/to someone outside of ATRS staff in the last year regarding Israel Bonds, that email may be subject to the FOIA request." > Mark White to Board Members Group, Freedom of Information Request - 6 june 2025.pdf p.1, 6/6/2025 > "Garrity invested $20 million in Israeli bonds on Oct. 12, 2023, saying it was important 'to show our support at a time when the people of Israel are facing horrific terrorism.' Garrity said the bonds are a good investment because they 'pay above-market returns and they've never defaulted.'" > OJ Oleka to Dennis Milligan, Pre-Election Update from the States - 4 nov 24.pdf p.4, 11/4/2024 > "Dear Dennis... Thank you again for all your support and I look forward to speaking with you soon." > Stuart Garawitz to Dennis Milligan, Israel Bonds State of Israel Economic Summary - 18 feb 25.pdf p.1, 2/18/2025 > "Subject: Accepted: Isreal Bonds - Private & Exclusive Economic Briefing" > Jason Brady to Wendy Spadoni, ISRAEL BONDS - 02.pdf p.1, 1/3/2025 > "At ATRS our investment decisions are based on recommendations from our outside professional investment consultants. They are monitoring and stay in regular communication with Westrock, and if they determine it is in the System's interest to sell our stake, they will make that recommendation to the Board." > Mark White to John Rollans, Communication with John Rollans - 9 june 2025.pdf p.2, 5/20/2025 > "I'd add that there are 5 analysts on Wall Street who are tracking and making recommendations on Westrock, and all 5 of them have the stock rated as 'buy', meaning they are recommending that their clients purchase Westrock stock." > Mark White to John Rollans, Communication with John Rollans - 9 june 2025.pdf p.2, 5/20/2025 > "Israel bonds are not rated." > DCI marketing FINRA disclosure footer, Lock in 5.72_ on 10-Year Jubilee Bonds Today! - 20 feb 25.pdf p.3 > "on June 4 we didn't just reach $5 billion in global investments since October 7 — we surpassed it. A powerful milestone, but the work continues." > DCI marketing email to Dennis Milligan, $5 BILLION for Israel– We're Not Done Yet - 8 june 2025.pdf p.1, 6/8/2025 ## Cross-References [[atrs-foia-r1-staff-emails]] [[auditor-foia-r1-brady]] companion source pages for the same FOIA response [[dennis-milligan]] [[jason-brady]] [[mark-white]] [[stuart-garawitz]] [[john-rollans]] entities updated with this batch's evidence [[oj-oleka]] [[sfof]] [[stacy-garrity]] [[ana-torres]] new entities introduced by this batch [[sfof-state-financial-officer-network]] [[westrock-procedural-asymmetry]] new concept pages developed from this batch [[dci-promotional-pipeline]] [[pecuniary-frame-act-498]] [[independent-credit-analysis-gap]] [[auditor-as-dci-channel]] companion concept pages updated with this batch's evidence