# Auditor's Office FOIA Production R3 (3-3-26) This is the third Auditor's-office production. It is the response to the Joshua Dunlap 6/22/2025 12:56 PM FOIA submission to [email protected]; the wiki captures its own provenance. The production took 8.5 months from request to response (6/22/2025 to 3/3/2026), the longest agency turnaround documented in the wiki. Total volume 248 files / 170 MB / 124 unique emails across three custodians: Jason Brady (200 files / 100 unique), Dennis Milligan (24 files / 12 unique), Wendy Spadoni (24 files / 12 unique). Each email is preserved as a paired `.eml` + `.msg` set. Roughly 75 percent of the production by file count is Development Corporation for Israel promotional correspondence matching established [[dci-promotional-pipeline]] templates: post-vote Operation Rising Lion content, monthly rate-sheet announcements, "Get 5 / Earn 5 / Unlock 5" product messaging, the celebrity one-on-one series with Leo Terrell, Nate Buzz, Jonah Platt, Emily Austin, and Rawan Osman, and Jewish-calendar holiday templates. These are cross-confirmation of DCI's continued post-vote sales cadence to Brady through February 2026 and are not individually cataloged. The substantive content is approximately 25-30 emails covering October 23, 2024 through February 25, 2026, with substantive activity concentrated May 22, 2025 through January 13, 2026. Two findings frame the production. First, the ATRS implementation stage of the Reams Israel Bonds mandate is documented in Brady's mailbox via the 12/29/2025 Rod Graves Board Update on Liquidity. The execution was a single $50 million capital call in December 2025, not the laddered five-year deployment Mark White's 5/22/2025 Board preview had proposed. Second, the production surfaces TJ Fowler as Auditor's-office General Counsel, the third state-level pension-and-treasury General Counsel position the wiki has documented after Olan Reeves at the Treasurer's office and Laura Gilson at APERS. Fowler was on leave during the critical week (June 19-22, 2025) when the Auditor's office received both Lenow's second ATRS canvass forward and Dunlap's primary FOIA submission; the operational FOIA handling fell to Stacy Peterson and Kurt Underwood in his absence. ## Sub-batch 1: Brady custodian (200 files / 100 unique emails) The Brady production is the largest of the three custodians and spans Inbox (92 unique), Sent-Items (5 unique), Deleted-Items (2 unique), and Recoverable-Items/Deletions (1 unique). The Inbox is dominated by DCI promotional template emails; the substantive content concentrates in 20 Inbox emails plus the 5 Sent-Items. Brady's iPhone is the primary routing device for Israel Bonds correspondence across the production, with the "Sent from my iPhone" footer on five documented forwards (the 6/19/2025 White-canvass forward to TJ Fowler and Peterson, the 7/11/2025 Ark Times article forward to Milligan's personal AOL, the 7/12/2025 6:52 AM Ark Times forward to Peterson and Corrigan, the 7/12/2025 6:54 AM Ark Times forward to Berman, and the 6/6/2025 APERS Q2 packet forward to Spadoni). ### The 12/29/2025 ATRS Reams capital call execution The single most substantively significant document in the Brady custodian production is Rod Graves' Monday December 29, 2025 11:23 AM `ATRS Board Update-Liquidity` email to the ATRS Board Distribution List with Mark White cc'd. Captured in Brady's Inbox via his ex officio designee membership on the ATRS Board for Auditor Milligan. > *"December payments since the last Board update consisted of several ATRS obligations including capital calls for various investments of approximately $185 million. This includes the Scout (Reams) mandate of $50 million for Israel Bonds and $50 million of the $100 million commitment to the Realty Income US Core Plus Fund. In addition ATRS paid out around $117 million in benefits, close to $160,000 in quarterly investment manager fees, and approximately $1.5 million in refunds and other expenses."* The funding source is documented in the same email: > *"Withdrawals totaling $100 million from the SSgA Global Index Fund along with withdrawals totaling $140 million from the BlackRock Global Index Fund were required to cover December liquidity needs."* The substantive findings: ATRS deployed the **full $50 million maximum** authorized by Resolution 2025-22, not a phased deployment. Mark White's 5/22/2025 Board preview captured at [[atrs-foia-r1-staff-emails]] proposed *"an investment of up to $50 million spread over 5 years, with up to $10 million per year"* — the actual execution overrode the ladder framing in favor of a single Dec 2025 capital call. The SSgA Global Index Fund withdrawal indirectly liquidated ATRS's pre-existing approximately $1 million passive Israel sovereign exposure documented at [[ssga-cmx6-2024-11-30]]; the net effect is replacement of indirect passive exposure with direct active exposure at roughly a 50× ratio. See the dedicated concept page at [[atrs-reams-capital-call-execution]] for the structural analysis. ### The post-vote Brady-Berman correspondence Brady's Sent-Items captures the first documented post-vote Brady-Berman direct correspondence at `The Arkansas times article` (Sat 7/12/2025 6:54 AM CDT, Brady to Lawrence Berman at [email protected]). The body is the bare Arkansas Times URL plus "Sent from my iPhone": > *https://arktimes.com/arkansas-blog/2025/07/11/arkansas-taxpayers-are-loaning-israel-millions-of-dollars-as-its-war-in-gaza-grinds-on* > > *Sent from my iPhone* Brady forwarded the published Lenow article to the DCI National Managing Director within 15 hours of publication, with no substantive commentary. The same morning Brady also forwarded the article to Stacy Peterson and Melissa Corrigan (6:52 AM, 2 minutes earlier than the Berman send) and the night before (7/11 7:28 PM) to Milligan's personal AOL account [email protected]. The Berman forward, 7/12 6:54 AM, is the only documented Brady-Berman direct outbound in the production. There is no documented Berman-to-Brady reply in this batch. ### Brady routing to Milligan's personal AOL The thread embedded in `Re Ark Times Article + Congratulations` (Brady Inbox, reply from Stacy Peterson 7/13/2025 12:40 PM) preserves the message header chain showing Brady forwarded Mark White's 7/11/2025 3:55 PM ATRS Board notification of the Arkansas Times article to DENNIS MILLIGAN at [email protected] at 7/11/2025 7:28 PM CDT from his iPhone. Same Milligan personal AOL address documented at [[stacy-peterson]] for the 10/4/2024 Israel solidarity speech approval. This is the second documented instance of Brady-Milligan personal-account routing on Israel Bonds business. Establishes that Auditor's-office Israel Bonds correspondence flows through both the official auditor.ar.gov channel and Milligan's personal AOL; the latter is not subject to FOIA at the Auditor's-office level. Brady's iPhone is the conduit. ### The Lenow Arkansas Times article and inquiry chain Three substantively related emails capture the full Lenow Arkansas Times reporting chain. The 7/2/2025 8:45 AM Lenow inquiry to APERS General Counsel Laura Gilson is preserved as `FW Request for comment` (Brady Inbox, forwarded by Amy Fecher to Brady at 9:50 AM with Spadoni cc'd, with Gilson's 8:49 AM forward to Fecher in the body). Lenow's full text: > *"Good Morning! I am reporting on a story for the Arkansas Times about the state's recent investment decisions related to Israel bonds and would like to request a comment. I'm not totally sure who I should direct my request to. Could you forward my request to the appropriate person if that person is not you? My deadline is 5 p.m. today, Wednesday, July 2."* > > *"According to the APERS investment policy, 'As fiduciaries, trustees have a legal responsibility to act solely in the best interests of the members, retirees, and beneficiaries of the system. This responsibility requires trustees to act with care, skill, and prudence in managing the assets of the system.'"* > > *"The decision to purchase Israel bonds was made at the recommendation of Jason Brady, on behalf of Auditor Milligan. In Brady's rationale for the recommendation he mentioned his former boss, Mike Huckabee, who now serves as the U.S. Ambassador to Israel, as well as the geopolitical importance of Israel for U.S. foreign policy. Auditor Milligan has made public comments about Israel suggesting that his motivation for supporting Israel bonds goes well beyond pecuniary factors."* > > *"Do these statements mean the board has considered non-pecuniary factors when making investments of APERS funds into Israel bonds?"* > > *"Furthermore, non-U.S. governmental bonds are not listed as a permissible investment in the Arkansas state statute pertaining to public employee retirement plans. Would an investment in Israel bonds violate state statute?"* Mark White's 4:44 PM same-day substantive response, ATRS-direction, is captured cross-custodian in Milligan's Boards subfolder at `Ark Times on Israel Bonds`. White's defense: > *"The members of the ATRS Board of Trustees look out for the best interests of our 140,000+ members. Every investment decision is driven by what makes the most financial sense for our members. Investing in bonds and other fixed income products is a key part of the Board's investment strategy, and having a diversified portfolio is in our members' best interests. This is why ATRS invests in thousands of different bonds issued by corporations and governments all over the world, including Israel."* > > *"Last month, the Board selected an investment manager to increase our stake in investment strategies that include bonds issued by the Government of Israel. The Board made this decision with the advice of its general investment consultant and their recommendation of an investment manager. This process — the selection of an investment manager based upon the advice and recommendation of our general investment consultant — is the same way the Board always chooses fixed income investment managers. This is what the Board's policies require."* > > *"Even though this request started with a Trustee, we still followed our usual process. Nothing prohibits a Trustee from suggesting an investment. What state law requires for ATRS (but not for other systems like APERS) is for our Board to seek the 'advice' of its consultant before making an investment decision. That's exactly what the Board did in this case."* > > *"The Board's decision was based on the materials that staff presented to them. This included the consultant's advice on an investment manager, as well as proposed fees and sample rates and terms. These are all pecuniary factors under Arkansas law."* > > *"You mention the caveat in the consultant's memo about not recommending a purchase, but this is no different from any of their other recommendations. It is not unique to this investment decision. Our general investment consultant's role is to review and make recommendations about investment managers. They never make recommendations about the purchase of individual stocks or bonds. That is not their job, and they would be exceeding the scope of their securities licensure if they were to do so."* > > *"You asked about the permissible investments listed in Arkansas Code § 24-2-201. That list and that statute do not apply to state retirement systems like ATRS. They apply only to retirement plans operated by local governments."* The 7/11/2025 3:55 PM Mark White ATRS Board notification of the article publication (`Ark Times Article + Congratulations`, Brady Inbox + Milligan Boards) attaches the article PDF "250711 Arkansas taxpayers loan Israel millions as the war in Gaza grinds on - Arkansas Times.pdf" and frames the article for trustees: *"It's not focused on just us, it's a broader look that also includes APERS and the State Treasurer's Office... Everything in the story relating to ATRS has already been out in public for several weeks now, so I'm cautiously optimistic that this story will not create any new drama. I'll keep an eye on social media this weekend to see if it gets any traction with our members."* White also announces the Top 15 Arkansas Teacher of the Year selection of Susan Ford (ATRS Trustee). ### The Lenow Arkansas Times article content The published article, captured as a PDF attachment, is the wiki's first major non-Wickline post-vote reporter story. Lenow's reporting substantively engages the FOIA-produced record including the Pulley 10/8/2024 HOLD recommendation and Brady's APERS IFSC "ancillary reason" framing. Lenow's opening framing of the financial-and-political stakes: > *"It's no secret the United States is Israel's biggest supporter, even as the country faces credible accusations of war crimes from nearly every international governance body and human rights organization in the world... Many Arkansans may not know their state government is also sending money to Israel, albeit as loans rather than aid. As of July, Arkansas holds $55 million in Israeli bonds, including $20 million purchased since May 1. That means Arkansas taxpayers have effectively loaned Israel $55 million to use how it sees fit."* > > *"Two boards overseeing the pension funds of Arkansas state employees also recently voted to buy up to $100 million more in Israeli bonds within the next few years... If the retirement systems act on those recommendations, Arkansas public entities could lend Israel up to $155 million that could be used to fund its ongoing wars."* Lenow's first public disclosure of the Pulley 10/8/2024 internal credit overview: > *"These recent decisions were made despite a recommendation made last fall by a senior investment manager within the state treasurer's office to hold off on buying more Israeli bonds. The internal report cited downgrades of Israel's long-term creditworthiness across all three major rating agencies."* > > *"On October 7, 2024, then-Treasurer Larry Walther asked the state's investment professionals to weigh in on whether Israeli bonds continued to be a good investment for Arkansas. 'The Treasurer requested a briefing or summary on Israeli bonds sometime this week,' Walther's chief deputy treasurer wrote in an email to two of the state's senior investment managers. 'He wanted to hear from you on your opinion about purchasing more Israeli bonds in the future.'"* > > *"One of the senior investment managers, Steve Pulley, drafted an internal report dated Oct. 8 for the treasury's investment meeting that month. Pulley recommended a 'hold on adding more bonds.' Pulley's report recommended that the state 'hold our positions and allow for the $17M to roll off [mature] in the first half of 2025 and the $20M maturing in the calendar year 2026.' Citing the recent downgrades in Israel's credit rating, he commented that 'the outlook remains negative, reflecting the ongoing uncertainties and potential for further escalations in the region.'"* This is the first public-reporting surfacing of the [[treasury-internal-credit-analysis]] document text. The Pulley HOLD recommendation that the wiki documents via the 9-23-25 Treasury R2 production was disclosed to the Arkansas Times via Lenow's Treasury FOIA, then quoted in the article published 7/11/2025. Lenow's first published quotation of Brady's APERS IFSC "ancillary reason" framing: > *"Jason Brady, the state's deputy auditor, noted this as an 'ancillary reason' to purchase Israeli bonds when presenting a resolution at the APERS investment committee in May."* > > *"'The U.S. ambassador to Israel is a former governor of this state and coincidentally my and Amy's former boss, Mike Huckabee,' Brady said, referencing APERS Executive Director Amy Fecher."* > > *"Brady also gave the committee another non-pecuniary reason for the purchase: 'Israel is considered the United States' most trusted and dependable ally in a region of the world that is volatile at best.'"* This is the first verbatim public-reporting quotation of Brady's IFSC presentation. Wickline's 5/15/2025 NWA Democrat-Gazette story summarized similar content; the Arkansas Times article presents direct quotation framed as "non-pecuniary reason." Lenow's reporting on Milligan's non-response to her inquiry: > *"The office of the state auditor did not respond to a request for comment about whether Milligan considered non-financial factors when advocating for state entities to invest in Israeli bonds."* The Auditor's-office documented silence on the central pecuniary-vs-political question is substantively distinct from the ATRS, APERS, and Treasury responses (all of which provided defensive statements). The silence is captured in the production: no Auditor's-office Sent-Items reply to Lenow exists in the Brady, Milligan, or Spadoni production. Lenow's reporting on Sanders's public framing: > *"Gov. Sarah Sanders celebrated one of the recent purchase decisions on social media with an explicitly political framing. 'Arkansas puts its money where its mouth is and is investing millions in Israeli bonds!' she proclaimed."* This is the first wiki documentation of Sanders's Israel Bonds social media post. The Spadoni R1 production documented the 11/5/2024 Sanders meeting decline by Erica Freeman; the Sanders Arkansas Bonds social media post is a separate public-facing statement. Lenow's reporting on Milligan's April Facebook post: > *"Milligan posted a photo of his meeting with the two men on Facebook in April. 'I'm always happy to have my friends Larry Berman and Brad Young from Israel Bonds Development Corp. in Little Rock,' he wrote. 'I'm proud to be a supporter of the State of Israel and happy to help these fine gentlemen in any way that I can.'"* This is the first wiki documentation of Milligan's April 2025 Facebook post commemorating the Berman/Young Capitol tour meeting. The post is public-facing acknowledgment in a personal-voice register (the "my friends" framing matches the Brad Young handwritten card "friends like you" framing documented at [[auditor-foia-r2-residual]]). Lenow's reporting on Knight's verbatim dissent at the 6/2 ATRS Board meeting: > *"That resolution, which authorizes ATRS staff to invest up to $50 million in Israeli bonds, passed with one vote against it, cast by board Chairman Danny Knight. Knight said that the resolution was 'going outside of the scope of the way we usually do things.' The board typically relies on financial professionals to recommend specific investments in stocks or bonds, not board members or their proxies."* Cross-confirms the Wickline 6/3/2025 Democrat-Gazette quote of Knight ("we are going outside the scope of the way we usually do things") captured in APERS R2 Sub-batches 0-6. Lenow's analytical takeaway: > *"But the Israeli bonds are different. ATRS' stake in other bonds issued by foreign governments is indirectly held through investment vehicles such as index funds. Up until this point, neither ATRS or APERS has held direct investments in Israeli bonds or indeed any foreign sovereign debt."* The Arkansas Times article confirms the wiki's documented [[apers-israel-bonds-authorization]] "zero" baseline finding: the May/June 2025 authorizations are the FIRST direct foreign sovereign debt holdings for either Arkansas pension system in their respective histories. ### Joshua Dunlap's 6/22/2025 FOIA submission `Freedom of Information Act Request: Records Pertaining to Israel Bonds` in Brady Inbox. Sunday 6/22/2025 12:56 PM, Joshua Dunlap ([email protected], 920 W 41st Street, North Little Rock, AR 72118) to [email protected], cc [email protected] + Jason Brady + Wendy Spadoni. Five categories of records requested across timeframe October 1, 2024 onward: > *"Originating Communications: The initial and all subsequent communications received by the Auditor's office from any representative of the Development Corporation for Israel / Israel Bonds (including, but not limited to, Larry Berman and Brad Young) that initiated the request for Auditor Milligan to arrange meetings with state pension systems in or around October 2024."* > > *"External Correspondence: All correspondence (including emails, letters, text messages, and records of communication on any platform) between any staff or officials of the Auditor's Office (including but not limited to Auditor Dennis Milligan, Jason Brady, and Wendy Spadoni) and the following external entities regarding Israel Bonds or anti-ESG (Environmental, Social, and Governance) investment principles: The Development Corporation for Israel / Israel Bonds. The State Financial Officers Foundation (SFOF). Aon Hewitt Investment Consulting. Scout Investments, Inc., and/or its Reams Asset Management division."* > > *"Internal Strategy: All internal correspondence, memoranda, and meeting notes within the Auditor's Office discussing the strategy, planning, or objectives for promoting investment in Israel Bonds to the Arkansas Teacher Retirement System (ATRS) and the Arkansas Public Employees Retirement System (APERS)."* > > *"Inter-Governmental Correspondence: All correspondence between the Auditor's office and other Arkansas government officials regarding Israel Bonds, including but not limited to: ATRS Executive Director Mark White and Deputy Director Rod Graves. APERS Executive Director Amy Fecher. State Treasurer John Thurston. Senate President Pro Tempore Bart Hester. Speaker of the House Brian Evans. Representative Les Warren. DFA Secretary Jim Hudson."* > > *"Meeting Records: All calendar entries, meeting invitations, agendas, materials provided, and any notes or minutes taken by staff of the Auditor's Office for the meetings held on or about April 14-15, 2025, with Larry Berman of Israel Bonds and the various state officials listed above."* Spadoni's same-day 1:49 PM forward `Fw Freedom of Information Act Request Records Pertaining to Israel Bonds` routes the request to TJ Fowler within 53 minutes. The 8.5-month gap between request (6/22/2025) and production (3/3/2026) is the longest agency turnaround in the wiki. ### The TJ Fowler FOIA-handling chain The `Re Freedom of Information Request_4`, `Re Freedom of Information Request_5`, and `RE Freedom of Information Request_6` thread (June 19-23, 2025) documents the Auditor's-office FOIA-handling structure during the critical week. Three substantive findings. Mark White issued a SECOND ATRS Board canvass on 6/19/2025 11:18 AM in response to a NEW Lenow FOIA filing between 6/6 and 6/18. Captured in Brady Inbox via Brady's ATRS Board membership: > *"We have received a second FOIA request, this one for emails 'regarding the purchase of Israeli bonds.' I already have the emails you've provided up through June 6. If you have sent or received any emails between June 6 and June 18 regarding the purchase of Israeli bonds, please forward them to me so that I can include them in our FOIA response."* The first canvass (6/6/2025 4:48 PM) is replied-to within the thread. The Wickline Lenow chain at [[auditor-foia-r2-residual]] documented the first canvass; this is a new second canvass on a new Lenow FOIA filing — establishing **three Lenow FOIA filings at ATRS in three weeks**. Brady forwarded White's 11:19 AM canvass-email from his iPhone to TJ Fowler and Stacy Peterson at 3:16 PM. Peterson's reply at 3:58 PM: > *"TJ, is this something you want me and Kurt to handle? Thx."* TJ Fowler's signature in his 6/23/2025 8:38 AM reply identifies him as Auditor's-office General Counsel: > *"T.J. Fowler / General Counsel, Auditor of State / 1401 West Capitol, Suite 325 / Little Rock, AR 72201 / 501.831.2707 / [email protected]"* Fowler's reply body: > *"Stacy, Hopefully, Jason let you know that I was on leave last week and you already started running with this. If not, let's get together ASAP this morning."* Fowler is the third state-level General Counsel position documented in the wiki, after Olan Reeves at the Treasurer's office (Interim through Dec 2024) and Laura Gilson at APERS. The Auditor's-office FOIA-handling structure as documented in this batch: - TJ Fowler — General Counsel, formal legal authority - Stacy Peterson + Kurt Underwood — operational handlers (per Peterson's 6/19 *"me and Kurt to handle"* framing) - Wendy Spadoni — triage and forwarding (Dunlap FOIA forwarded to Fowler 53 min after receipt) - Jason Brady — Auditor's-office FOIA liaison and iPhone-based router - Melissa Corrigan — Chief of Staff coordination on personnel and routing Fowler was on leave the week of June 16-20, 2025. During his absence the Auditor's office received Lenow's 6/19 White-canvass forward and Dunlap's 6/22 primary FOIA submission. Peterson and Underwood ran the operational response without him; he returned 6/23 and rejoined the chain. Brady's 6/10/2025 12:54 PM `israel` email in Sent-Items to TJ Fowler (with empty body and attachments `ISRAEL BONDS - 03.pdf` and `ISRAEL BONDS - 04.pdf`) is the documented R1-attachment forward to Fowler for FOIA-response coordination. The two PDFs are Brady's 10/23/2024 seed message and White's same-day reply, the same files cataloged at [[auditor-foia-r1-brady]]. ### Other Brady substantive correspondence The June 9, 2025 7:28 AM Mark White `Communication with John Rollans` email to the ATRS Board (captured in Brady Inbox via designee membership) forwards White's prior 5/19-5/20 Rollans Westrock Coffee correspondence to the Board for awareness. The 5/19/2025 prior Rollans message at the wiki [[westrock-procedural-asymmetry]] is supplemented by Rollans's 3:22 PM follow-up describing Westrock as having lost approximately $200 million over three or four years with no profitable quarter, asking about divestment process. White's 5/20 reply ("I do understand your concern, but for a newer but growing company like Westrock Coffee, it is not uncommon for them to show even several years of losses before breaking through to profitability... I'll 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'") frames the consultant-driven recommendation pathway alongside independent Wall Street analyst validation. The June 11, 2025 9:00 AM APERS Q2 Board meeting packet distribution and the September 10, 2025 9:00 AM APERS Q3 Board meeting packet distribution arrived in Brady's mailbox via the standard APERS Trustee CC line (Brady as designee for Milligan). The September 10 packet was forwarded internally by Spadoni to Brady on 9/9/2025 8:07 AM. The full APERS Trustee + cc distribution lists are preserved verbatim in the forwarded copies, naming Walther at his personal Gmail address `[email protected]` as a TO recipient — cross-confirms the Treasury R2 Sub-batch 3 finding that Walther uses personal Gmail for post-Treasurer-tenure APERS business as of September 2025. The December 3, 2025 3:09 PM Amy Fecher `Information on Real Estate` distribution to APERS Trustees forwards background materials on APERS office relocation. Fecher's contemporaneous instruction: > *"I ask that you do not 'reply all' to this email as it would be a FOIA violation. While it is acceptable for me to provide the board with information, we cannot discuss board business through email."* The note establishes explicit Fecher FOIA-awareness instruction to APERS Trustees in the post-vote period. The 12/3 distribution cross-confirms the APERS R2 Sub-batches 0-6 documented Q4 Board meeting (December 3, 2025) agenda did not include Israel Bonds. The 6/26/2025 9:13 AM National Association of State Treasurers ([email protected]) `Act Fast Reserve Your Spot at NIPF!` invitation to Dennis Milligan promotes the National Institute of Public Finance enrollment. Captured in Milligan's NAST subfolder. NAST is the state-treasurer association; Milligan as Auditor receives the invitation in implicit recognition of his SFOF + treasurer-alumni network position. The two `Arkansas State Auditor Auditor of State, Your News for 6/11/2025 / 6/17/2025` Newz Group press-clipping digest emails (Wed 6/11 4:31 AM and Tue 6/17 4:33 AM, Newz Group service to Brady) document the Auditor's-office subscription to a routine news monitoring service. Substantive content not extracted; would document news coverage of the Auditor's office in the immediate post-vote period. The 12/10/2025 9:50 AM `Data Match Claims Paid` (Laura Malagon, UCP Claims Examiner I) and 1/13/2026 9:38 AM `UCP Check Run DM` (same Malagon to UCP Check Run group, processing Batch 3322 of 4,582 checks for $1,107,902.26) are routine Unclaimed Property Program correspondence not substantively related to Israel Bonds. Their appearance in the FOIA production likely reflects a broad keyword match in the response scope. The two Deleted-Items emails (`INSIDE Investments That Strengthen Israel's Economy` 8/7/2025 and `Obtain 5` 2/25/2026) and the one Recoverable-Items/Deletions email (`Emily Austin has a message for you` 2/2026 DCI promo) are DCI promotional templates matching the [[dci-promotional-pipeline]] pattern. The Brady-side post-vote DCI sales cadence continues uninterrupted through February 2026. ### Brady's iPhone-based forwarding pattern The R3 production documents Brady's systematic use of his iPhone for Israel Bonds correspondence routing. Five "Sent from my iPhone" footers appear on: - 6/6/2025 2:20 PM forward of the APERS Q2 Board packet to Spadoni - 6/10/2025 12:54 PM `israel` forward of R1-attachment PDFs to TJ Fowler - 6/19/2025 3:16 PM forward of the Mark White second canvass to TJ Fowler and Peterson - 7/11/2025 7:28 PM forward of the Ark Times article notification to Milligan's personal AOL - 7/12/2025 6:52 AM forward of the Ark Times article notification to Peterson + Corrigan - 7/12/2025 6:54 AM forward of the Arkansas Times URL to Berman The iPhone-based forwarding pattern routes Israel Bonds correspondence through Brady's mobile device, sometimes to personal-domain destinations (Milligan AOL) and external addresses (Berman at israelbonds.com) on weekend mornings. The pattern is consistent with mobile-device convenience but also has the consequence of moving correspondence outside the standard auditor.ar.gov desktop-email FOIA-search perimeter when routing to personal-AOL accounts. ## Sub-batch 2: Milligan custodian (24 files / 12 unique emails) The Milligan production has three subfolders: Inbox/Boards (8 unique), Inbox/Advertisements (3 unique), and Inbox/NAST (1 unique). The Boards subfolder cross-custodian-confirms eight emails also present in Brady's Inbox (APERS Q2 packet, APERS Q3 packet, ATRS Board Update-Liquidity, Ark Times Article + Congratulations, Ark Times on Israel Bonds, Communication with John Rollans, Information on Real Estate, and the additional `Preview of June 2 Meeting` not in Brady's mailbox). ### The 5/22/2025 Mark White Board preview cross-custodian capture `Preview of June 2 Meeting` in Milligan Inbox/Boards (also in Spadoni ATRS subfolder). Thu 5/22/2025 4:16 PM CDT, Mark White to ATRS Board Members Group. Confirms Milligan's receipt of the preview email as an ex officio Board member. Verbatim Israel Bonds paragraph from the preview: > *"Our Board colleague, State Auditor Dennis Milligan, is asking the Board to consider making an investment in Israel Bonds. These are government bonds issued and guaranteed by the nation of Israel. The Auditor made a similar request last week to the Arkansas Public Employee Retirement System, and their Board's Investment Committee approved an investment of between $25 and $50 million. Jason Brady will be making this request on behalf of the Auditor, and we will have advice and materials from Aon on how the investment could be structured. From a pecuniary standpoint, it appears to me these bonds are a worthy investment. If the Board decides to pursue this, based on my conversations with Aon, my recommendation would be an investment of up to $50 million spread over 5 years, with up to $10 million per year. This will allow us to 'ladder' the bonds and receive ongoing revenue."* The "spread over 5 years, up to $10 million per year" ladder framing is the structural counter-evidence to the 12/29/2025 Graves liquidity email's single-quarter $50 million capital call: ATRS approved Resolution 2025-22 with the laddered five-year deployment proposed in the May 22 preview, then deployed the full $50M in a single quarter via Reams. See [[atrs-reams-capital-call-execution]] for the analysis of the ladder-vs-single-call disjunction. Notable cross-custodian absence: the 5/22 preview is in Milligan's mailbox (he is an ATRS Trustee ex officio per BP1 Section XII) and Spadoni's mailbox (she handles Milligan's calendar and Board correspondence), but NOT in Brady's mailbox. Brady's documented Israel Bonds correspondence in this production begins with the 6/6/2025 APERS Q2 packet distribution; the 5/22 ATRS Board preview did not reach Brady through any forwarding chain captured in the production. ### Milligan Advertisements subfolder Three DCI promotional emails in Milligan Inbox/Advertisements: `$5 BILLION for Israel– We're Not Done Yet` (6/8/2025), `Celebrate Shavuot with Strong Rates and Stronger Bonds` (5/30/2025), `Get to Know Our eShalom Bond!` (6/5/2025). All match established [[dci-promotional-pipeline]] templates and cross-confirm DCI's continued post-vote sales cadence reaching Milligan personally. ## Sub-batch 3: Spadoni custodian (24 files / 12 unique emails) The Spadoni production has three subfolders: Inbox/Boards-&-Commissions/APERS (6 unique), Inbox/Boards-&-Commissions/ATRS (4 unique), and Inbox/Calendar-Requests (2 unique). The Boards subfolders are filed by Spadoni for archive purposes; the originals are mostly Brady-forwarded copies (Brady-from-iPhone forwarding pattern documented above). ### Spadoni Calendar-Requests subfolder Two emails preserved in Spadoni's Calendar-Requests folder for calendar coordination purposes, dated pre-vote. `Israel bonds ` (Wed 10/23/2024 3:39 PM CDT, Brady to Amy Fecher, cc Auditor Dennis Milligan via auditor@). The cross-custodian third capture of Brady's 10/23/2024 seed message — the foundational Israel Bonds outreach. Full verbatim text: > *"As you both know, the Auditor in his time as treasurer of state requested the legislature to pass legislation that would allow the state or at least the treasurer of state to invest in Israel bonds. The Auditor has been contacted by a representative of Israel Bonds and asked if he would arrange a meeting with both of you and your investment teams in November to visit. On the Auditors behalf, I am making that request of you. We are looking for a day both visits could be conducted - say no more than 1 hour - to maximize his trip to Arkansas. The Auditor has a couple of other meetings for Larry he is also trying to arrange as well - but your meetings are Larry's priority. I am out Nov. 7-12 on personal leave. I assume we will want to block out the Wednesday before Thanksgiving as well. Would you both please agree to have a meeting with him and have your exec assistant's send 3 or 4 of days next month that Might work and maybe we can start from there? Thank you for the consideration. Jason."* > > *"Sent from my iPhone"* Spadoni's retention of the seed message in her Calendar-Requests folder documents that the seed message reached her for calendar-coordination purposes, complementing Brady's R1 capture (ISRAEL BONDS - 03.pdf), the auditor@ shared-mailbox capture at [[auditor-foia-r2-residual]], and the ATRS Staff Emails capture at [[atrs-foia-r1-staff-emails]]. The seed message is now documented across four custodial vantages in the wiki. `Fwd You're Invited A Private & Exclusive Briefing` (Thu 12/26/2024 7:58 PM CST, Brady to [email protected] shared mailbox). Brady forwards the same-day 11:10 AM Ethan Behling (DCI) invitation for the 1/15/2025 Yali Rothenberg "Private & Exclusive Briefing" through the shared mailbox for calendar coordination. The Spadoni capture of this thread cross-confirms Milligan's documented personal registration and attendance at the 1/15 Rothenberg briefing per [[auditor-foia-r2-milligan]] chunk 1. ### Spadoni Boards-&-Commissions/APERS and /ATRS subfolders The APERS subfolder (6 unique) and ATRS subfolder (4 unique) hold Brady-forwarded or Milligan-forwarded copies of APERS and ATRS Board correspondence for archival. Most are cross-custodian duplicates of the same emails in Brady's Inbox and Milligan's Boards subfolder. The Preview of June 2 Meeting is in the ATRS subfolder via Spadoni's Milligan-distribution-list access. The Information on Real Estate APERS Trustee distribution is filed in the APERS subfolder. The Brady-forwarded APERS Q2 packet of 6/6/2025 2:20 PM is filed in the APERS subfolder. ## Evidence ### Rod Graves December 2025 ATRS Reams capital call execution > *"December payments since the last Board update consisted of several ATRS obligations including capital calls for various investments of approximately $185 million. This includes the Scout (Reams) mandate of $50 million for Israel Bonds and $50 million of the $100 million commitment to the Realty Income US Core Plus Fund."* > Rod Graves to ATRS Board Distribution List, ATRS Board Update-Liquidity, Mon 12/29/2025 11:23 AM CST > *"Withdrawals totaling $100 million from the SSgA Global Index Fund along with withdrawals totaling $140 million from the BlackRock Global Index Fund were required to cover December liquidity needs."* > Same email ### Brady 7/12/2025 Berman direct correspondence > *"https://linkprotect.cudasvc.com/url?a=https%3a%2f%2farktimes.com%2farkansas-blog%2f2025%2f07%2f11%2farkansas-taxpayers-are-loaning-israel-millions-of-dollars-as-its-war-in-gaza-grinds-on..."* > > *"Sent from my iPhone"* > Brady to [email protected], The Arkansas times article, Sat 7/12/2025 6:54 AM CDT (Brady Sent-Items) ### TJ Fowler signature block > *"T.J. Fowler / General Counsel, Auditor of State / 1401 West Capitol, Suite 325 / Little Rock, AR 72201 / 501.831.2707 / [email protected]"* > TJ Fowler to Stacy Peterson, RE Freedom of Information Request, Mon 6/23/2025 8:38 AM ### Mark White 6/19/2025 second ATRS Board canvass > *"We have received a second FOIA request, this one for emails 'regarding the purchase of Israeli bonds.' I already have the emails you've provided up through June 6. If you have sent or received any emails between June 6 and June 18 regarding the purchase of Israeli bonds, please forward them to me so that I can include them in our FOIA response."* > Mark White to ATRS Board Members Group, Re Freedom of Information Request, Thu 6/19/2025 11:18 AM ### Mark White 7/2/2025 Lenow response (process defense) > *"Even though this request started with a Trustee, we still followed our usual process. Nothing prohibits a Trustee from suggesting an investment. What state law requires for ATRS (but not for other systems like APERS) is for our Board to seek the 'advice' of its consultant before making an investment decision. That's exactly what the Board did in this case."* > > *"Our general investment consultant's role is to review and make recommendations about investment managers. They never make recommendations about the purchase of individual stocks or bonds. That is not their job, and they would be exceeding the scope of their securities licensure if they were to do so."* > Mark White to Jennifer Lenow ([email protected]), Re: [EXTERNAL] Request for comment, Wed 7/2/2025 4:44 PM (cross-custodian in Brady Inbox FW Request for comment and Milligan Boards Ark Times on Israel Bonds) ### Joshua Dunlap 6/22/2025 FOIA to Auditor's office > *"This request pertains to any and all records related to the promotion of, investment in, or communications concerning bonds issued by the State of Israel (commonly known as 'Israel Bonds'). The timeframe for this request is October 1, 2024, to the date this request is processed."* > Joshua Dunlap ([email protected], 920 W 41st Street, North Little Rock, AR 72118) to [email protected]; cc [email protected], Jason Brady, Wendy Spadoni; Freedom of Information Act Request: Records Pertaining to Israel Bonds, Sun 6/22/2025 12:56 PM ### Mark White 7/11/2025 Board notification of Arkansas Times article > *"I mentioned last week that the Arkansas Times was working on a story regarding the Israel bonds, and they published the story this afternoon. It's not focused on just us, it's a broader look that also includes APERS and the State Treasurer's Office... Everything in the story relating to ATRS has already been out in public for several weeks now, so I'm cautiously optimistic that this story will not create any new drama."* > Mark White to ATRS Board Distribution List, Ark Times Article + Congratulations, Fri 7/11/2025 3:55 PM (cross-custodian in Brady Inbox + Milligan Boards) ### Lenow's reporting on Pulley's HOLD memo > *"These recent decisions were made despite a recommendation made last fall by a senior investment manager within the state treasurer's office to hold off on buying more Israeli bonds. The internal report cited downgrades of Israel's long-term creditworthiness across all three major rating agencies."* > > *"One of the senior investment managers, Steve Pulley, drafted an internal report dated Oct. 8 for the treasury's investment meeting that month. Pulley recommended a 'hold on adding more bonds.' Pulley's report recommended that the state 'hold our positions and allow for the $17M to roll off [mature] in the first half of 2025 and the $20M maturing in the calendar year 2026.' Citing the recent downgrades in Israel's credit rating, he commented that 'the outlook remains negative, reflecting the ongoing uncertainties and potential for further escalations in the region.'"* > Jennifer Lenow, "Arkansas taxpayers loan Israel millions as the war in Gaza grinds on," Arkansas Times, July 11, 2025 2:26 PM (attached PDF in Brady Inbox + Milligan Boards Ark Times Article + Congratulations.eml) ### Lenow's quotation of Brady's APERS IFSC "ancillary reason" framing > *"Jason Brady, the state's deputy auditor, noted this as an 'ancillary reason' to purchase Israeli bonds when presenting a resolution at the APERS investment committee in May. 'The U.S. ambassador to Israel is a former governor of this state and coincidentally my and Amy's former boss, Mike Huckabee,' Brady said, referencing APERS Executive Director Amy Fecher. Brady also gave the committee another non-pecuniary reason for the purchase: 'Israel is considered the United States' most trusted and dependable ally in a region of the world that is volatile at best.'"* > Lenow, Arkansas Times, July 11, 2025 ### Lenow's report on Milligan non-response > *"The office of the state auditor did not respond to a request for comment about whether Milligan considered non-financial factors when advocating for state entities to invest in Israeli bonds."* > Lenow, Arkansas Times, July 11, 2025 ### Lenow's quotation of Milligan's April 2025 Facebook post > *"Milligan posted a photo of his meeting with the two men on Facebook in April. 'I'm always happy to have my friends Larry Berman and Brad Young from Israel Bonds Development Corp. in Little Rock,' he wrote. 'I'm proud to be a supporter of the State of Israel and happy to help these fine gentlemen in any way that I can.'"* > Lenow, Arkansas Times, July 11, 2025 ### Lenow's quotation of Sanders social media > *"Gov. Sarah Sanders celebrated one of the recent purchase decisions on social media with an explicitly political framing. 'Arkansas puts its money where its mouth is and is investing millions in Israeli bonds!' she proclaimed."* > Lenow, Arkansas Times, July 11, 2025 ### Mark White Westrock Coffee response to Rollans (cross-confirmation) > *"I do understand your concern, but for a newer but growing company like Westrock Coffee, it is not uncommon for them to show even several years of losses before breaking through to profitability. At ATRS our investment decisions are based on recommendations from our outside professional investment consultants."* > Mark White to John Rollans, Re: [EXTERNAL] Re: [EXTERNAL] FOI Request, Tue 5/20/2025 12:10 PM (forwarded by White to Board Members Group 6/9/2025 7:28 AM as Communication with John Rollans) ## Cross-References [[jason-brady]] - [[lawrence-berman]] - [[dennis-milligan]] - [[mark-white]] - [[stacy-peterson]] - [[kurt-underwood]] - [[melissa-corrigan]] - [[wendy-spadoni]] - [[rod-graves]] - [[reams-asset-management]] - [[jennifer-lenow]] - [[joshua-dunlap]] - [[larry-walther]] - [[amy-fecher]] - [[laura-gilson]] - [[john-rollans]] - [[tj-fowler]] - [[atrs-reams-capital-call-execution]] - [[atrs-resolution-2025-22]] - [[westrock-procedural-asymmetry]] - [[independent-credit-analysis-gap]] - [[auditor-as-dci-channel]] - [[auditor-office-org-structure]] - [[ssga-cmx6-2024-11-30]] - [[dci-promotional-pipeline]] - [[treasury-internal-credit-analysis]] - [[auditor-foia-r1-brady]] - [[auditor-foia-r2-residual]] - [[atrs-foia-r1-staff-emails]] - [[auditor-multi-official-capitol-tour]] - [[auditor-foia-r2-milligan]]