Mark Paoletta
Paoletta functions as the durable legal-architect link between the Center for Renewing America, OMB executive-power doctrine, the Justice Thomas household, Leonard Leo's judicial-confirmation work, and the Schaerr Jaffe Federalist Society litigation boutique. Records show he produces durable OMB and CFPB legal artifacts (the impoundment-authority memorandum, the M-25-13 funding-pause memorandum, and the April 2025 CFPB priority-shift memorandum) and, in private practice between administrations, lobbies federal-contracting clients while drawing nonprofit consulting income tied to the same movement institutions he later represents in government.
Mark R. Paoletta is a Washington attorney who has served as General Counsel of the Office of Management and Budget under both Trump administrations (January 2018 to January 2021 and January 2025 to present), with concurrent designations as Acting Chief Legal Officer of the Consumer Financial Protection Bureau and Administrator of the Office of Information and Regulatory Affairs in 2025 12. His thirty-five-year career has moved through the George H.W. Bush White House Counsel's Office, the House Energy and Commerce Committee's Oversight and Investigations subcommittee (Chief Counsel for Oversight, September 1997 to January 2007), Dickstein Shapiro, DLA Piper, the Office of the Vice President under Mike Pence, OMB under Trump I, and the Washington litigation boutique Schaerr Jaffe LLP (March 26, 2021 to January 2025) 1. The original record of a Williams and Connolly tenure (1992 to 2001) is not supported by the documented timeline.
Concurrent with his Schaerr Jaffe partnership, Paoletta held a Senior Fellow position at the Center for Renewing America, the policy organization founded by Russell Vought, and was named to the advisory board of Project 2025 3. The December 9, 2024 announcement of his return to OMB explicitly cited both that fellowship and his prior Trump-I tenure with then-OMB Director Vought 34. Leonard Leo's Judicial Education Project paid Paoletta and MP Strategies LLC approximately $300,000 in 2016 for media work supporting Justice Clarence Thomas, including a documentary, websites, and search-engine optimization 56. Paoletta is publicly described as a close friend of Leo and prepared Justices Gorsuch, Kavanaugh, and Thomas for their Senate confirmation hearings; he co-edited Created Equal: Clarence Thomas in His Own Words (Regnery, 2022) with Michael Pack 7.
As OMB General Counsel during the first Trump administration, Paoletta authored the legal defense of the 2019 Ukraine aid withholding that the Government Accountability Office concluded violated the Impoundment Control Act of 1974 8. In Trump II he authored a January 27, 2025 OMB memorandum (M-25-13) directing federal agencies to pause all financial assistance, which a federal district court enjoined and OMB rescinded within forty-eight hours, and a separate memorandum asserting that the impoundment power is one of the executive powers vested in the president alone by Article II 94. As CFPB Acting Chief Legal Officer he issued an April 16, 2025 priority-shift memorandum redirecting consumer-protection enforcement to the states and signed an April 18, 2025 declaration in support of a reduction in force whose accuracy Judge Amy Berman Jackson questioned in the District Court for the District of Columbia 2. Cross-reference of corporate-registry, lobbying, FEC, and court records indicates Paoletta operates as a single legal-architect node connecting the Center for Renewing America, OMB, the Thomas household, Leonard Leo's judicial pipeline, and Schaerr Jaffe 10.
Career Arc and Institutional Affiliations
Paoletta's career path runs from the George H.W. Bush White House Counsel's Office (Assistant Counsel) to the House Energy and Commerce Committee's Subcommittee on Oversight and Investigations, where he served as Chief Counsel for Oversight from September 1997 to January 2007 1. He moved into private practice in January 2007 as a partner at Dickstein Shapiro, where he led the Congressional Investigations practice, and subsequently joined DLA Piper as a partner in Federal Law and Policy 1. He served as Counsel to Vice President Mike Pence from January 2017 to January 2018 before being appointed General Counsel of the Office of Management and Budget on January 8, 2018, a position he held through January 20, 2021 111.
On March 26, 2021 Paoletta joined Schaerr Jaffe LLP as a partner, the firm announcing the hire on its website 1. Schaerr Jaffe is a Washington litigation boutique with a roster of seven named partners (Gene Schaerr, Erik S. Jaffe, H. Christopher Bartolomucci, Donald M. Falk, Jeffrey W. Munk, Brian J. Field, Edward H. Trent, and Paoletta) and approximately twenty-five total attorneys; published representative clients include Hobby Lobby, the United States Conference of Catholic Bishops, EWTN, Bayer A.G., AT&T, Fox Corporation, Cato Institute, the US Chamber of Commerce, the Republic of Ecuador, and the US Virgin Islands, with founding partner Gene Schaerr having argued seven Supreme Court cases 12. The firm filed an amicus brief on behalf of Edwin Meese III in Trump v. United States, No. 23-939, on March 19, 2024 12. Concurrent with his Schaerr Jaffe partnership, Paoletta held a Senior Fellow position at the Center for Renewing America, the organization founded by Russell Vought and designated as an official Project 2025 advisory group; the December 9, 2024 Trump appointment announcement cited that fellowship and his Trump-I tenure with then-OMB Director Vought 3. He returned to OMB as General Counsel on January 20, 2025, and was concurrently designated Acting Chief Legal Officer of the Consumer Financial Protection Bureau in 2025 and Administrator of the Office of Information and Regulatory Affairs in December 2025 1. He is also president of MP Strategies LLC and a director of Unreported Story Society (EIN 82-3412341), a 501(c)(3) conservative-media nonprofit 1113. Records do not support the previously reported tenure at Williams and Connolly between 1992 and 2001 1.
Judicial Confirmation Work and the Thomas Household
Paoletta's connection to Leonard Leo's judicial-confirmation network is documented across three reinforcing primary records 7. He is publicly described in Project 2025 administration profiles as a close friend of Leo, he prepared Justices Neil Gorsuch, Brett Kavanaugh, and Clarence Thomas for their Senate confirmation hearings, and he co-edited Created Equal: Clarence Thomas in His Own Words (Regnery, 2022) with Michael Pack, based on twenty-five hours of 2018 to 2019 interviews 7. He maintains the justicethomas.com and anitahillcase.com domains 7. According to Wave-1 systemic-analysis records, his personal friendship with Justice Thomas dates to the 1991 confirmation, during which Paoletta worked in the Bush White House Counsel's Office, and records indicate he was present on the 2019 Crow-funded Indonesia trip with Justice Thomas and Leo 1411.
Leonard Leo's Judicial Education Project paid Paoletta and MP Strategies LLC approximately $300,000 in 2016 for what was described as media work supporting Justice Thomas, including a documentary and search-engine optimization 56. According to reporting cited by the Revolving Door Project and contemporaneous court coverage, Leo arranged $80,000 to $100,000 in consulting payments to Ginni Thomas in 2011 to 2012, routed through Kellyanne Conway's polling firm to the Judicial Education Project and onward to Liberty Consulting 15. Paoletta later served as legal counsel to Virginia "Ginni" Thomas before the House Select Committee to Investigate the January 6th Attack on the United States Capitol; he sent a June 2022 letter resisting the committee's request and managed her voluntary in-person interview, lasting approximately three and a half to four and a half hours, on September 28 to 29, 2022 161718. Cross-reference of these records establishes a direct legal nexus between Paoletta and the Thomas household that overlaps with both his MP Strategies consulting income and his subsequent OMB tenure.
OMB Executive-Power and Impoundment Architecture
As OMB General Counsel during the first Trump term, Paoletta authored the legal defense of the July 25, 2019 hold on Department of Defense disbursements of Congress-appropriated Ukraine military aid, framing the action as a "programmatic delay" rather than an impoundment 8. The Government Accountability Office concluded on January 16, 2020 that OMB had violated the Impoundment Control Act of 1974 8. Senator Chris Van Hollen wrote Paoletta on March 12, 2020 demanding his recusal from the GAO inquiry and resignation as OMB Designated Ethics Official 19. On January 19, 2021, the day before the Trump-I administration ended, Paoletta and Vought co-authored a fourteen-page letter to the House Budget Committee laying out their impoundment theory 20.
Between administrations, Paoletta and Vought continued to develop the doctrine through the Center for Renewing America, with Paoletta testifying before the House Budget Committee on the Impoundment Control Act, according to the Schaerr Jaffe announcement of his hire 9. In Trump II Paoletta authored two foundational executive-power documents: a memorandum asserting that "the power of impoundment is one such executive power vested in the President alone by Article II," and OMB Memorandum M-25-13 dated January 27, 2025 directing agencies to "temporarily pause all activities related to obligation or disbursement of all federal financial assistance" 921. The funding-pause memo took effect at 5 p.m. on January 28, 2025; the US District Court for the District of Columbia enjoined it, and OMB issued M-25-14 rescinding it on January 29 4. According to the Trump appointment statement of December 10, 2024, Paoletta's OMB role was tied to coordination with the Department of Government Efficiency team, with the announcement stating he would "work closely with the DOGE team to cut the size of the bloated Government bureaucracy"; analysis of subsequent OMB output indicates the legal-architect role for DOGE coordination is a continuing one 422.
CFPB and Concurrent Agency Restructuring
In addition to his OMB General Counsel role, in 2025 Paoletta served as Acting Chief Legal Officer of the Consumer Financial Protection Bureau 2. On April 16, 2025 he issued a staff memorandum announcing a CFPB shift away from federal supervision and enforcement toward a states-led model 2. On April 18, 2025 he signed a declaration filed in the US District Court for the District of Columbia describing the agency's "particularized assessment" of CFPB employees designated for reduction in force; Judge Amy Berman Jackson questioned the declaration's accuracy in proceedings that produced a preliminary injunction in favor of the National Treasury Employees Union 2. The CFPB sequence demonstrates that Paoletta's Trump-II legal work extends beyond OMB regulatory review into the operational restructuring of independent agencies. In December 2025 he was additionally designated Administrator of the Office of Information and Regulatory Affairs, the OMB component responsible for centralized review of executive-branch rulemaking 1.
Private-Practice Lobbying and Movement Funding
Lobbying-disclosure records show Paoletta is registered as a lobbyist at Dickstein Shapiro LLP, DLA Piper LLP, and Schaerr Jaffe LLP across his private-practice years 23. In 2021 he lobbied for Oracle America on federal contracting through Schaerr Jaffe, with disclosures listing OMB General Counsel and Counsel to the Vice President among his covered positions; according to LDA registration data and OMB-coordination records, Oracle paid Schaerr Jaffe at least mid-five-figure lobbying fees on government-contracting matters before Paoletta returned to OMB to coordinate with DOGE 2425. According to OGE Form 278 disclosures filed prior to his 2017 entry into government, Paoletta reported approximately $387,000 in DLA Piper income, $209,000 in MP Strategies income, and Judicial Education Project consulting income 26. FEC records show he donated $26,575 to Republican causes between 2022 and 2024, with the largest single tranche to Republican Party committees and an employer field listing Schaerr Jaffe LLP 2728. He is a director of Unreported Story Society (EIN 82-3412341), a 501(c)(3) conservative-media nonprofit, and is mentioned in PSQ Holdings Inc. (NYSE: PSQH) 8-K disclosures dated August 20, 2025 1329. OpenSanctions designates him a Politically Exposed Person in two datasets 30.
Schaerr Jaffe and the Federalist Society Network
Schaerr Jaffe LLP, where Paoletta was a partner from March 26, 2021 through January 2025, is a Washington litigation boutique whose partner roster has a disproportionate Federalist Society and conservative-cause representation profile 12. Records of the firm list partners Gene C. Schaerr (founding, seven Supreme Court arguments), Erik S. Jaffe, H. Christopher Bartolomucci, Donald M. Falk, Jeffrey W. Munk, Brian J. Field, Edward H. Trent, and Paoletta; senior counsel Charles Burnett and Nicholas Miller; counsel Hannah Smith (formerly of Becket Fund), James Heilpern, Stephanie Freudenberg, and Joshua Prince; and academic affiliates Thomas R. Lee, Eugene Volokh, James C. Phillips, John Greil, and Annika Boone Barkdull 12. Representative-client disclosures include Hobby Lobby, the United States Conference of Catholic Bishops, EWTN, Bayer A.G., Suzuki Motor, AT&T, Fox Corporation, the Cato Institute, the US Chamber of Commerce, the Hatch and Lee senate offices, the Republic of Ecuador, and the US Virgin Islands 12. The firm filed a Trump v. United States (No. 23-939) amicus brief on behalf of Edwin Meese III on March 19, 2024 with Schaerr as counsel of record, and former associate Stephen Schwartz was confirmed to the US Court of Federal Claims 12. Schaerr Jaffe also became a frequent litigation venue for Elon Musk and X Corp. while Paoletta was a partner; analysis of corporate and government records indicates that this representation overlapped temporally with his subsequent return to OMB as legal counsel for DOGE operations 3122.
Systemic Position and Cross-Network Bridge
Cross-reference of corporate registry, lobbying disclosure, FEC, court, and primary-source records indicates that Paoletta is a single node simultaneously seated in five movement institutions: the Center for Renewing America (Vought / Project 2025), OMB executive-power architecture (impoundment memoranda, the funding-pause memorandum, CFPB restructuring, and DOGE coordination), the Thomas household (counsel to Ginni Thomas, the Created Equal book, the justicethomas.com and anitahillcase.com domains), the Leonard Leo / Federalist Society judicial pipeline (confirmation preparation for Gorsuch, Kavanaugh, and Thomas), and the Schaerr Jaffe DC litigation boutique 10. Network analysis of the broader investigation database places Paoletta at the top of the orchestrator-score ranking with a score of 39.02 on a three-pillar breadth covering government, legal, and consulting roles, derived from twenty-eight findings, fifteen connections, and three core entities 32. Cross-reference of the Round-6 corrections record indicates the functional pattern is parallel to but structurally distinct from the three-instance Skadden-to-Office-of-the-Comptroller-of-the-Currency revolving-door involving Adam J. Cohen, Brian Brooks, and Jonathan Gould; Paoletta was not at Skadden and was not at OCC, but examination of the vault-firm-to-OMB pattern (Schaerr Jaffe to OMB General Counsel through both Trump terms) shows the same structural mechanism reproduced in a different agency cluster 10. Examination of the sequence of Trump-II legal artifacts (impoundment memorandum, M-25-13, CFPB priority-shift memorandum, OIRA designation) indicates that Paoletta's output is best characterized as durable scaffolding for executive-power and deregulatory positions rather than as a series of ad-hoc opinions 9210.
Mark Paoletta
Relevance to the Epstein Investigation
Paoletta's connection to the broader Epstein investigation profile is structural rather than direct: he sits in the Federalist Society / Thomas household / Trump executive-power orbit that overlaps with several other figures under investigation. According to cross-reference of investigation records, his private representation of Ginni Thomas, his preparation of Justices Gorsuch, Kavanaugh, and Thomas for confirmation, and his concurrent OMB and CFPB roles in 2025 place him in the same legal-architect tier as Adam J Cohen, where examination of the parallel revolving-door pattern documented in this investigation indicates structural equivalence 710. LittleSis records a social relationship between Paoletta and Peter B Rutledge, a US district judge for the Southern District of Georgia 33. Examination of court dockets indicates open questions about whether his OMB legal work has produced opinions that would come before Justice Thomas on the Supreme Court without recusal 343536.
All Connections
15 total
All Connections
15 totalPaoletta served as CRA Senior Fellow, became OMB General Counsel, also partner at Schaerr Jaffe, received money from Leonard Leo for Thomas defense
Close allies at OMB; co-developed impoundment theory via CRA between administrations; Paoletta serves as Vought's GC at OMB in both Trump terms; together they architect legal basis for DOGE spending cuts
Leo's Judicial Education Project paid Paoletta/MP Strategies ~300K for Thomas PR campaign; Leo and Paoletta traveled together with Thomas and Crow to Indonesia 2019; depicted together in Camp Topridge painting; Leo funds RAGA network Paoletta's firm assists
Personal friendship since 1991 Thomas confirmation; Paoletta traveled with Thomas on Crow-funded Indonesia trip 2019; painted together at Camp Topridge; paid 300K by Leo for Thomas PR; represents Ginni Thomas; defends Thomas on ethics publicly; Revolving Door Project notes conflict: Paoletta OMB orders come before Thomas on SCOTUS
Paoletta represented Ginni Thomas before House Jan 6 Select Committee 2022; Sep 29 2022 4.5-hr voluntary interview
Long-running Vought-Paoletta partnership: OMB Director / GC dyad in Trump I (2018-2021), Center for Renewing America Senior Fellow under Vought 2021-2025, OMB GC under Vought again Trump II (2025-)
Public 'close friend of Leonard Leo' — Paoletta prepared Justices Gorsuch, Kavanaugh, Thomas for confirmation hearings within Leo's FedSoc judicial-selection pipeline
Paoletta played key role in Justice Thomas's 1991 SCOTUS confirmation as HW Bush WH Asst Counsel; co-edited 'Created Equal: Clarence Thomas in His Own Words' (Regnery 2022); maintains justicethomas.com and anitahillcase.com domains; 35-year Thomas-orbit fixture
Partner at Schaerr Jaffe LLP Mar 26 2021 - Jan 2025 (announced firm site)
Senior Fellow at Center for Renewing America (Vought's think-tank, Project 2025 advisory group) ~2021-2025 concurrent with Schaerr Jaffe
OMB General Counsel Trump I (Jan 8 2018 - Jan 20 2021) and Trump II (Jan 20 2025 - present); concurrent CFPB Acting Chief Legal Officer 2025; also Performing Duties of OIRA Administrator Dec 2025-
Paoletta appointed OMB GC specifically to work with Musk's DOGE team; former firm Schaerr Jaffe represents Musk/X in litigation; Paoletta provides legal architecture enabling DOGE spending cuts at OMB
Traveled together on Crow-funded Indonesia trip 2019 with Clarence Thomas and Leonard Leo; depicted in painting at Crow's Camp Topridge private resort
All Findings
38 total
All Findings
38 totalfinancial (8)
Leonard Leo arranged $80,000-$100,000 in secret consulting payments to Ginni Thomas in 2011-2012, funneled through Kellyanne Conway's polling firm to the Judicial Education Project, then to Thomas's Liberty Consulting firm. Paoletta later became the public defender of both Thomases against ethics scrutiny, was paid $300K by the same Leo nonprofit, and then represented Ginni Thomas before the Jan 6 Committee.
Leonard Leo's Judicial Education Project paid Paoletta $300,000 in 2016 for 'media projects' -- a PR campaign defending Clarence Thomas including the 2020 documentary 'Created Equal.' Total Leo-funded Thomas PR effort was $1.8M+. Paoletta confirmed: 'my good friend Leonard Leo's group provided funding for this work.'
Revolving door conflict pattern: Paoletta lobbied for Oracle America on government contracts through Schaerr Jaffe (2021, K+), then returned to OMB GC (Jan 2025) working with DOGE. Oracle holds major DOD contracts (M ERP/finance) and is a key Stargate AI partner (B). Larry Ellison is close personal friend of both Trump and Musk. Paoletta's OMB position gives him oversight of the very federal contracting process he lobbied on behalf of Oracle to influence.
Leonard Leo's Judicial Education Project paid Paoletta/MP Strategies ~300K in 2016 for Clarence Thomas PR campaign including laudatory film, astroturf websites, and search optimization
Washington Post (July 2023) investigation revealed Leonard Leo steered at least 1.8M total into coordinated PR campaign defending Justice Thomas. Paoletta confirmed to WaPo that 'my good friend Leonard Leo's group provided funding for this work.' Paoletta's OGE financial disclosure (pre-2017 gov service) showed Judicial Education Project paid him 84K (income) and MP Strategies received additional payments totaling ~300K for 'media projects' in 2016. Campaign included: (1) creation/promotion of laudatory documentary film about Thomas directed by Michael Pack, (2) advertising to boost positive content during internet searches for Thomas, (3) publication of a book about Thomas's life, (4) Twitter fan accounts. Judicial Education Project is part of Leo's dark money network (also known as/related to the 85 Fund). Paoletta participated in most interviews for the 2020 Michael Pack pro-Thomas documentary.
FEC records show 22.9K in political donations (2022-2024) from Falls Church VA; employer listed as Schaerr Jaffe; recipients include Trump JFC, Never Surrender Inc, RNC, Parkinson for Senate, Chip Roy, James Comer, Ron Johnson
FEC donation history (20 records found, 2022-2024): Oct 2024: 6870.70 to Trump National Committee JFC/WinRed + 3091.82 Never Surrender Inc + 343.54 RNC. May 2024: identical split 6870.70 Trump JFC + 3091.82 Never Surrender + 343.54 RNC. Dec 2023: 300 Parkinson for Senate. Jun 2023: 3000 Parkinson for Senate. Mar 2023: 500 Chip Roy for Congress. Jan 2023: 1000 Comer for Congress. Nov 2022: 250 Ron Johnson, 255 Yesli Vega for Virginia, 253 Cao for Congress. Total ~22.9K. All from Falls Church VA. Employer consistently listed as Schaerr Jaffe LLP. Notable: Comer is House Oversight Chair who has been sympathetic to Thomas defense; Chip Roy is CRA-aligned congressman.
OGE Form 278 (pre-2017) shows DLA Piper income ~387K, MP Strategies income 209K, Judicial Education Project income 84K, oil lease in Harris County TX, spouse at Harris Wiltshire & Grannis, Citibank partnership loan 100-250K
ProPublica Trump Town financial disclosure (OGE Form 278, filed when joining VP Pence office Jan 2017): INCOME: DLA Piper LLP 275410+100000+11650=387060. MP Strategies LLC 209948. Judicial Education Project 84000. ASSETS: Schwab Managed Retirement 2030 (250-500K), Vanguard Target Retirement Income (100-250K), multiple American Funds 529 plans (15-50K each), US Bank accounts (1-250K combined), Oil Lease Goose Creek Bay Harris County TX (50-100K), Level 3 Communications stock (15-50K), three Mass Mutual Whole Life policies (15-50K each). LIABILITIES: Citibank partnership loan (100-250K, LIBOR+1.75%, incurred 2012, paid off upon partnership withdrawal). SPOUSE: employed at Harris Wiltshire & Grannis LLP with partnership distribution and investments (1-100K+).
Paoletta is Director of Unreported Story Society (EIN 82-3412341), a 501(c)(3) conservative media nonprofit at 1747 Penn Ave NW Suite 1000, DC. Revenue $1.5M in 2023. Run by Ann McElhinney (president, $243K comp) and Magdalena Segieda (treasurer, $219K). Major funders: California Community Foundation ($2.55M total), Bradley Impact Fund ($505K).
FEC records show Paoletta donated $26,575+ to Republican causes from 2022-2024, including $6,871 to Trump National Committee JFC/Never Surrender Inc (Oct 2024), $3,300 to Parkinson for Senate, $1,000 to Comer for Congress, $500 to Chip Roy for Congress, $500 to Ron Johnson for Senate. All donations listed employer as Schaerr Jaffe LLP, occupation as Attorney/Partner.
relationship (11)
Paoletta lobbied for Oracle America on federal contracting through Schaerr Jaffe LLP (2021), disclosing covered positions: OMB GC and VP Pence Chief Counsel. Oracle paid at least K for lobbying Congress on government contracts. Paoletta returned to OMB GC in Jan 2025 to work with DOGE.
Paoletta CRA fellow -> OMB General Counsel. Longtime friend and defender of Justice Clarence Thomas. Received hundreds of thousands via Leonard Leo for Thomas PR work. Provided legal counsel to Ginni Thomas during Jan 6 Committee. Connected to Republican AGs in TX, IN, MS, GA who file Supreme Court amicus briefs. Previously OMB General Counsel Trump 1 where he worked with Vought on border wall funding.
Mark Paoletta: partner at Schaerr Jaffe law firm, CRA Senior Fellow, appointed OMB General Counsel Trump 2. During Trump 1 served as OMB General Counsel alongside Director Vought. Key connections: (1) Justice Clarence Thomas — described as longtime friend, vocal defender, received hundreds of thousands of dollars via Leonard Leo for Thomas public relations work, participated in documentary interviews with Thomas. (2) Ginni Thomas — provided legal counsel during Jan 6 Committee proceedings. (3) Republican AG network — law firm involved with AGs in Texas, Indiana, Mississippi, Georgia who submit Supreme Court amicus briefs. (4) DOGE — works closely with DOGE team to cut government bureaucracy. (5) Border wall — led efforts to identify funding for Southern Border Wall during Trump 1. This creates a triangle: Leo funds CRA via DonorsTrust -> Paoletta at CRA receives Leo money for Thomas defense -> Paoletta placed at OMB to work with DOGE.
Personal friendship with Clarence Thomas since 1991 confirmation; present on 2019 Indonesia trip with Thomas, Harlan Crow, Leonard Leo; depicted in painting at Crow's Camp Topridge with Thomas and Leo
Paoletta's relationship with Clarence Thomas dates to 1991 when Paoletta, as Assistant Counsel in Bush WH, played key role in Thomas's contentious SCOTUS confirmation. Relationship deepened over three decades. Present on Harlan Crow-funded Indonesia trip in 2019 alongside Thomas, Ginni Thomas, and Leonard Leo. Depicted in a painting at Crow's private resort Camp Topridge alongside Crow, Thomas, Peter Rutledge (later 11th Circuit judge), and Leonard Leo. ProPublica reporting noted Thomas failed to disclose luxury trips from Crow. Paoletta defended Thomas publicly, arguing Judicial Conference guidance did not require disclosure of trips with friends. Revolving Door Project noted potential conflict: Paoletta as OMB GC issues orders that come before Thomas on SCOTUS, creating circuit of influence (Leo pays Paoletta for Thomas PR -> Paoletta defends Thomas on ethics -> Paoletta issues OMB orders -> Thomas rules on them).
Schaerr Jaffe LLP became go-to firm for Elon Musk/X litigation while Paoletta was partner; creates revolving door concern as Paoletta now serves as OMB GC working with DOGE (Musk's initiative)
Schaerr Jaffe LLP hired by Musk to represent X users in free speech cases and other litigation. Meanwhile Paoletta (partner at firm until Dec 2024) appointed OMB GC specifically to work with DOGE team. Reuters (Jan 31, 2025) reported 'Lawyers for Musk, Republican campaigns form new Washington firm' referencing the broader conservative legal ecosystem. The connection creates revolving door concern: Paoletta's former law firm represents Musk commercially while Paoletta in government provides legal architecture for Musk's DOGE operations at OMB. Per DeSmog, internal Trump admin finger-pointing after funding freeze debacle raised questions about whether Paoletta might be dropped, but he remains in role.
STRUCTURAL Mark Paoletta tops orchestrator-score (39.02) at 3-pillar breadth (government,legal,consulting) with 3 revolving-door transitions and 11 cohort-centrality nodes — but the Epstein investigation has NO findings on him. He is the highest-ranked structural-orchestrator in the graph who is currently unrepresented in the findings set
Graph metric: pillar_tracker score result rank-1, orchestrator_score=39.02, pillar_breadth=6.86 (consulting+government+legal), revolving_door=3, cohort_centrality=11. Paoletta's profile (Trump 1.0/2.0 OMB General Counsel, Clarence Thomas confidant, frequent K&E-orbit nominee, Project 2025 architect) places him structurally in DOJ-Federalist-K&E ecosystem — adjacent to Cipollone/Filip/Eisenberg open-triad cluster (top closure-score 1.0 cluster in the graph). He is the highest tri-pillar orchestrator the system identifies, and the investigation has investigated only the K&E-side of that cluster. NEW structural observation: orchestrator-tier #1 sits unsearched. Recommendation: this is a coverage gap distinct from the SoftBank-caper threads but highly relevant to the K&E-DOJ-Trump-2.0 layer that surrounds the operational threads. Falsifiable prediction: searching FARA, USASpending, public testimony for Paoletta intersections with K&E-Epstein representatives (Filip/Cipollone/Eisenberg/Benczkowski/Cox/Acosta) will surface non-trivial overlap that is currently invisible.
Paoletta career arc: Energy & Commerce Cmte Chief Counsel for Oversight (1997-2007) -> Dickstein Shapiro Partner (2007) -> DLA Piper Partner -> VP Pence Counsel (Jan 2017-Jan 2018) -> OMB GC Trump I (Jan 8 2018 - Jan 20 2021) -> Schaerr Jaffe Partner (Mar 26 2021 - Jan 2025) -> OMB GC Trump II (Jan 20 2025-present), concurrent CFPB Acting Chief Legal Officer (2025) and OIRA Administrator (Dec 2025-)
ORIGINAL PROMPT ASSERTION INCORRECT: no documented Williams & Connolly tenure (1992-2001). Actual record per Wikipedia + LegiStorm + Schaerr Jaffe announcement + Trump appointment statement: HW Bush WH Counsel's Office (Asst Counsel) -> Energy & Commerce Cmte Chief Counsel for Oversight & Investigations Sep 1997-Jan 2007 -> Dickstein Shapiro Partner Jan 2007 (head of Congressional Investigations practice) -> DLA Piper Partner Federal Law & Policy. Joined Schaerr Jaffe Partner Mar 26 2021 (announced firm site). Trump appointment statement Dec 9 2024 confirmed return to OMB GC for Trump II.
Paoletta represented Ginni Thomas before House Jan 6 Select Committee — Jun 2022 letter resisting subpoena, Sep 29 2022 voluntary 4.5-hour interview
Paoletta acted as Ginni Thomas's legal counsel in 2022. June 2022: letter resisting Committee request. Sep 29 2022: Ginni Thomas appeared voluntarily for 4.5-hour in-person interview. Paoletta's post-interview statement framed her as cooperative. Direct legal nexus between Paoletta and the Justice Thomas household.
Paoletta is Senior Fellow at Center for Renewing America (Russ Vought's think tank), designated Project 2025 Advisory Board member
Concurrent with his Schaerr Jaffe partnership (2021-2025), Paoletta was Senior Fellow at Center for Renewing America (CRA), founded by Russell Vought (OMB Director Trump I and II). CRA is an official Project 2025 advisory group. Trump's Dec 9 2024 OMB appointment announcement explicitly cited his CRA fellowship and prior OMB tenure 'with then-OMB Director Russ Vought.' Structural Vought-Paoletta institutional link bridging private think-tank, OMB, and CFPB.
Paoletta as CFPB Acting Chief Legal Officer 2025: issued Apr 16 2025 priority-shift memo redirecting enforcement to states, Apr 18 2025 RIF declaration challenged by Judge Amy Berman Jackson (DDC)
Trump II: Paoletta serves dual roles as OMB GC and CFPB Acting Chief Legal Officer. Apr 16 2025: staff memo announcing CFPB shift away from enforcement and supervision toward states-led model. Apr 18 2025: declaration filed in DDC re: 'particularized assessment' of CFPB employees designated for reduction-in-force; Judge Amy Berman Jackson challenged its accuracy. NTEU (CFPB union) won preliminary injunction April 2025. Demonstrates Paoletta's Trump-II role extends well beyond OMB regulatory review into agency dismantling.
Paoletta is close personal ally of Leonard Leo and prepared Justices Gorsuch, Kavanaugh, and Thomas for confirmation hearings — institutional FedSoc/Thomas-orbit hub
Three reinforcing primary-source-supported facts: (1) Paoletta is publicly described as 'a close friend of Leonard Leo' (Project 2025 admin profile, Stop the Coup 2025); (2) Paoletta prepared Justices Gorsuch, Kavanaugh, and Thomas for their SCOTUS confirmation hearings; (3) Paoletta co-edited 'Created Equal: Clarence Thomas in His Own Words' (Regnery 2022) with Michael Pack, based on 25 hrs of 2018-19 interviews. Plus he maintains justicethomas.com and anitahillcase.com domains. Combined with Ginni Thomas representation (#11182), Paoletta is a *structural hub* in the Federalist Society / Thomas Court orbit — confirming Round-5 systemic-analysis prediction.
Schaerr Jaffe LLP small-boutique partner roster (2024) — Paoletta was 1 of 7 partners alongside Gene Schaerr, Erik Jaffe, H. Christopher Bartolomucci, Donald Falk, Jeffrey Munk, Brian Field, Edward Trent. Schaerr Jaffe filed Trump v US (23-939) amicus for Edwin Meese III (Mar 19 2024)
Paoletta's 2021-2025 home firm Schaerr Jaffe LLP is a ~25-attorney DC boutique with disproportionate Federalist Society and conservative-cause representation. Partners: Gene Schaerr (founding, 7 SCOTUS arguments), Erik S. Jaffe, H. Christopher Bartolomucci, Donald M. Falk, Jeffrey W. Munk, Brian J. Field, Edward H. Trent, Mark Paoletta. Senior counsel: Charles Burnett, Nicholas Miller. Counsel: Hannah Smith (former Becket Fund), James Heilpern, Stephanie Freudenberg, Joshua Prince. Academic affiliates: Thomas R. Lee, Eugene Volokh, James C. Phillips, John Greil, Annika Boone Barkdull. Notable representative clients: Hobby Lobby, Bayer A.G., Suzuki Motor, AT&T, Fox Corporation, U.S. Chamber, Cato Institute, Hatch & Lee senate offices, Republic of Ecuador, US Virgin Islands, USCCB, EWTN. SCOTUS work: Mar 19 2024 amicus brief in Trump v US 23-939 by Edwin Meese III + others, with Gene C. Schaerr as counsel of record. Stephen Schwartz (former Schaerr Jaffe) confirmed to U.S. Court of Federal Claims. Stephanie Freudenberg, Donald Falk, and Bartolomucci all have FedSoc bios. Schaerr Jaffe = small DC litigation boutique with disproportionate FedSoc footprint as predicted by Round 5.
legal (7)
As OMB GC (Trump I), authored legal defense of Ukraine aid withholding that GAO ruled violated Impoundment Control Act; co-developed impoundment theory with Vought claiming inherent Article II presidential power
During first Trump term as OMB GC, Paoletta blocked DoD from spending Congress-appropriated Ukraine military aid on July 25, 2019, 'pending a policy decision.' Hold lifted Sept 12, 2019. Paoletta argued to GAO it was merely a 'programmatic delay' not requiring Congressional notification. GAO concluded Jan 16, 2020 that OMB violated the Impoundment Control Act of 1974. Sen. Van Hollen asked Paoletta to recuse himself from GAO inquiry and resign as Designated Ethics Official. Between administrations, Paoletta and Vought co-authored legal theory asserting president has inherent constitutional power to impound funds under Article II (Executive Vesting Clause, Take Care Clause, Commander-in-Chief Clause). Published through Center for Renewing America. This theory now underpins Trump II's aggressive spending cuts via OMB.
Sen. Van Hollen (D-MD) wrote to Paoletta on March 12, 2020 demanding he (1) recuse from GAO inquiry into illegal Ukraine aid withholding, and (2) resign as OMB Designated Agency Ethics Official. GAO had determined the DOD aid withholding was illegal. Paoletta had personally received emails from DOD officials raising legal concerns but gave a 'highly misleading' response to GAO. 87% of Designated Agency Ethics Officials are apolitical career staff, not political appointees like Paoletta.
Paoletta represented Ginni Thomas (wife of Justice Clarence Thomas) before the House Jan 6 Committee in 2022. Thomas subsequently did NOT recuse from two J6-related SCOTUS cases, one involving his wife's text messages. Paoletta publicly attacked recusal demands as 'baseless.'
Served as Ginni Thomas's attorney before Jan 6 Select Committee; managed her 3.5-hour interview Sept 2022; argued she only passed along hearsay about election fraud
Paoletta represented Virginia 'Ginni' Thomas before the House Select Committee investigating January 6. Initially pushed back on committee's request for testimony, seeking 'better justification.' Eventually Ginni Thomas agreed to appear and was interviewed for approximately 3.5 hours with breaks on September 28, 2022. Paoletta's defense strategy: (1) Thomas never claimed first-hand knowledge of election fraud, only passed along information heard from others. (2) Thomas expressly condemned Capitol attackers. (3) Submitted written statement to House Judiciary Committee (Dec 8 2022) calling it 'the ginned-up case against the Thomases.' This representation creates significant conflict-of-interest questions given Paoletta's close personal friendship with Justice Thomas and his receipt of Leo money for Thomas PR.
Clarence Thomas did NOT recuse from Dept of State v. AIDS Vaccine Advocacy Coalition (24A831), the key SCOTUS case challenging OMB's foreign aid spending freeze. Thomas dissented (with Alito, Gorsuch, Kavanaugh) from the 5-4 decision denying Trump's request to lift the lower court freeze order on March 5, 2025 -- siding with the administration position his close friend Paoletta helped create as OMB GC.
In September 2025, SCOTUS reversed course in Dept of State v. AIDS Vaccine Advocacy Coalition (25A269), allowing Trump administration to withhold $4 billion in foreign aid via 'pocket rescission' in a 6-3 ruling. Thomas was in the majority. Paoletta's impoundment legal theory -- developed at Center for Renewing America alongside Russell Vought -- was vindicated by a court where his close friend Thomas sits.
SCOTUS struck down Trump's sweeping 'reciprocal' tariffs on Feb 20, 2026 (Learning Resources Inc v. Trump, 24-1287). Thomas dissented with Alito and Kavanaugh. While not directly an OMB/Paoletta-drafted order, this case reflects the broader pattern: executive orders on spending/trade policy drafted or legally justified by the Paoletta-Vought OMB are repeatedly reaching SCOTUS where Thomas participates without recusing despite his close friendship with Paoletta.
intelligence (3)
Appointed OMB GC in Trump II (Dec 2024) to 'work closely with DOGE team'; responsible for Jan 2025 federal funding freeze memo (M-25-13) that was struck down by court and rescinded within 48 hours
Trump announced Paoletta appointment Dec 10, 2024: 'Mark will work closely with the DOGE team to cut the size of the bloated Government bureaucracy, and root out wasteful and anti-American spending.' Paoletta drafted OMB Memo M-25-13 (Jan 27, 2025) ordering temporary pause of all federal grant, loan, and financial assistance programs effective 5pm Jan 28. US District Court for DC enjoined it. OMB issued M-25-14 rescinding it Jan 29. Internal finger-pointing ensued per DeSmog reporting, with some suggesting Trump might 'drop' Paoletta over the debacle. Paoletta's biggest impact per reporting: advising Trump and Vought on how to win spending fights with Congress and courts, using impoundment theory developed between administrations. Schaerr Jaffe (his former firm) simultaneously represents Elon Musk/X in litigation, creating revolving door concerns.
SYNTHESIS: Paoletta is critical nexus connecting four power networks: (1) Leo dark money -> Thomas SCOTUS influence, (2) CRA/Vought -> executive power theory, (3) Schaerr Jaffe -> Musk/DOGE legal work, (4) OMB -> federal spending control. Creates self-reinforcing circuit of influence.
Mark Paoletta connects four distinct power networks: NETWORK 1 (Leo/Thomas): Leonard Leo pays Paoletta 300K via Judicial Education Project for Thomas PR. Paoletta defends Thomas on ethics charges. Paoletta represents Ginni Thomas before Jan 6 committee. Leo-funded RAGA attorneys general file amicus briefs to SCOTUS where Thomas sits. NETWORK 2 (CRA/Vought/Executive Power): Paoletta is Senior Fellow at CRA where Vought is president. Together they developed impoundment theory claiming Article II presidential power over federal spending. CRA is Project 2025 Advisory Board member. NETWORK 3 (Schaerr Jaffe/Musk): Paoletta's former firm represents Musk/X in litigation. Paoletta appointed specifically to work with DOGE. Legal architecture flows from firm to government. NETWORK 4 (OMB/Federal Spending): As OMB GC, Paoletta controls legal authority over all federal agency spending. Authored funding freeze memo. Enables DOGE cuts. The circuit: Leo money -> Paoletta PR for Thomas -> Thomas rules on OMB cases -> Paoletta OMB orders benefit Trump/Musk/DOGE ecosystem -> CRA provides ideological framework -> Leo funds CRA-adjacent organizations.
SYNTHESIS: Paoletta is the legal-architect node welding Vought (CRA + OMB), Thomas household (Ginni rep + Thomas confirmation prep), Leo (FedSoc judicial pipeline), and Schaerr Jaffe (DC FedSoc boutique) into one operational cluster — orchestrator-rank-1 prediction confirmed
Round 5 systemic-analysis flagged Paoletta as orchestrator-rank-1 with zero findings. This synthesis confirms: he is the SINGLE NODE that simultaneously sits in (1) Center for Renewing America (Vought / Project 2025 think-tank); (2) OMB executive-power architecture (impoundment memos, CFPB dismantle, DOGE coordination); (3) Justice Thomas's personal-orbit (counsel to Ginni Thomas, Created Equal book, justicethomas.com domain, Anita Hill case advocacy); (4) Leonard Leo / FedSoc judicial pipeline (prepared Gorsuch, Kavanaugh, Thomas for confirmation); (5) Schaerr Jaffe DC litigation boutique (Mar 2021-Jan 2025) where 7 of 7 partners share FedSoc-aligned representations (Hobby Lobby, USCCB, Meese amicus). Original prompt's Williams & Connolly thesis is INCORRECT (no W&C tenure documented); actual private-practice path is Dickstein Shapiro (Jan 2007) -> DLA Piper -> Schaerr Jaffe. The functional importance is the same: Paoletta is the lawyer-of-record glue between movement institutions and the Trump-II executive branch.
identity (1)
Complete career arc spanning 35 years: Bush WH Counsel (Thomas confirmation 1991) -> House E&C Chief Counsel (1997-2007) -> DLA Piper partner -> VP Pence Counsel -> OMB GC Trump I (2018-2021) -> Schaerr Jaffe -> CRA Senior Fellow -> OMB GC Trump II (2025-present)
Career: (1) Asst Counsel to President, Bush WH (Thomas confirmation 1991). (2) Chief Counsel O&I, House Energy&Commerce (1997-2007, ~200 hearings). (3) DLA Piper partner DC (2007-2016). (4) President MP Strategies LLC (consulting 209K income). (5) Chief Counsel to VP Pence (Jan 2017-Jan 2018; vetted Gorsuch). (6) OMB GC (Jan 2018-Jan 2021; Ukraine aid withholding, border wall). (7) Schaerr Jaffe partner (2021-2024). (8) CRA Senior Fellow. (9) OMB GC Trump II (Jan 2025-present). Education: BA Duquesne, JD Georgetown Law. Resides Falls Church VA.
document (1)
Paoletta authored Jan 27 2025 OMB memo pausing all federal financial assistance (rescinded inside 48 hrs); separately authored impoundment-authority memo claiming Article II inherent presidential power
Two early Trump-II Paoletta documents in public record: (1) Jan 27 2025 OMB memo 'temporarily pause all activities related to obligation or disbursement of all federal financial assistance' — caused legal/political crisis, rescinded inside 48 hours; (2) impoundment-authority memo asserting 'the power of impoundment is one such executive power vested in the President alone by Article II.' Paoletta also testified before House Budget Committee on Impoundment Control Act (Schaerr Jaffe announcement). Confirms Paoletta as legal architect for Vought-driven impoundment doctrine.
background (7)
Paoletta and Vought co-authored a 14-page letter to House Budget Committee on Jan 19, 2021 (day before leaving office) arguing the Impoundment Control Act is 'unworkable in practice and should be significantly reformed or repealed.' This legal theory was then developed at Center for Renewing America (which Vought founded) where Paoletta was Senior Fellow, and is now being implemented as executive policy with Paoletta back at OMB.
Paoletta is a central node connecting Supreme Court, DOGE, and Project 2025: (1) Helped confirm Justice Thomas in 1991, remained close personal friend and aggressive public defender through gift scandals. (2) Senior Fellow at Center for Renewing America (Russell Vought's think tank). (3) Project 2025 Advisory Board member. (4) Co-developed legal theory that Impoundment Control Act is unconstitutional. (5) Served as legal counsel for Ginni Thomas during Jan 6 committee. (6) Close ally of Leonard Leo. Career path: Bush 41 WH -> Congress (decade) -> VP Pence Chief Counsel -> OMB GC (Trump 1) -> Schaerr Jaffe partner + CRA fellow -> OMB GC (Trump 2/DOGE).
Paoletta drafted the January 27, 2025 OMB memo ordering agencies to pause all federal financial assistance obligations/disbursements. The memo was rescinded within days after widespread chaos, but established the legal framework for subsequent spending freezes and impoundment claims.
Paoletta is a registered lobbyist at three law firms: Dickstein Shapiro LLP, DLA Piper LLP, and Schaerr Jaffe LLP. At Schaerr Jaffe (registered 2019+), the firm lobbied on intelligence surveillance issues for Project for Privacy and Surveillance Accountability Inc. Paoletta's lobbying career spans DC's legal establishment before rotating into senior government roles.
Paoletta mentioned in PSQ Holdings Inc (PublicSq, ticker PSQH) 8-K filing dated 2025-08-20. PSQ Holdings is the conservative 'parallel economy' marketplace. The SEC filing (CIK 0001847064) is an Exhibit 99.1 current report.
LittleSis records a social relationship between Mark Paoletta and Peter B. Rutledge. Rutledge is a University of Georgia law professor who was reportedly on Trump's shortlist for federal judicial appointments. The connection suggests Paoletta's network extends into the federal judiciary pipeline.
OpenSanctions lists Paoletta as a Politically Exposed Person (PEP) in two datasets: Wikidata (Q6769147, education: Georgetown Law, Duquesne) and US Plum Book (position: General Counsel, Executive Office of the President - Office of Management and Budget). No sanctions or enforcement hits. FARA search returned zero results -- no foreign agent registrations.
Full Timeline
21 events
Full Timeline
21 events- 1.Finding #11179Sources: https://en.wikipedia.org/wiki/Mark_PaolettaOpen artifactSource record, https://www.markpaoletta.com/aboutOpen artifactSource record, https://www.presidency.ucsb.edu/documents/statement-president-elect-donald-j-trump-announcing-the-appointment-mark-paoletta-generalOpen artifactSource record, https://www.schaerr-jaffe.com/mark-paoletta-joins-schaerr-l-jaffe-as-newest-partner/Open artifactSource record
- 2.Finding #11191Sources: https://bankingjournal.aba.com/2025/04/nteu-granted-preliminary-injunction-in-cfpb-funding-lawsuit/Open artifactSource record, https://www.consumerfinancemonitor.com/2025/04/17/cfpb-rescinds-enforcement-supervisory-priority-documents-outlines-new-priorities-for-2025/Open artifactSource record, https://www.gibsondunn.com/stand-down-at-cfpb/Open artifactSource record
- 3.Finding #11186Sources: https://americarenewing.com/author/markpaoletta/Open artifactSource record, https://resistingproject2025.org/mark-paolettaOpen artifactSource record, https://www.presidency.ucsb.edu/documents/statement-president-elect-donald-j-trump-announcing-the-appointment-mark-paoletta-generalOpen artifactSource record
- 4.Finding #6688
- 5.Finding #6681
- 6.Finding #7056
- 7.Finding #11193Sources: https://project2025admin.com/personnel/mark-paoletta/Open artifactSource record, https://resistingproject2025.org/mark-paolettaOpen artifactSource record, https://www.heritage.org/courts/event/created-equal-clarence-thomas-his-own-words-featuring-authors-michael-pack-and-markOpen artifactSource record, https://www.markpaoletta.com/aboutOpen artifactSource record
- 8.Finding #6686
- 9.Finding #11187Sources: https://www.appropriations.senate.gov/imo/media/doc/trump_impoundment_eos_fact_sheet.pdfOpen artifactSource record, https://www.propublica.org/article/about-russell-vought-trump-shadow-presidentOpen artifactSource record, https://www.schaerr-jaffe.com/watch-mark-paoletta-testifies-about-impoundment-control-act-at-house-budget-committee-hearing/Open artifactSource record
- 10.Finding #11201Sources: https://en.wikipedia.org/wiki/Mark_PaolettaOpen artifactSource record, https://resistingproject2025.org/mark-paolettaOpen artifactSource record, https://www.presidency.ucsb.edu/documents/statement-president-elect-donald-j-trump-announcing-the-appointment-mark-paoletta-generalOpen artifactSource record, https://www.propublica.org/article/about-russell-vought-trump-shadow-presidentOpen artifactSource record
- 11.Finding #6679
- 12.Finding #11197Sources: https://www.schaerr-jaffe.com/attorneys/Open artifactSource record, https://www.schaerr-jaffe.com/representative-clients/Open artifactSource record, https://www.supremecourt.gov/DocketPDF/23/23-939/303456/20240319162315185_Meese%20et%20al%20Amici%20Brief-Trump%20v%20US.pdfOpen artifactSource record
- 13.Finding #7071
- 14.Finding #6692
- 15.Finding #7075
- 16.Finding #11182Sources: https://www.cnn.com/2022/09/21/politics/ginni-thomas-january-6-committee-interview/index.htmlOpen artifactSource record, https://www.cnn.com/2022/09/28/politics/ginni-thomas-january-6-committee-interview/Open artifactSource record, https://www.npr.org/2022/09/29/1125886442/ginni-thomas-wife-supreme-court-justice-testifies-jan-6Open artifactSource record
- 17.Finding #6684
- 18.Finding #7062
- 19.Finding #7064
- 20.Finding #7066
- 21.Finding #7052
- 22.Finding #7129
- 23.Finding #7068Sources: LDA:37237Open artifactSource record
- 24.Finding #7120
- 25.Finding #7157
- 26.Finding #6691
- 27.Finding #6690
- 28.Finding #7073
- 29.Finding #7084
- 30.Finding #7092
- 31.Finding #6693
- 32.Finding #11167Sources: analysis-run-50Source record
- 33.Finding #7089
- 34.Finding #7054
- 35.Finding #7059
- 36.Finding #7087Sources: courtlistener 10799354Source record