Breitbart News has learned that a mysterious group called Virginians for Limited Government (VLG) recently sent out $11,851 of direct mail pieces favoring the candidacy of Corey Stewart and opposing the candidacies of Scott Lingamfelter, Steve Martin, and Jeanmarie Davis in the race for the Republican nomination for Lieutenant Governor in an apparent violation of Virginia election law. 

The state’s election laws and policies require that “[a]ny person, association, organization or group of individuals that anticipates receiving contributions and/or spending funds in excess of $200 in order to influence the outcome of any non-federal election in Virginia must register as a political committee with [the Virginia State Board of Elections].”  The law also requires that independent expenditure reports from political action committees registered with the Virginia SBE are “due within 24 hours of the time when the funds were expended or dissemination of the expenditure (whichever is first).” 

A Virginia resident who operates the Virginia Conservative website reported that the pro-Stewart mailer paid for by VLG arrived in his mailbox on Monday, May 6. The mailers appear to have been sent to the entire list of the 13,000 delegates who will be attending the Republican nominating convention in Richmond on May 18 for the purpose of selecting the party’s nominees for Governor, Lieutenant Governor, and Attorney General. 

Breitbart News searched the Virginia State Board of Elections [SBE] public reports website on Friday and found no listing for a registered political action committee using the name Virginians for Limited Government. Breitbart News then confirmed with a spokesperson for the Virginia SBE that as of 3 pm on Friday, May 10 VLG had not filed the required Statement of Organization with the Virginia SBE. 

The Virginia SBE spokesman initially told Breitbart News that, according to information provided by other officials at the Virginia SBE, they understood that VLG was not required to file a Statement of Organization because it was a federal political action committee registered with the Federal Election Commission. State law, however, is very specific in stating that “[a]ny political action committee that is registered  with the Federal Election Commission is only required to file a Statement of Organization with [the Virginia] SBE.” 

Breitbart News requested that the spokesperson for the Virginia SBE provide copies of any files from the Federal Election Commission showing that VLG was registered with that agency as a federal political action committee. A Breitbart search performed of the Federal Election Commission website was unable to show any such listing.

Half an hour later, the Virginia SBE sent Breitbart News links to documents filed with the Federal Election Commission which they believed complied with this request. Breitbart News reviewed these documents and found that they were for an entirely different organization unrelated to VLG, Americans for Limited Government, which apparently had a political action committee arm registered with the FEC during 2010 and 2011. 

Shortly after, the same official phoned back and notified Breitbart News that while there was still no Statement of Organization, other officials at the Virginia SBE had received two independent expenditure reports from VLG sent by fax from a FedEx Office location in Alexandria, Virginia. The first was faxed on Tuesday, May 7 and the second was faxed on Thursday, May 9. The spokesperson subsequently forwarded those reports to Breitbart News by email.

Both reports left the line for the organization’s Virginia SBE identification number blank. These identification numbers are assigned when a political action committee files its original Statement of Organization. The lack of such a number in this independent expenditure report supports what a spokesperson for the Virginia SBE confirmed and what Breitbart News’s own search of the Virginia SBE website revealed: no such Statement of Organization has been filed.

The first report indicated that VLG spent $9,926.96 on May 6, and the second report indicated that VLG spent $2,555.00 on May 9. Both reports indicated “mail” as the purpose of the expenditure, “The Voyaguer Company of Omaha, Nebraska” as the vendor, and stated that 25% of the expenditure was in support of Stewart, 25% was in opposition to Davis, 25% was in opposition to Martin, and 25% was in opposition to Lingamfelder. 

The signatures on both reports are unrecognizable. The authorizer of the expenditures is listed as “John Granderson” in the first report and “John Grandson” in the second.

Breitbart News phoned the day time contact phone number listed on both reports, but received no answer.

When VLG was incorporated in the Commonwealth of Virginia on April 27, 2012, the same attorney who has served as General Counsel for the Republican Party of Virginia since 2009, Lee E. Goodman, was listed as the corporation’s registered agent. Mr. Goodman is an attorney and shareholder with the law firm of LeClair Ryan, which is headquartered in Washington, D.C. but also has an office at 123 Main Street, 8th floor, Charlottesville, Virginia, the same address listed as the registered office of VLG. Sources tell Breitbart News that Mr. Goodman is still affiliated with VLG. 

Breitbart News phoned Mr. Goodman at his Washington, D.C. office on Friday to verify this information, but he refused to comment. We identified the purpose of our call as a press inquiry, and then asked Mr. Goodman if he could confirm for us that he was the registered agent for VLG, and if so, if he could explain why the firm had failed to file a Statement of Organization, as is required by law.  Mr. Goodman responded “I don’t comment on any company our firm represents in a registered agent or any other capacity. Thank you.”  

Saturday evening, Pat Mullins, Chairman of the Republican Party of Virginia, provided this email statement to Breitbart News: “The Republican Party of Virginia has from the beginning been and will remain, scrupulously neutral in regard to all party nomination contests. Any questions about Lee Goodman’s work with his legal clients should be referred to him.”

VLG has been operational since at least December, 2012, when it first began soliciting campaign contributions on its website’s donation page, which contains disclaimer language associated with a federal political action committee, even though VLG has never have been registered as one with the Federal Election Commission.

Less than a week before delegates gather at the Republican Party’s nominating convention in Richmond on May 18 to select their nominees for Governor, Lieutenant Governor, and Attorney General, several questions about the mysterious VLG remain unanswered: Who are its officers, who funds it, and when did it first raise funds with the intent of supporting one candidate and opposing three others in the race for the Republican nomination for Lieutenant Governor of Virginia?

Update: On Monday morning, the donation page was removed from the Virginians for Limited Government webpage. It is currently a nonworking link.