The Architect

In Part I, we met the weapon and the man who first fired it. In Part II, we meet the architect — a woman who spent thirty years learning how to build institutional power that hides its own wiring, and then built exactly that to decide which lawyers get to keep their licenses. Follow her name, and it leads through a five-layer shell, into a Georgetown rowhouse, and onto a tax form she was never supposed to be found on.

Every story about the 65 Project tells you about David Brock. Almost none of them tell you who actually built it.

That is not an accident. It is the first thing you should understand about this entire operation: it was constructed so that the eye would always land somewhere other than its center. Brock is famous. Brock is a lightning rod. Brock sells the headline. And while the cameras pointed at the man everyone already loved to hate, the person who conceived the project, named it, and shaped it sat one tile over on the masthead under the mild, forgettable title of Senior Advisor.

Her name is Melissa Moss. When the news outlet Axios first revealed the 65 Project to the world, it was Moss who was identified as the person who devised it. And then, in nearly every account that followed, she quietly receded — back into the deep background of Washington from which she came. This part is about pulling her back into the light, because you cannot understand what the 65 Project is until you understand who made it and how its money was arranged.

Moss is not a newcomer, an activist, or a volunteer. By the account on the 65 Project’s own website, she is a veteran political strategist with more than three decades in public affairs — and the résumé does not read like a list of jobs. It reads like the blueprint for everything she would later build.

She came to Washington from San Francisco for one reason: to help launch the Democratic Leadership Council. As its first National Field Director, Moss was on the ground floor when Al From founded the DLC in 1985, in the still-smoking crater of Walter Mondale’s 1984 landslide defeat. The DLC’s explicit mission was to drag the Democratic Party back from its post-1960s leftward drift and toward the center — the “New Democrats,” who embraced welfare reform, free trade, tough-on-crime policies, balanced budgets, and market-friendly solutions over big-government liberalism. Bill Clinton chaired the organization in 1990 and 1991. It became the blueprint for his presidency and for the entire Third Way era that followed.

The policy brain behind that centrist reboot was the DLC’s think tank, the Progressive Policy Institute — Clinton’s “idea mill,” the shop that supplied the blueprints and the doctrine. And Moss helped wire the field operation that turned all of it from an idea into a national political machine. This is the part to sit with: she was present at the creation of the most successful institutional re-engineering of a political party in modern American history — an apparatus that layered ideology, fundraising, field operations, and messaging so the party could win without being captured by its own base. She did not observe that machine being built. She helped build it.

From there the résumé reads like a tour of every lever of institutional power. She became Finance Director of the Democratic National Committee — not a fundraiser, the fundraiser, the person responsible for raising the national party’s money and, necessarily, for knowing every legal channel through which political money moves and every structure through which a donor’s name can be kept off the thing it pays for. She served as a political appointee in the Clinton administration at the Department of Commerce’s Office of Public Liaison — the literal bridge between corporate donors and the White House. She did a turn in high finance as a Senior Vice President at Capital Guardian Trust Company, where the daily business is trusts and the conversion of assets into untraceable value. She holds degrees from UCLA and the Kennedy School at Harvard. And she runs her own consulting firm, Moss Advisors.

Hold onto the irony, because it is the spine of this entire series. The left spent decades attacking the DLC machine Moss helped build as too corporate, too opaque, too insulated from the people it claimed to serve — an apparatus that demanded discipline and “responsibility” from everyone while answering to almost no one. Thirty years later, the same builder constructed an accountability machine that runs on precisely the same logic: lofty public demands for integrity, wrapped around a structure engineered to be the opposite of accountable.

There is one credential on that résumé that matters more than all the others, because it is the hinge on which the whole story turns.

Before the 65 Project, Moss founded a nonprofit called Law Works. Read what the 65 Project’s own website says it was for: Law Works was “a bipartisan nonprofit dedicated to supporting and protecting the Mueller Investigation” (the 65 Project, “About Us,” archived March 2022).

Sit with that. The same woman, through the same organization, built her reputation on a nonprofit whose stated purpose was to shield a set of lawyers — the investigators she wished to defend — from political interference. And then she took that exact vehicle, Law Works, and turned it into the umbrella for a campaign whose stated purpose was to destroy a different set of lawyers, by stripping them of their licenses and making them “toxic.” The shield became the sword. The same shell, the same founder, the same machinery — pointed first at protecting lawyers she favored, then at annihilating lawyers she did not.

That is not a coincidence of branding. It is the reuse of infrastructure, which is the single most consistent signature of the world this series documents: you do not build a new machine each time. You build one opaque, respectable-sounding vehicle, and you re-aim it.

Before we trace where the money goes, look at what the 65 Project legally is — because its own federal tax filing answers that question in a way almost no reporting has noted.

On the Franklin Education Forum’s 990, there is a schedule called Schedule R, where an organization must identify its “disregarded entities.” That is a precise tax term, and it matters: a disregarded entity is a company the IRS treats as part of the parent itself — not a separate organization, not a grantee, not an arm’s-length partner, but the parent operating under a different name, sharing the parent’s own tax identification number. And there, listed as a disregarded entity wholly controlled by the Franklin Education Forum, is 65 Project LLC.

Read what that tells you. The 65 Project is not an independent watchdog that happens to receive support from a nonprofit. On its own tax return, it is the Franklin Education Forum — a disregarded LLC sharing the parent’s EIN, with just over $1 million in income for the year. The campaign that publicly demands transparency and accountability from officers of the court files its own existence as a sub-entity of a communications nonprofit, with no separate tax identity of its own.

And note the company it keeps on that schedule. The same Franklin Education Forum operates two other disregarded LLCs under the same roof and the same tax number: BridgeTogether Foundation LLC and Rescue Project for Afghanistan LLC, each with well over a million dollars of its own income. Franklin is not a single-purpose host. It is a multi-shell operator — a parent that spins up disregarded LLCs for whatever the project of the moment happens to be. The 65 Project is simply the one pointed at lawyers.

Note one more thing, because you will see it confirmed again and again: the Project’s own stated purpose, in its own federal filing, is “to deter future abuse of the legal system by lawyers.” Not to adjudicate it. Not to prove it case by case. To deter. The word that defines this entire series is not an inference drawn by critics. It is written on the tax return, under penalty of perjury.

Here is where most readers’ eyes glaze over, because the people who build these structures count on exactly that. So let me make it plain, because the opacity is not a side detail — the opacity is the design.

When you hear “the 65 Project,” you probably picture an organization — an office, a staff, a bank account, tax filings you could look up. It is not that. As its own filing showed us, the 65 Project is a disregarded LLC sharing its parent’s tax number; it has no independent tax identity and discloses no donors of its own. Law Works, the Moss-founded entity publicly described as its umbrella, is just as thin on the public record: no website, no separate filing, no standalone financial disclosure. These are not organizations in the way you picture one. They are activities — lines of work nested inside other entities, by design.

The mechanism that makes this possible is called fiscal sponsorship. An established nonprofit “hosts” a project under its own legal and tax umbrella; the project files no taxes of its own and discloses no donors of its own, because on paper it is simply one activity inside the host. The consequence is the entire point: when a donor funds the 65 Project, the paperwork never says “the 65 Project.” It names the host. The campaign doing the actual work — filing the complaints, running the ads, generating the headlines — never appears on a disclosure at all.

Now watch the money fall through the floors. Read it from the top down:

The chairman of that host nonprofit, the Franklin Education Forum, was David Brock — the same Brock listed as a Senior Advisor to the 65 Project at the bottom of the stack. So the money enters at the top under a respectable, forgettable name no ordinary person would ever connect to bar complaints against election lawyers, and it falls floor by floor to the work at the bottom, where no filing is required at all. Every layer strips away another piece of traceability. By the time it reaches the lawyers being targeted, there is nothing left to follow back up.

If the structure is built to obscure who pays, then the obvious question is the one it was built to prevent you from asking: who pays?

One rail is already documented, and it is a familiar kind of name. Before the 65 Project launched, Law Works drew support routed through Pierre Omidyar’s Democracy Fund — the foundation built by the billionaire founder of eBay, which lists a grant to “LawWorks” in its own public grants database. And the way Omidyar funds things is itself part of the pattern of invisibility we follow in full in Part III: he does not write personal checks that show up with his name on them. His trust contributes enormous blocks of PayPal and eBay stock to his foundations — in a single year, the Democracy Fund received a combined $62.9 million in such shares — the foundation sells the stock, and Omidyar steps back while the institution does the granting. By the time the money reaches a campaign like the 65 Project, the fingerprints are gone. The check, when it lands, bears an institution’s name, not a man’s.

It is the perfect complement to the Moss-Brock layering: tech-fortune money pre-laundered through a foundation, meeting Democratic-institutional money pre-laundered through a fiscal sponsor, both arriving at the work with the original hand wiped clean. We follow Omidyar all the way down in Part III. But there is a closer, stranger piece of the money story — and it sits not at the funding end, but at the receiving end. It leads back to the architect herself, and to a single address.

Pull the Franklin Education Forum’s tax return for the year the 65 Project was born — the fiscal year ending December 2022, filed under federal identification number 46-3009324 (the same entity now operating under the renamed identity Democracy Matters Foundation). Turn to Part VII, the schedule where a nonprofit must list its highest-paid independent contractors. It is one of the few places in this entire structure where money is named in the open, because the IRS form demands it.

There, among the contractors, is a payment of $360,000 for “Strategic Consulting Services.” The recipient is listed as Lyons L.L.C., at 3027 N Street NW, Washington, DC. It is the single highest-paid contractor on the entire return.

That name — Lyons L.L.C. — means nothing to you. It is supposed to mean nothing to you. So pull the second document: the District of Columbia’s corporate registry, the public record every business entity must file to exist. Search the name and read what comes back. The registered agent — the legal owner of record — is Melissa Moss. The address on the filing is the same one printed on the tax form: 3027 N Street NW — a residential rowhouse in Georgetown. A home, not an office tower or a firm’s suite.

Hold the shape of that precisely, because precision is what makes it unanswerable. The money did not flow from Lyons LLC into the Project; Lyons is not a funder. The flow runs the other way. The campaign’s host — Franklin, chaired by Brock — paid $360,000 in consulting fees to a company owned by Melissa Moss, the person who conceived the campaign that host operated. She built the machine, and the machine’s host paid her, through a vehicle bearing a name that connects to her only if you know to pull the registry and look.

And look at who sits directly beneath her on that schedule. The second-highest-paid contractor on the entire return is Teter Legal LLC — $310,370 for “managing consulting services” — the private firm of Michael Teter, the 65 Project’s Managing Director, the man whose signature would land on roughly a hundred of its bar complaints. So the two people who ran the campaign at the top — the architect who designed it and the director who operated it — were not merely paid. They were the number one and number two highest-paid contractors on the books, each through a private LLC, together drawing $670,370. Set that against the roughly $1.07 million the 65 Project LLC reported in income for the year, and the arithmetic is its own headline: well over half of everything the campaign took in went straight back out to the personal companies of the two people running it.

The third name on the list completes the picture of what kind of operation this is. Below the two principals sits the Bonner Group — $240,000 for fundraising — one of the Democratic Party’s best-known professional fundraising firms. An “accountability” campaign that markets itself as a good-government watchdog was, on its own tax return, paying a marquee partisan fundraising shop and routing its two largest checks to its own leaders’ LLCs.

And the address on that top line is not only Moss’s. 3027 N Street NW is the Georgetown home she shares with her husband, Jonathan Silver — himself no stranger to institutional power. Silver ran the Department of Energy’s Loan Programs Office under President Obama, overseeing roughly $70 billion in clean-energy lending (the office at the center of the Solyndra controversy), after a private-sector career that included a managing directorship at the hedge fund Tiger Management. So the single rowhouse from which the 65 Project’s largest consulting vehicle is registered is also the household of a former top federal finance official. To be clear and fair: there is no evidence Silver funded or directed the 65 Project. That is not the claim. The claim is the geometry — how much institutional power sits at one Georgetown address, and how little of it you were ever meant to see.

None of this, by itself, is illegal. Consultants are paid; nonprofits hire firms; principals form LLCs; campaigns use fundraisers. What it is, is the thing the entire public-facing story was built to keep you from seeing: an “accountability” campaign whose own two leaders were its two largest contractors, paid through private vehicles, while the structure around them was arranged so that no donor filing would ever say “the 65 Project” and no casual search would ever connect “Lyons L.L.C.” to the woman who built it. The disclosure was technically present, sitting on page nine of a tax form under a name you had no reason to recognize. That is not transparency. That is compliance engineered to function as concealment.

It would be one thing if this elaborate, self-paying, deliberately untraceable structure had been built to do something modest. It was not. When Axios broke the 65 Project’s existence in March 2022, the scale was already set: the campaign was targeting 111 attorneys across 26 states, with plans to air ads in the battlegrounds — Arizona, Georgia, Michigan, Nevada, Pennsylvania, Wisconsin. The targets included names you know, Rudy Giuliani and Sidney Powell among them, and many you do not: lawyers at small regional firms whose entire livelihood was their license.

The purpose was stated plainly by the people building it. Brock described the goal as filing bar complaints to make the targeted lawyers “toxic in their communities and in their firms.” And a person involved with the project told Axios the deeper aim in a single sentence that should chill anyone who believes in the right to counsel: the complaints mattered “for the deterrent effect that it can bring so that you can kill the pool of available legal talent going forward.”

Read that again. Not win the cases. Not prove the misconduct. Kill the pool. Make sure that the next lawyer who considers taking an election case the campaign disfavors looks at what happened to the last one and declines the call.

And here is the part that, at first glance, looks like failure — until you remember what the campaign said its purpose was. By most public measures, the bar complaints did not produce many disbarments. A great many were dismissed; others ended in lesser outcomes; the marquee disciplinary cases that did succeed against figures like Giuliani ran largely through official bar authorities and, in some states, criminal pleas — not through the 65 Project’s filings. If the goal had been to win cases, the record would read as a string of losses. But the goal, by the campaign’s own words and its own tax return, was never to win cases. It was to deter. And measured against that standard, a low disciplinary count is not failure at all — it is beside the point. The headlines, the ad buys, the public naming, the years of professional limbo for the targeted: those land regardless of how the complaint is ultimately resolved. The process was the punishment. The machine worked exactly as designed, even when it “lost,” and it has continued filing complaints in the years since.

And there was a second objective, hiding in the launch coverage, that this series will return to in full: the 65 Project announced it would push the American Bar Association and every state bar to codify new rules barring certain election challenges — to adopt model language declaring that lawsuits like the ones it opposed violate the ethical duties lawyers must abide by. This is the part most reporting missed entirely. The campaign did not merely intend to use the existing rules of the profession. It intended to rewrite them — to bake its political judgment about which lawsuits are legitimate directly into the code of conduct that governs who may practice law at all. We will follow that effort to its present-day conclusion later in this series.

One honest note, because this series does not overstate its case. The 65 Project dressed itself in bipartisan credibility — its advisory board included a former Republican Homeland Security official and Federalist Society member alongside the Democratic names. That respectable front was real, and it was also the point: it is far easier to run a one-sided campaign when you can display a two-sided board. The architecture underneath the board, as we have now traced it, was anything but bipartisan.

Step back from the detail and look at the shape of it, because the shape is the point.

The woman who helped engineer the Democratic Party’s centrist reboot — an apparatus the left attacked for decades as corporate and unaccountable — spent thirty years mastering how to build institutional power that hides its own wiring. Then she built a campaign that demands transparency and integrity from officers of the court, in the loftiest public language, while operating through the most opaque nonprofit shells money can buy: no filing of its own, no donor disclosure of its own, a founder kept out of the spotlight, its leadership paid through private LLCs registered at a home address, the whole structure layered so that the people who funded it never appear on the same page as the thing they funded.

That brings us back to the question that names this series. Who are they? In Part I, the answer was a method and a man. In Part II, it is an architect — a veteran builder of hidden machines — and the nested shells she designed to keep herself, and the money, out of view.

But we still have not reached the deepest pocket. The same pre-laundered tech-fortune pipeline that seeded Law Works before the 65 Project ever launched is the one we trace in full in Part III — because the deepest pockets stay the cleanest. And it raises the question this series cannot avoid: what does a billionaire with three passports, one of them issued by a nation at war with the United States, have to do with deciding who is allowed to practice law in America?

Part III — The Money Behind the Mask — follows the fortune that funds the machine while keeping its own hands clean.

• The Franklin Education Forum, IRS Form 990 (fiscal year ending December 2022), EIN 46-3009324 — Part VII, Section B (independent contractors) and Schedule R, Part I (disregarded entities). Via ProPublica Nonprofit Explorer: full filing. (The entity now appears under its renamed identity, Democracy Matters Foundation, same EIN.)
• Lyons L.L.C. — registered agent and address of record — District of Columbia Department of Licensing and Consumer Protection, CorpOnline business registry (corponline.dc.gov).
• Lachlan Markay & Jonathan Swan, “Scoop: High-powered group targets Trump lawyers’ livelihoods,” Axios, March 7, 2022 (founding scoop; “make them toxic,” “kill the pool,” 111 attorneys in 26 states, plan to push the ABA and state bars to codify new rules).
• The 65 Project, “About Us” (archived March 2022) — Moss biography; Law Works described as founded to support and protect the Mueller Investigation; David and Nathan Fink listed as Consulting Counsel.
• Democracy Fund grant to “LawWorks,” Democracy Fund public grants database.
• Jonathan Silver, Executive Director, DOE Loan Programs Office — U.S. Department of Energy public records.