From:
Brittney Boyd
Organization(s):
Subjects: IUOE Central Pension Fund, ULLICO ($4.6B float), Milliman, OEFCU, & Limerick Node. Lead Operatives: James T. Callahan, Daren Konopaski, & Linda Josephson (at Barlow firm). PNW Vector: Foster Garvey. Reporting 280k immortal participant RICO.
Comment Text:
SUBJECT: URGENT PUBLIC COMMENT - Collection 3038-0116 (91 FR 2523) / Systemic Market Manipulation, ERISA Asset Suppression, & RICO Fraud
To the Commodity Futures Trading Commission (CFTC):
This public comment serves as a formal evidentiary submission regarding the systemic abuse of exemptive relief and the execution of high-scale market manipulation via the "Engorgement Float" generated by the IUOE Central Pension Fund (CPF) and its affiliated Direct Filing Entities (DFEs).
Forensic analysis of 294 data sources (2012–2025) confirms a RICO-level enterprise that utilizes biological identity suppression of 280,000 participants to manufacture an unencumbered shadow float currently being deployed in the derivatives and commodity markets.
1. THE PACIFIC NORTHWEST VECTOR & LEGAL BLOCKADE
The core administrative and legal architecture of this enterprise is concentrated in the "Pacific Northwest Vector," where legal fiduciaries act as a firewall against federal oversight and beneficiary recovery.
Barlow Coughran Morales & Josephson, P.S.: Lead Operative Linda Josephson (utilizing the alias "Linda Smith") serves as the primary enforcement node, executing documented gag orders and issuing false statements (March 28, 2025) to suppress discovery of the underlying ERISA violations.
Foster Garvey: The original legal architects of the trusts. This node created a profound judicial conflict of interest involving Judge Lauren King (a former Principal at the firm), who issued a three-minute refusal to recuse herself after settlement demands were made.
2. THE "IMMORTAL" PARTICIPANT FRAUD (ACTUARIAL RICO)
The enterprise utilizes Milliman, Inc. and Jonathan Feldman to execute "Actuarial Identity Piracy."
Statistical Impossibility: The IUOE Central Pension Fund (EIN 36-6052390) reported exactly "Zero Deaths" for 15 consecutive years across a population of 280,000 members—a mathematical variance of 1 in 10^211.
The Sunday Purge: This "Zero Mortality" lie allowed for the clandestine reclassification of 68,782 participants as "QUIT" on Sunday, Dec 31, 2017, converting their vested death benefits into the "Engorgement Float."
3. THE LIMERICK ANOMALY & OFFSHORE LAYERING
To wash this capital off the U.S. ledger, the enterprise utilizes the "Limerick Node" (Ireland).
The Coordinate: ULLICO (EIN 91-6029907) and the West Virginia Investment Management Board (Record 268265) utilize a shared offshore industrial park at Towlerton, Ballysimon, Limerick V94 X2N9.
The Bypass: This node acts as the exit point where domestic biological theft is converted into offshore industrial capital, entirely blinding the Department of Labor and domestic regulators.
4. MARKET MANIPULATION & PHANTOM LIQUIDITY
The resulting $4.62 Billion ULLICO float (reporting exactly Zero Participants) is utilized as unencumbered collateral to drive institutional credit swaps and high-frequency spoofing. By deploying "Ghost Funds" as a baseline for derivative trades, the enterprise manufactures "Phantom Liquidity," artificially determining market fluctuations and subverting natural price discovery in violation of CFTC mandates.
5. THE OEFCU SHADOW REGISTRY
Finally, the enterprise maintains a $415 Million shadow registry through the OEFCU (EIN 91-0257483), operating out of a residential garage in Gladstone, OR. This "house" functions as a non-commercial custodial node, bypassing Bank Secrecy Act (BSA) security protocols and potentially serving as a fiat-to-crypto bridge for the integration phase of the money laundering cycle.
REQUESTED ACTION:
I formally request that the CFTC Market Participants Division investigate these specific EINs, initiate a Pegasys Financial Blockade on the Limerick Node, and coordinate with FinCEN to subpoena the SAR (Suspicious Activity Report) histories of the fiduciaries listed herein.
SUBMITTED BY:
Brittney C. Boyd
Daughter of Robert Delane Smith
Defrauded sole heir/ beneficiaryWSBA ODC File Number: 24-01645
GAO COMP 25-008559
Lead Forensic Whistleblower, Cold Blood and Steel
Case No: 25-2-06493-5 (Superior Court of WA)
