The Same Signature
The Same Door, Part 2 — the deep file. *A ten-part investigation into how foreign governments and America's largest foster-care Medicaid contractor buy influence through the same Washington firms. The series overview stated this part's finding in a page; this is the documentary record behind it, published so that any reader can pull the same files and check.
By "buy influence," this series refers to lawful paid lobbying and advocacy intended to influence public policy; it does not allege bribery, corruption, or any unlawful exchange.
What this part does not show
This article does not allege that any person, firm, company, or foreign principal named here violated any law. It examines publicly disclosed lobbying registrations, FARA filings, and other government records.
No Chinese principal appears in the records discussed in this part. The CUSEF thread of this series runs through different firms (Parts 4–6) and is not attributed to the people or engagements examined here.
We found no evidence in the records reviewed for this article that funds moved between Centene and any foreign principal discussed here. The two sets of records described below share personnel, not documented transfers of funds.
We found no evidence in the records reviewed for this article that any foreign principal knew of, directed, coordinated with, or benefited from the Centene work described here, or vice versa. The filings establish overlapping professional relationships, not coordination.
And the null we went hunting for: our review of FEC processed Schedule A records found no itemized contributions to Centene's corporate PAC from contributors listing Brownstein as their employer, 2022–2026 cycles. Later in this piece we take that null one layer deeper.
Start with the letter
On November 9, 2020, a two-and-a-half-page engagement letter went out on Brownstein Hyatt Farber Schreck letterhead, addressed to Ambassador Motaz Zahran of Egypt at 3521 International Court NW, Washington. The Justice Department has a copy — the firm filed it that same night, at 11:24 PM, as the exhibit to a new foreign-agent registration. Because it sits in a public docket, we can quote it exactly, and its five most important sentences are worth reading the way a filing clerk never will:
*"The Firm will represent the Ambassador and the Embassy."* The client is Egypt's ministry of foreign affairs, through its embassy.
*"It is anticipated that Nadeam Elshami and I will supervise work on this account."* The "I" is the letter's signer — Edward Royce, then the firm's policy director and previously chairman of the House Foreign Affairs Committee. The other named supervisor, Elshami, was previously chief of staff to the Speaker of the House.
*"Our monthly retainer fee for this matter will be $65,000, inclusive of all charges and expenses."*
*"The Embassy will be invoiced for this retainer quarterly in advance and no work will begin until the invoice has been paid."*
The firm's senior team, the letter adds, *"will travel to Egypt at least once a year,"* working to Terms of Reference supplied by Cairo.
Now the date again: November 9, 2020. On that one day, four documents entered the Justice Department's system. The firm registered Egypt's Ministry of Foreign Affairs as a foreign principal. It filed the engagement letter above. Nadeam Elshami filed his personal short-form registration statement naming Egypt. Under FARA, partners, officers, directors, associates, employees, and agents of a registrant who act in furtherance of a foreign principal's interests are required to file short-form registration statements, except personnel engaged solely in clerical, administrative, or similar duties. And a second Brownstein lobbyist filed his own short-form adding Egypt to a foreign client list he had been building since 2016: Alfred Mottur.
Hold those two names. At the moment they signed those forms, both men were also registered lobbyists for Centene Corporation — which describes itself as the largest Medicaid managed care organization in the United States and, through its Texas subsidiary Superior HealthPlan, serves as the single MCO for Texas STAR Health, the program providing coordinated healthcare services for children in foster care and kinship care. Elshami had been on the Centene account since its first filing; Mottur since its second. Neither stopped. That is the finding of this part, and the rest of it is the paperwork.
Two statutes that have never met
To see why this pattern is invisible in the ordinary course, you need the mechanics — thirty seconds of statute, no more.
The Foreign Agents Registration Act is a 1938 law administered by the Justice Department. A firm representing a foreign government registers once, then files: an exhibit attaching each engagement contract, a supplemental statement every six months itemizing fees received and contacts made, and short-form registration statements from individuals required to file them under FARA. Item 10 of the short-form makes the individual name their foreign principal in their own filing.
The Lobbying Disclosure Act is a 1995 law administered by Congress. A firm lobbying for a domestic client registers with the Senate and House and files quarterly: income, issues, and the names of the individual lobbyists on the account, with each new name disclosing their prior "covered positions" in government.
Two filing systems, two branches of government, two document formats — and the filings reviewed here do not cross-reference an individual's disclosures in the other system. A firm can appear in both all day, lawfully. So can a person. The only way to know is to pull both dockets and lay them side by side, which is what this investigation did, preserving every document. What follows is the two ledgers, then the names on both.
Ledger one: thirty-two filings for Centene
Brownstein registered Centene as a lobbying client in the first quarter of 2019 — the registration names a single lobbyist, Nadeam Elshami. From that filing through the second quarter of 2026 the engagement runs 32 consecutive filings (one registration, thirty quarterly reports, one amendment), with no termination on file. We retrieved all 32 and recomputed the total under the disclosure system's own convention that an amendment supersedes its original: $2,110,000 over thirty quarters.
The fee curve is almost featureless — $60,000 a quarter through 2019–2020, $70,000 for one quarter, then $80,000 through 2024, back to $60,000 since 2025. Never a spike, never a gap, never a termination. Nineteen different lobbyists have cycled through the account; the current roster is eight names.
The subject matter, from the most recent filing, in the filing's own words: *"Issues related to ACA, Medicare Advantage, and Medicaid; Issues related to Artificial Intelligence in healthcare; P.L. 119-21 (H.R. 1): One Big Beautiful Bill implementation; Healthcare premium tax credits; Pharmacy contracts for long term care (LTC)."* One quarter earlier the list also carried a line the aggregate story shouldn't lose: *"General mental health policy."* Medicaid — which provides health coverage to many children and youth in foster care — appears in every recent quarter.
Ledger two: the foreign book, now with every fee on the page
Registration #5870 — opened June 16, 2008 — carries ten active foreign principals as of our August 1 pull: Saudi Arabia's Ministry of Foreign Affairs (since September 22, 2016), Saudi Arabia's Public Investment Fund (since June 22, 2023), King Abdullah University of Science and Technology, Egypt's Ministry of Foreign Affairs (since November 9, 2020), the governments of Iceland and Mozambique, two South Korean principals, Morocco's embassy, and a Turkmen pipeline company. Twenty-two more have come and gone since 2008.
FARA, unlike the lobbying statute, discloses the contracts themselves. With the Egypt letter now in hand, the fee schedule reads — every figure from an exhibit or supplemental statement in the Justice Department's docket:
Two receipts anchor the rates to real money: Egypt's 2023 supplemental statement records $181,232 received in a single July entry, and the most recent six-month statement shows $4,428,465.45 received across all principals — the Saudi account alone, $1,796,995.53. And the Egypt engagement is not historical: the renewal exhibit the firm filed on October 27, 2025 states, in its own words, that the work *"remains active and has not changed in scope or retainer."*
Now the arithmetic the two ledgers never perform together. Centene pays $60,000 a quarter. Egypt pays $65,000 a month. On the firm's own filed numbers, a single month of Egypt's retainer outearns a full quarter of Centene's — and Saudi Arabia's foreign ministry pays twice Egypt again. Six months of receipts reported across the foreign principals exceed everything Centene has paid in seven and a half years. Neither number is secret. They have simply never appeared on the same page, because no page exists for them to share.
The four names, from their own forms
Union the last four quarters of Centene filings: nine lobbyists. Pull #5870's active short-form roster: thirty-three names. Cross them, and four of the nine are simultaneously active registered foreign agents. We did not take the cross-match on faith — we pulled each person's short-form PDF and read Item 10, where the registrant names their principal in their own filing:
All four name Saudi Arabia's Public Investment Fund. Sullivan's and Hancock's forms describe *"education and advocacy before the U.S. federal government involving Public Investment Fund transactions."* The forms identify their compensation as salary and state that it is "not based solely on services rendered to the foreign principal(s)." That language describes the compensation reported on the forms; it does not establish whether an employee may accept or decline a particular client assignment.
The pedigree line, because it tells you what kind of team this is: Sullivan's own covered-position disclosure reads *"Staff Director, Senate Finance Committee; Chief Counsel, Senate Finance Committee"* — fourteen years at the committee with jurisdiction over Medicaid, the subject of Part 3. Hancock's reads counsel roles in a Senate office; Usyk's, staff history in two more. The foreign bench is senior too: the 33 active short-forms include a former U.S. Senator from Arkansas, a former U.S. Senator from Alaska, and the former House Foreign Affairs chairman whose signature opens this article.
Elshami is the longest thread. He is the only name on all 32 Centene filings — sole lobbyist on the registration itself — and he has held the Egypt registration continuously since the day the account opened, the same day the engagement letter named him its co-supervisor. Roughly five and a half years, and counting, in which one person has been simultaneously a registered agent of a foreign government and a registered lobbyist for Centene, which says it serves more children involved in the child-welfare and foster-care system than any other Medicaid managed care organization in the nation. Both registrations are active today. Both appear in separate federal disclosure systems that do not present those relationships together in the filings reviewed here.
The first man through the door: Mottur's nine principals
We reviewed all thirteen of Alfred Mottur's short-form filings, from 2008 through 2024, and his file provides an earlier example of the overlap this series documents.
September 22, 2016: the firm registers Saudi Arabia's Ministry of Foreign Affairs; Mottur files his short-form for Saudi Arabia *the same day*. Then, filing by filing, his own Item 10s accumulate: Iraq's embassy (2017). India (2018). Cambodia (2019). Egypt — November 9, 2020, the same day as Elshami, in the same midnight batch. South Korea's embassy (2021).
Across that run, from the second quarter of 2019 to the second quarter of 2023, Mottur also appears on 18 consecutive Brownstein quarterly filings for Centene. Four years in which one lobbyist was registered, at various moments, for as many as four foreign governments and one Medicaid company at once — every registration disclosed, every one lawful, no system anywhere displaying them together.
His Centene work ended in mid-2023, His later FARA filings include: a Public Investment Fund short-form filed June 22, 2023 — eight days before his final Centene quarter closed on June 30. Then Bahrain (January 2024). Then NEOM, the Saudi megacity company (March 2024). We print those dates as dates; the record establishes sequence, not cause, and we claim nothing more. (One precision note, because accuracy is house style: a second Mottur — Thomas Robb Mottur — also filed under this registration in 2022. He is a different person, and no statement in this article includes him.)
Elshami is therefore not the first Centene lobbyist in the records reviewed here to appear in both disclosure systems. Mottur appeared on Centene lobbying filings while also holding FARA short-form registrations during an earlier period; Elshami appears in both systems during a later overlapping period.
The one who never signed
The dual registrants are the finding; the non-registrants are the control group, and one of them matters most.
Emily Felder has appeared on 29 of the 32 Centene filings — second only to Elshami — and on the current roster. Her covered-position disclosure, in her own filing's words: *"Director of the Office of Legislation, CMS; Counsel, House Energy and Commerce Committee; Counsel, Senate Committee on Homeland Security and Government Affairs; Counsel, House Oversight and Government Reform Committee."* The Office of Legislation is the unit of the federal Medicaid agency that manages its relationship with Congress. The person who once directed how CMS communicates with Congress later became a lobbyist for Centene, which describes itself as the largest Medicaid managed care organization in the United States.
Our review of Brownstein's active and terminated short-form rosters under registration #5870 found no FARA short-form for Felder, Steinmetz, Tarazi, Mish, or Iovino. We did not stop at the active list; we pulled the terminated roster too, all 53 records, to make the negative real. The Centene account, in other words, is not uniformly dual-hatted — it is staffed by both kinds of lobbyist, and nothing in either statute would tell a client, a legislator, or a state Medicaid agency which kind they were talking to.
The money that isn't there
One more null, taken a layer deeper than the series overview stated it.
Our review of FEC processed Schedule A records found no itemized contributions to Centene Corporation PAC from contributors listing Brownstein Hyatt Farber Schreck or BHFS as their employer across the 2022, 2024, and partial 2026 cycles. The original search was independently re-verified on August 16, 2026. FEC employer information is self-reported. We then checked the firm's own PAC (BHFS-E, PC PAC, FEC committee C00390583) against the federal enforcement record: no FEC enforcement matter names the firm or its PAC as respondent (FEC legal database, searched August 2, 2026). Our search found no FEC enforcement matter naming the firm or its PAC as a respondent. The system is cleaner than a cynic would guess — which is precisely why the structure itself, not any actor in it, is the story.
Legal, disclosed — and structurally invisible
FARA and the LDA are separate federal disclosure regimes with different purposes and reporting requirements. This article does not allege that appearing in both systems is unlawful or that any individual named here violated either statute.
The paragraph no one is obligated to write is the one this series exists for. A Senate staffer reading a Medicaid position paper has no flag telling her its author is a registered agent of a foreign sovereign wealth fund. A state Medicaid director scoring a managed-care bid has no line on any form asking whether the winning bidder's Washington team also serves foreign ministries. The Justice Department maintains the FARA records examined here, while Congress maintains the LDA records. Four members of the recent Centene roster examined in this investigation appear in both systems, and Mottur appeared in both during an earlier period. The filings do not present those relationships together; identifying the overlap requires comparing the separate records.
And the reason it belongs in a child-welfare series has not changed: the domestic half of this ledger is Medicaid — named on every recent filing — and the client is the company whose Texas subsidiary, Superior HealthPlan, serves as the single MCO for Texas STAR Health, the foster-care healthcare program. The population on the other end of the Medicaid line has the least capacity of any constituency in America to watch the watchers. So the watching falls to the public record — which, as this part has shown, watches in two rooms that share no door.
What you can do with these records
Everything in this article came from public files you can open tonight, without an account, a subscription, or a records request. The civic action for this part is verification itself:
1. Pull the foreign ledger. At efile.fara.gov (Justice Department FARA eFile), search registrant 5870. Open the Exhibit A/B filings — the contracts, including the November 9, 2020 Egypt engagement letter quoted above (efile.fara.gov/docs/5870-Exhibit-AB-20201109-17.pdf) — and any individual's short-form to see the principal named in Item 10 (Elshami's: efile.fara.gov/docs/5870-Short-Form-20201109-132.pdf).
2. Pull the domestic ledger. At lda.gov (the Senate/House Lobbying Disclosure system), search client "Centene," registrant "Brownstein." The most recent quarterly filing, with roster and covered positions: lda.gov/filings/public/filing/3a48b3d5-8dca-4ae8-9d35-6c5a6ca7048c/print/.
3. Do the comparison no system does. Any name on the lobbying filing can be checked against the FARA short-form roster in under a minute. If you find a change — a termination, a new principal, a new name — the record has moved, and we want to know: tips@projectmilkcarton.org.
4. Ask for the missing door. If you believe the two disclosure systems should reference each other, that is a question for your own representative and senators — find them at house.gov/representatives/find-your-representative and senate.gov/senators/senators-contact.htm. Educating officials about how existing disclosure law performs is exactly what these records are public for.
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Sources & Methods
Every figure traces to a primary source retrieved and preserved in case file SSI-2026-0018: the Justice Department FARA eFile docket for registration #5870 — active and terminated principal rosters; active (33) and terminated (53) short-form rosters; the 2020 Egypt Exhibit A/B containing the engagement letter and the 2025 renewal exhibit (retrieved August 2, 2026); the Saudi 2016/2018 exhibits, PIF 2023/2025 exhibits, KAUST and NEOM exhibits; supplemental statements through March 2026; and all thirteen Alfred Mottur short-forms 2008–2024 plus the four current dual registrants' short-forms (retrieved August 1–2, 2026) — and the Senate Lobbying Disclosure database for the complete 32-filing Brownstein–Centene set, income recomputed under the amendment-superseded convention, with Felder's covered-position text from the filings themselves. The Centene-PAC null was originally computed from FEC data and independently re-verified on August 16, 2026, using FEC processed Schedule A data for Centene Corporation PAC (C00397851), across the 2022, 2024, and partial 2026 cycles. The search returned no itemized contributions from contributors listing Brownstein Hyatt Farber Schreck or BHFS as their employer. FEC employer fields are self-reported. The enforcement search against the FEC legal database for BHFS-E, PC PAC (C00390583) was conducted August 2, 2026. Verification materials are preserved in case file SSI-2026-0018.
Project Milk Carton is a 501(c)(3) transparency organization. This series reports on systems, not candidates; it takes no position on any election, candidate, or party. This article does not allege unlawful conduct. It reports disclosed relationships and activities reflected in the sources described above.

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