NATIONAL CITIZEN COMPLAINT TEMPLATE50 States • District of Columbia • 5 U.S. Territories

THE OUTLAW ARMORY

outlawlivin.com

This is what it is:

Apollo Global Management owns Lifetouch — the company that photographs your children in public schools across the United States. Apollo’s co-founder and former CEO Leon Black paid $158 million to Jeffrey Epstein — a convicted child sex predator and registered sex offender — between 2012 and 2017. Black has been accused of sexual assault by multiple women at Epstein’s properties. He has never been charged.

Schools across the country are canceling Lifetouch contracts. Most states have done nothing. No state authority has independently verified that children’s images are safe.

This is what you wanted:

You wanted someone to do something. You shared the posts. You got angry. Anger without a mechanism is theater.

This is the mechanism.

This document contains a fill-in-the-blank formal complaint letter that works in every U.S. state and territory. Print it. Fill in your name, your state, and the date. Sign it. Mail it certified to your Governor and Attorney General. The addresses for all 56 jurisdictions are in the appendix.

Certified mail costs $4.85. Two letters cost $9.70.

Do you really care?

If your child was photographed by Lifetouch in a public school, and you won’t spend $9.70 to find out whether anyone in your state government has verified those images are safe — stop posting about it. Sit down.

But if you’re still reading — print the letter. Fill it in. Mail it. Their silence after receipt is the evidence.

Be the avalanche.

Page 2: The Letter  •  Page 4: Legal Framework  •  Page 5: All 56 Addresses

[YOUR FULL NAME]

[YOUR STREET ADDRESS]

[CITY, STATE, ZIP]

[DATE]

[RECIPIENT NAME AND TITLE]

[OFFICE ADDRESS]

[CITY, STATE, ZIP]

Re: Formal Citizen Complaint — Request for State Investigation into Apollo Global Management / Lifetouch Ownership Chain and Child Safety

Dear [RECIPIENT TITLE AND NAME],

I am a citizen of [YOUR STATE/TERRITORY]. I am writing to formally request that your office initiate or request an investigation by your state’s investigative agency into the following matter of public concern.

STATEMENT OF FACTS

Apollo Global Management, through its acquisition of Shutterfly, Inc. in September 2019, owns Lifetouch — the national leader in school photography. Lifetouch photographs millions of children in public schools across the United States, including in this state.

Apollo’s co-founder and former CEO, Leon Black, paid approximately $158 million to Jeffrey Epstein between 2012 and 2017. These payments were made while Epstein was a registered sex offender following his 2008 conviction for procuring a minor for prostitution. Black resigned as CEO of Apollo in 2021 following public disclosure of these payments. Multiple women have accused Black of sexual assault at properties associated with Epstein. He has never been charged.

Schools in multiple states have suspended or canceled contracts with Lifetouch in response to these disclosures. To my knowledge, no authority in this state has taken similar action or initiated any independent investigation.

Nationally, over 350,000 children are reported missing each year. The numbers have trended upward. To my knowledge, no state authority has cross-referenced Lifetouch contract school data with missing children data in this state.

LEGAL AUTHORITY

Every state attorney general serves as the chief legal officer and is empowered to initiate investigations into matters of public concern, particularly those involving the safety of children. Every state governor has the authority to request or direct state law enforcement agencies to investigate credible concerns.

Federal immunity granted under the 2007 Non-Prosecution Agreement in the Epstein matter does not bar state prosecution. Gamble v. United States, 587 U.S. 678 (2019), confirmed the separate sovereigns doctrine: a state may prosecute conduct independently of any federal decision. The majority of states have no statute of limitations on felony sexual offenses against children.

FORMAL REQUEST FOR INVESTIGATION

I respectfully and formally request that your office initiate an investigation with a scope sufficient to answer the following questions. These questions cannot be answered by Lifetouch press releases or Apollo internal reviews. They require examination of federal records, including the DOJ Epstein files, flight logs, financial records, and victim depositions.

1. Did any Epstein-associated individual — including but not limited to Leon Black, Ghislaine Maxwell, or any co-conspirator identified in the federal indictment — have direct or indirect access to Lifetouch systems, databases, or image archives at any time?

2. Do the Epstein flight logs, financial records, or communications released by the DOJ reference any locations, residents, or minors in this state?

3. Were any of the identified victims in the federal indictment residents of this state or enrolled in this state’s public schools at any time?

4. Did Leon Black or any entity controlled by or associated with Black access, request, or receive any data — including images, names, addresses, school enrollment records, or scheduling information — from Lifetouch or Shutterfly at any time?

5. What due diligence was performed by this state before permitting a company owned by an entity whose founder maintained a $158 million financial relationship with a convicted child sex predator to photograph minor children in public schools?

6. Has any state authority cross-referenced Lifetouch contract school data with this state’s missing children data? If not, I request that this cross-reference be performed and the results made public.

Questions 1 through 4 require access to federal records. If your office determines that federal cooperation or subpoena power is necessary, I request that your office exercise every available mechanism to obtain those records.

A refusal to pursue answers to these questions — when the authority exists and the concern has been documented — is itself evidence of willful failure to discharge the duties of office.

NOTICE OF OBLIGATION

This letter constitutes formal notice of articulable concern. The constitutional oath of office creates a fiduciary obligation to the People. Every state imposes criminal penalties for willful failure of a public officer to discharge the duties of office. Every bonded officer is liable under the terms of the official bond for neglect or misconduct.

I request written acknowledgment of receipt and a written response indicating what action your office intends to take.

Respectfully submitted,

_____________________________________________

[YOUR PRINTED NAME]

[CITY, STATE]

Citizen of the United States

Sent via USPS Certified Mail, Return Receipt Requested

Tracking Number: [TRACKING NUMBER]

LEGAL FRAMEWORK — WHY THIS WORKS IN EVERY STATE

SEPARATE SOVEREIGNS DOCTRINE

Gamble v. United States, 587 U.S. 678 (2019): The Supreme Court held that the federal government and state governments are separate sovereigns. A federal decision not to prosecute does not bar a state from prosecuting the same conduct. The Epstein Non-Prosecution Agreement was a federal agreement. It does not immunize anyone from state charges.

STATUTE OF LIMITATIONS

The majority of U.S. states have no statute of limitations on felony sexual offenses against children. For states that do impose a limit, many have extended or eliminated those limits in recent years. Check your state’s specific statute, but in most jurisdictions, these offenses can be prosecuted at any time.

ATTORNEY GENERAL AUTHORITY

In 47 of 50 states, the attorney general has the power to initiate criminal investigation or prosecution. In the remaining three (Connecticut, North Carolina, Arkansas), the AG’s authority is more limited but the Governor can direct state investigative agencies. In every state, the Governor has authority to request state law enforcement investigations.

OFFICIAL MISCONDUCT / DERELICTION OF DUTY

Every state has a criminal statute penalizing willful failure of a public officer to discharge the duties of office. The specific statute number varies by state, but the principle is universal: an officer who willfully neglects or refuses to perform a duty required by law is subject to criminal penalty, removal from office, or both.

OFFICIAL BONDS

Most states require bonded officers to faithfully perform the duties of office. The bond is a surety guarantee. Misconduct or neglect breaches the bond. In many states, any person injured by the officer’s failure may institute suit against the officer and the sureties.

THE OATH

Article VI, Clause 3 of the United States Constitution requires all state officers to be bound by oath to support the Constitution. This oath creates a fiduciary obligation. An officer who fails to investigate a credible concern involving the safety of children — after formal notice — has breached that obligation.

For the full constitutional analysis of the oath, bond, and fiduciary obligation framework, visit:

outlawlivin.com

APPENDIX: ATTORNEY GENERAL & GOVERNOR — ALL 56 U.S. JURISDICTIONS

Verify current officeholders at usa.gov/state-attorney-general and usa.gov/state-governor before mailing.

JURISDICTION	ATTORNEY GENERAL	AG MAILING ADDRESS	GOVERNOR
Alabama	Steve Marshall	501 Washington Ave., Montgomery, AL 36104	Kay Ivey
Alaska	Stephen Cox	1031 W. 4th Ave., Suite 200, Anchorage, AK 99501	Mike Dunleavy
Arizona	Kris Mayes	2005 N. Central Ave., Phoenix, AZ 85004	Katie Hobbs
Arkansas	Tim Griffin	323 Center St., Suite 200, Little Rock, AR 72201	Sarah Huckabee Sanders
California	Rob Bonta	P.O. Box 944255, Sacramento, CA 94244-2550	Gavin Newsom
Colorado	Philip Weiser	1300 Broadway, 10th Floor, Denver, CO 80203	Jared Polis
Connecticut	William Tong	165 Capitol Ave., Hartford, CT 06106	Ned Lamont
Delaware	Kathy Jennings	820 N. French St., Wilmington, DE 19801	Matt Meyer
Florida	James Uthmeier	The Capitol, PL-01, Tallahassee, FL 32399	Ron DeSantis
Georgia	Chris Carr	40 Capitol Square SW, Atlanta, GA 30334	Brian Kemp
Hawaii	Anne E. Lopez	425 Queen St., Honolulu, HI 96813	Josh Green
Idaho	Raúl Labrador	700 W. Jefferson St., Suite 210, Boise, ID 83720	Brad Little
Illinois	Kwame Raoul	115 S. LaSalle St., Chicago, IL 60603	JB Pritzker
Indiana	Todd Rokita	302 W. Washington St., 5th Floor, Indianapolis, IN 46204	Mike Braun
Iowa	Brenna Bird	1305 E. Walnut St., Des Moines, IA 50319	Kim Reynolds
Kansas	Kris Kobach	120 SW 10th Ave., 2nd Floor, Topeka, KS 66612	Laura Kelly
Kentucky	Russell Coleman	700 Capital Ave., Suite 118, Frankfort, KY 40601	Andy Beshear
Louisiana	Liz Murrill	P.O. Box 94005, Baton Rouge, LA 70804	Jeff Landry
Maine	Aaron Frey	6 State House Station, Augusta, ME 04333	Janet Mills
Maryland	Anthony Brown	200 St. Paul Place, Baltimore, MD 21202	Wes Moore
Massachusetts	Andrea Joy Campbell	One Ashburton Place, Boston, MA 02108	Maura Healey
Michigan	Dana Nessel	525 W. Ottawa St., Lansing, MI 48933	Gretchen Whitmer
Minnesota	Keith Ellison	445 Minnesota St., Suite 1400, St. Paul, MN 55101	Tim Walz
Mississippi	Lynn Fitch	P.O. Box 220, Jackson, MS 39205	Tate Reeves
Missouri	Catherine Hanaway	207 W. High St., Jefferson City, MO 65101	Mike Kehoe
Montana	Austin Knudsen	215 N. Sanders, Helena, MT 59601	Greg Gianforte
Nebraska	Mike Hilgers	2115 State Capitol, P.O. Box 98920, Lincoln, NE 68509	Jim Pillen
Nevada	Aaron Ford	100 N. Carson St., Carson City, NV 89701	Joe Lombardo
New Hampshire	John Formella	33 Capitol St., Concord, NH 03301	Kelly Ayotte
New Jersey	Jen Davenport	25 Market St., Trenton, NJ 08625	Mikie Sherrill
New Mexico	Raúl Torrez	408 Galisteo St., Santa Fe, NM 87501	Michelle Lujan Grisham
New York	Letitia James	The Capitol, Albany, NY 12224	Kathy Hochul
North Carolina	Jeff Jackson	9001 Mail Service Center, Raleigh, NC 27699-9001	Josh Stein
North Dakota	Drew Wrigley	600 E. Boulevard Ave., Dept. 125, Bismarck, ND 58505	Kelly Armstrong
Ohio	Dave Yost	30 E. Broad St., 14th Floor, Columbus, OH 43215	Mike DeWine
Oklahoma	Gentner Drummond	313 NE 21st St., Oklahoma City, OK 73105	Kevin Stitt
Oregon	Dan Rayfield	1162 Court St. NE, Salem, OR 97301	Tina Kotek
Pennsylvania	Dave Sunday	16th Floor, Strawberry Square, Harrisburg, PA 17120	Josh Shapiro
Rhode Island	Peter Neronha	150 S. Main St., Providence, RI 02903	Dan McKee
South Carolina	Alan Wilson	P.O. Box 11549, Columbia, SC 29211	Henry McMaster
South Dakota	Marty Jackley	1302 E. Hwy 14, Suite 1, Pierre, SD 57501	Larry Rhoden
Tennessee	Jonathan Skrmetti	P.O. Box 20207, Nashville, TN 37202	Bill Lee
Texas	Ken Paxton	P.O. Box 12548, Austin, TX 78711	Greg Abbott
Utah	Derek Brown	350 N. State St., Suite 230, Salt Lake City, UT 84114	Spencer Cox
Vermont	Charity Clark	109 State St., Montpelier, VT 05609	Phil Scott
Virginia	Jay Jones	202 N. 9th St., Richmond, VA 23219	Abigail Spanberger
Washington	Nick Brown	P.O. Box 40100, Olympia, WA 98504	Bob Ferguson
West Virginia	JB McCuskey	State Capitol, Bldg. 1, Room E-26, Charleston, WV 25305	Patrick Morrisey
Wisconsin	Josh Kaul	P.O. Box 7857, Madison, WI 53707	Tony Evers
Wyoming	Keith Kautz	109 State Capitol, Cheyenne, WY 82002	Mark Gordon
District of Columbia	Brian Schwalb	400 6th St. NW, Washington, DC 20001	Muriel Bowser (Mayor)
Puerto Rico	Domingo Emanuelli Hernández (Secretary of Justice)	P.O. Box 9020192, San Juan, PR 00902	Jenniffer González-Colón
U.S. Virgin Islands	Ariel Smith (Acting)	34-38 Kronprindsens Gade, Charlotte Amalie, St. Thomas, VI 00802	Albert Bryan Jr.
Guam	Douglas Moylan	590 S. Marine Corps Dr., Suite 706, Tamuning, GU 96913	Lourdes Leon Guerrero
American Samoa	Fainu’ulelei Falefatu Alailima-Utu	P.O. Box 7, Pago Pago, AS 96799	Lemanu Peleti Mauga
Northern Mariana Islands	Edward Manibusan	Caller Box 10007, Saipan, MP 96950	Arnold Palacios

HOW TO SEND CERTIFIED MAIL

1. Print two copies of the letter (one for your Attorney General, one for your Governor). Fill in each with the correct recipient from this appendix.

2. Sign each letter in ink.

3. Go to your local Post Office. Ask for Certified Mail with Return Receipt (green card).

4. Cost: approximately $4.85 per letter. Two letters = approximately $9.70.

5. Keep your certified mail receipts. Photograph them. These are your proof of delivery.

6. When the green return receipt cards come back signed, photograph those too.

7. If you do not receive a written response within 30 days, that silence is documentable evidence.

SHARE THIS DOCUMENT. Download it. Print it. Hand it to every parent you know.

One letter is a crank. A thousand is a mandate.

DISCLAIMER

This document is provided for informational and civic engagement purposes only. It does not constitute legal advice. The author is not an attorney and is not providing legal representation or counsel. No attorney-client relationship is created by the use of this document. Citizens are encouraged to consult with a licensed attorney in their jurisdiction before taking legal action. The information contained herein is based on publicly available records, publicly reported facts, and publicly accessible statutes. Every effort has been made to ensure accuracy, but laws and officeholders change. Verify all names, addresses, and statutes before mailing. Use of this template is at your own discretion and risk.

THE OUTLAW ARMORY  •  outlawlivin.com

Document. File. Ask questions. Record the silence. Vote.