Highway 31, the shell independent expenditure organization used by Washington, D.C based consulting firms run by Obama campaigners in the Alabama U.S. Senate race, dropped another $57,369 into the bucket on Monday for a direct mail hit piece targeting conservative Republican candidate Roy Moore.

Total spending by the shell organization since it was formed on November 6 now exceeds $2.9 million.

The special election between Moore and liberal Democrat Doug Jones to select a successor to former Senator Jeff Sessions (R-AL), now President Trump’s Attorney General, will be held next Tuesday, December 12.

An estimated $2.7 million of the $2.9 million in advertising conducted by Highway 31 to attack Roy Moore has been provided on credit by three secretive Washington, D.C. consulting firms founded by former Obama staffers: Bully Pulpit Interactive, which specializes in online advertising; Waterfront Strategies, a wholly owned subsidiary of GMMB Consulting, which specializes in television and radio media buys and production; and Putnam Partners, which specializes in media production.

GMMB Consulting, the parent company of Waterfront Strategies, was founded and is still run by former Obama campaign staffer Jim Margolis.

Bully Pulpit Interactive was founded and is still run by former Obama campaign official Andrew Bleeker.

Putnam Partners was founded and is still run by former Obama campaign staffer Mark Putnam.

According to the shell organization’s last financial status report filed with the FEC on November 30, the group has no cash and no assets. As of November 22, it owed three secretive Washington, D.C. consulting firms founded by former Obama campaign staffers more than $1 million for services they provided entirely on credit.

With today’s news, that debt has now likely grown to $2.9 million, which means it is either an in-kind contribution from the firms run by the former Obama campaign staffers, or has been funded by some other unknown liberals, almost certainly not based in Alabama.

Under current FEC rules, Highway 31 claims that it is under no obligation to report the names of those donors prior to next Tuesday’s election between liberal Democrat Doug Jones and conservative Republican Roy Moore.

Indeed, the names of Highway 31 donors–if there are any–currently will not be reported to the FEC until January 21, more than a month after next Tuesday’s election.

A number of critics on both sides of the political aisle believe that Highway 31’s concealment of its donors prior to the hotly contested election violates the spirit, if not the letter, of federal election law, as Breitbart News reported:

“Yes, this appears to be legal. FEC regulations concerning debt are fairly straightforward: political committees are allowed to have debt as long as they report the amount of debt to the FEC. The regulations do not address the situation of taking on debt when a committee has no assets or donors, ” Tyler Cole, Legislative Director & Policy Counsel at Issue One, a non-profit whose “goal is to pass and protect federal legislation that strengthens accountability and returns America to a system of self-governance for the common good,” told Breitbart News when asked about the propriety of the Highway 31 arrangement with Bully Pulpit Interactive and GMMB Consulting’s Waterfront Strategies. “Issue One believes that it is important for voters to know who is funding advertisements that seek to influence their vote,” Cole added. “This is disclosure in name only given that due to the reporting deadlines, voters will not be able to see what individuals or organization are funding Highway 31 until after the election. Unfortunate situations like these are why we believe that disclosure laws should be strengthened so voters get more information and get that information more quickly and easily,” Cole concluded.

Here are the details of the independent expenditure committee report filed by Highway 31 with the FEC at 4 pm on Tuesday:

Committee: HIGHWAY 31

Ourso Beychok Johnson, Inc.

352 Napoleon St

Baton Rouge, Louisiana 708025939 Purpose of Expenditure: Direct Mail – Estimate

Name of Federal Candidate supported or opposed by expenditure: Roy Moore

Candidate ID: S8AL00340

Office Sought: Senate

State is Alabama in District

Date of Disbursement or Obligation =

Date of Public Distribution/Dissemination = 12/04/2017

Person Completing Form: Edward Still

Date Signed = 12/05/2017

Amount Expended = $57,369.00

Calendar YTD Per Election for Office Sought = $2,933,727.60

Subtotal of Itemized Independent Expenditures = $57369

Subtotal of Unitemized Independent Expenditures = $0

Total Expenditures This Period = $57,369

With seven additional days to spend money provided on credit by Washington, D.C. based consulting firms run by former Obama campaign staffers and or unknown parties to influence the voting behavior of Alabamians between Monday and next Tuesday’s election, Highway 31 expenditures are certain to exceed $3 million, and will probably end up being much more.