AFLDS Scam? GoldCare Health & Wellness, LLC Was "Voluntarily Dissolved" on January 6, 2023

"GoldCare™" also flagrantly violates HIPAA regulations protecting patient privacy while advertising it as a positive thing. Alex Berenson, move over. Simone Gold is in the house.

So when I covered the America’s Frontline Doctors (AFLDS) crazy court case the other day, I honestly didn’t have a huge bias either way or even a mild opinion about who was right. I was genuinely confused.

But since I posted that article, someone shared a link to some court documents in the comments. Assuming these court documents are genuine, I have to say I am even less impressed with everyone involved, and the whole thing is basically a Jerry Springer show on steroids.

If you have time, it’s somewhat enlightening and weirdly entertaining to read the court documents, because the judge is clearly frustrated and annoyed with both sides. The TLDR (too long didn’t read) is as follows:

The judge thinks that Dr. Simone Gold has been wrongly funneling money from the AFLDS charity to her for profit LLC, which may actually be illegal. Dr. Gold also apparently received some highly excessive compensation of $50,000 a month for leaving the board. Emphasis mine:

There was discussion about Gold staying on as a consultant. AFLDS wanted Gold to stay on and continue to be involved in fundraising and continue as the “face” of the company. In fact, the company paid her $50,000 per month. No Consulting Agreement, however, was ever finalized and signed.

The notion that a non-profit company could take donated funds and pay them to a principal of the company to invest in a for profit business is simply absurd. Gold is a very intelligent physician and lawyer. She had to know that such an arrangement was completely improper and likely illegal. In any event, there is simply no evidence that AFLDS agreed to pay her $1.5M. Such a payment was clearly not a condition to her resignation.

Meanwhile the board directors of AFLDS are also getting excess compensation, and the judge thinks they are basically clowns who don’t know what the hell they are doing.

Gilbert is apparently still being paid $20,000 per month from AFLDS. It is not at all clear why the company decided to pay Mack an additional $20,000 per year to be President. It is far from clear to the Court what Mack’s role in the company is. He does not appear to have any corporate managerial experience.

It is, of course, not the Court’s role to make managerial decisions for this company. Nonetheless, paying Mack and Gilbert a total of $40,000 per month appears to the Court to be greatly excessive.

Gilbert and Mack contend that they are in charge and control of the company. Yet, it has been on their watch that the company’s operations have spiraled into chaos.

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As noted at the hearing, the Court seriously questions whether Gilbert and Mack have the skill sets to properly run this non-profit company. The Court is not convinced that Gold is causing irreparable injury to this company. In fact, Gold’s skill set appears to be critical to the survival of AFLDS.

The end result is that the judge thinks that the whole thing is a mess, and both sides need to figure out how to actually get the organization back on its feet. But the bottom line is, the board members have every right to fire Simone Gold.

My takeaway from this is that both sides are greedy as all get out. In my opinion, if you are running a not-for-profit charity, your executive expenses should be as minimal as possible. Top salaries for national nonprofit executives of established charities run around $500,000/year, which I still think is a bit much. The average salary for heads of nonprofits is $101,381 nationally.

So if Simone Gold is asking for $50,000/month as a retainer…well, you do the math ($600,000/year). That is simply far more than anyone should be getting from a nonprofit. Simultaneously, AFLDS board members should also not be getting $20,000/month apiece ($240,000/year) just for sitting on the board of a nonprofit, which apparently they don’t even control and hasn’t actually been doing much of anything these days in terms of actual medical freedom advocacy.

These numbers in and of themselves are outrageous and wrong, and should send AFLDS into the dustbin of history. If you are still donating to AFLDS, you are being used by people who are engaging in fiscal malfeasance, in my opinion.

Despite these egregious financial revelations, people are still defending Gold’s excessive retainer. The person commenting on my last article claimed that Gold was justified in requesting $50,000/month because “consultants have to pay their own expenses.” This is a BS argument when we’re talking this amount of money. The excuse is that Gold needs “bodyguards” or travels to speak. (By the way, maybe Gold is getting paid to speak as well? Did you consider that?)

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I’m sorry. First of all, if Gold really needs bodyguards, which I don’t believe, but just in case, then the agreement should have been for the organization to pay directly for those bodyguards, not pay Gold personally so she could hire her own staff. So I think this is a bogus argument.

Secondly, there is a difference between Gold’s crazy consultation fee and a professional who might be making $30/hour full-time if they work in an office on salary, and them charging $50 or $75 an hour when they’re working as a consultant (which is usually part-time, by the way), because they have to pay for their own equipment, Internet bill, and office space.

But the really big story here, which an investigative reporter like Matt Taibbi should sink his teeth into, is what is going on with Simone Gold allegedly funneling money from AFLDS to her for-profit LLC, which is extremely problematic, if not downright fraudulent.

There are a lot of shenanigans relating to Gold’s for-profit LLC that I want to cover here. Do note that this not an investigative reporting piece of comprehensive journalism.

First of all, in order to do this subject justice, someone would need to take about a month and actually go and interview all of the people involved, if possible; request formal court documents, financial reports, and other information from the involved parties; and try to craft a cohesive narrative. I simply do not have the time, wherewithal, or even the patience to do that.

But what I have done is a preliminary investigation, which has convinced me that what Simone Gold is doing with “GoldCare™ Health & Wellness” is at best fishy and at worst completely unethical if not downright fraudulent.

My concern is that if Gold ever gets prosecuted for this, it’s going to be a big setback for the medical freedom movement. What she may have been doing here makes Alex Berenson’s snarky comments look like cute little outbursts of a loveable but out of control teenage boy.

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What I’m seeing with this Simone Gold story is something a lot more sinister, and I’m not even talking about shady controlled opposition narratives that other people are proposing. Those people could potentially be right, but I don’t even think that needs to be a part of this story. I think the most obvious thing that’s going on here is a simple case of greed.

I’ve seen it before in other arenas up close and personal, and I know this thing happens all the time. Health and wellness seem to be prime areas for greedy people to take advantage of the sick and desperately, sadly.

An Example of a Shady Holistic School

Skip to the next section if you want to get to the meat of the GoldCare problem, but this story gives some additional insight, I think:

I’ll give an example of the Ayurvedic organization that I got my training from. The teachers were wonderful, but the couple running the school, who lived in Mexico, started to treat the students poorly when they were disappointed they weren’t getting what was promised.

When the owners of the school found out that some of the students were complaining in a private Facebook group that a friend of mine and I had set up for student support, they started threatening the students and intimidating them, saying they would withhold diplomas. One of our friends was kicked out of the school for her concerns, just prior to graduating, and was unable to get her transcript despite paying this school thousands.

I had fortunately already graduated and so had my friend, and we were able to do some investigation. We found out that the school had claimed to be a registered educational institution in the state of Florida. See, a registered educational institution is required by law to provide transcripts upon request in Florida.

But it turns out that the Ayurveda school’s LLC in Florida had been expired for a while, so the school registration meant zilch. And since the owners (one American) were located in Mexico, we questioned whether they were even paying taxes in the United States.

Because there were all sorts of shady things going on…including one underqualified staff member who was not an Ayurvedic Practitioner posing as someone with the credentials to run a mentorship class for required clinical hours…and short-shrifting students on required teaching hours…we filed a formal complaint with the Ayurvedic association that had provided the school with its “accreditation.”

That organization did an investigation, and the end result was that the school was required to get all of their books in order and (hopefully) act more ethically to continue to be listed with the association (now using the labels “verified” and not “accredited” for all schools, perhaps partly due to their lack of ability to fully vet schools).

I haven’t followed up with this since to see if the students are being treated better, but we do know that the school did finally reenact their LLC. Hopefully they also created a better feedback structure in the school so that students who had complaints wouldn’t be kicked out.

However, those of us who filed formal complaints (at least five of us) were concerned that the Ayurvedic association was understaffed and needed money, and so perhaps prioritized the yearly listing fees they were getting from said school versus doing what they probably should have been done…which was kick the rogue school off their list of approved schools entirely.

Despite all the drama, the broken dreams of wrongfully expelled students, and all the evidence, quite a few remaining students refused to believe that the school’s founders were capable of being assholes.

You think that’s bad? I also had to quit a spiritual school recently after finding out that the main guru was allegedly involved in literal ponzi schemes and setting up the head guru (now deceased) with sexual liaisons with students. They were also overcharging students and taking advantage of sick, emotionally fragile people. But that is for another article someday.

What I learned from these experiences is that there are a lot of people who come off as love of light on the surface, who market themselves really well, and who seem like they care, but when push comes to shove, they are really just trying to promote themselves and their business to make money.

Do not be fooled by slick marketing, touchy-feely PR, and someone with a good speaking voice. Also look at their actions - are they backing up their inspiring-sounding words?

What Has America’s Frontline Doctors Actually Done?

Given what I’ve seen with bad gurus, I think a lot of people want to defend Simone Gold because she is charismatic and says what they want to hear. And they just can’t fathom that maybe she’s just a “grifter” in the true sense of the word.

But I can only look at the facts here. And based on the facts, I do not think that she is sincere, or if she is, she’s completely delusional about what she is worth. In my opinion, nobody is worth $50,000/month retainer from a nonprofit organization. No-one.

If you want to set up a for profit and pay yourself that much, I don’t care, but when you’re gathering donations from people - probably most of whom don’t have that much money - and they think they’re doing it for “medical freedom,” you better damn well spend that money carefully.

I took a look at the AFLDS websites - see “press releases” here - to try to see exactly what they were spending their money on. Now, I will say that they look like they are putting pumping out a lot of content, but you know what? I pump out a lot of content too, and nobody’s paying me $50,000/month, so boo-hoo, big deal. That’s not justifying all this money they’re raking in.

I then wanted to see whether AFLDS was actually making any sort of legislative impact. Now to be fair, I haven’t gone through every single press release that they’ve posted on their website(s) because frankly I don’t have the time to do it. But I’ll tell you what I did see. Pretty much most of the so-called “briefs” they advertise recently don’t seem to actually be cases AFLDS took the lead on.

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In short, their latest efforts (other than the battles between Gold and the board members) seem centered around posting a press release here and there going on about how they’ve posted an amicus brief relating to some sort of health freedom case, as if this was some major accomplishment, but in reality, all what they did was simply have their lawyer write a letter to support whatever case was already in process.

Well, this is nice, and I’m not saying these things don’t help, but filing amicus briefs is not leading the legislative agenda. Anyone can do that. I could write a letter to support a case. So could you.

Does AFLDS need millions and millions of dollars to do this? No. For the amount of money that they are apparently raking in, if they can afford a $50,000/month retainer, I would expect them to be taking more of a leadership role legislatively and with their lawyers.

In 2021, AFLDS did file two lawsuits, one was to stop covid shots for kids and another was to fight NYC’s vaccine mandate. Both noble causes, but obviously failed.

I also found another press release that that seemed to indicate that one of their lawyers was supporting a fightfighter in a lawsuit...however the way the press release was worded, aka “America’s Frontline Doctors’ (AFLDS) Senior Affiliate Attorney” (Affiliate Attorney?) I got the impression that AFLDS might not actually have been running the case, but that a lawyer simply associated with AFLDS was.

The question is, was the client paying the AFLDS lawyer while the lawyer was actually working on their own, and AFLDS was just trumpeting this case as an example of something that the nonprofit was doing (and funding)? This is one of those things where to do this story justice, I’d have to go and track everybody down and maybe see if I could get some receipts.

Early on, AFLDS was getting some negative press for allegedly bilking patients during the height of the COVID-19 pandemic. Time magazine covered the story, and cited Mike, who paid for a telehealth appointment that was never fulfilled:

Through its website, Mike says, he paid the group $90 for a telemedicine appointment with a doctor willing to prescribe the drug.

A week later, he was still anxiously waiting for the consultation. Calls and emails to AFLD went unreturned, he says. Finally, he called his bank to report a fraudulent charge. “Not even an apology,” Mike, whom TIME is referring to using a pseudonym because of his concerns about his job, told TIME in an interview. “This is absolutely nuts. This organization is not helping anyone but their pocketbooks.”

Time also noted that the AFLDS nonprofit was essentially defunct in Arizona, where it was registered. However, since then, the Free Speech Foundation, which is the nonprofit organization behind AFLDS, has fixed this and is actually active and in good standing now, according to the Arizona Corporations Commission:

The Major Red Flags With GoldCare

So let’s take a look at “GoldCare™ Health & Wellness” (in parenthesis for the ridiculous trademark symbol), which is Simone Gold’s for-profit LLC that she’s using to supposedly change healthcare.

Now, I actually believe that we need alternative healthcare structures, but when I looked at the GoldCare website I immediately had warning bells going off, set off by one word: tokens.

Tokens for healthcare? I’m sorry! Doesn’t this immediately sound scammy to you? The only thing missing here are NFTs for healthcare. Maybe Gold might want to create some Superhero Simone NFTs that she can sell in exchange for healthcare tokens? You see what I mean when I say this already is sounding scammy?

So how does this work? Well, first of all, I was told by the commenter (on my other article), who apparently is a member of this organization, that it’s a PMA or “private member association,” and she was under the impression that it was nonprofit. I initially responded and said, it’s an LLC, according to the Arizona court documents, and LLCs are for-profit corporations.

Well, technically, I was wrong. In a couple of states, you can have an LLC become a nonprofit. but from what I understand, one of those states is not Florida, which is where one GoldCare Health & Wellness, LLC was registered. Please note the word was. We’ll get to that in a second.

Even in the five states in which an LLC can be a nonprofit, there are very strict rules, and the LLC must be a sub-corporation under an existing nonprofit corporation. In addition, just because the state gives recognition to the nonprofit LLC, that doesn’t mean that the IRS will.

Getting an IRS to recognize a nonprofit organization is extremely difficult and requires a lot of hoop jumping. You can’t just open up any company and claim it’s a nonprofit and boom not have to pay taxes. So given all of this, if “GoldCare™ Health & Wellness” is marketing itself as some sort of nonprofit organization when it isn’t, that is clearly fraudulent and in and of itself could get Simone Gold into a lot of trouble.

Now on the “GoldCare™ Health & Wellness” website, I actually don’t see much information about the structure of the company, and there is no address or phone number, which is also really fishy. No contact form that I could find.

I actually signed up for the newsletter, which strangely required a phone number (of course, I put in a fake phone number). After submitting the form, I never got an automated message saying I had signed up for a mailing list. This makes me think that the form is actually not a newsletter but a sales pipeline operation for them to get phone numbers, so that they can call people and potentially sell them these memberships.

The GoldCare memberships start at $1,000/year for an individual plan, for the first 1,000 people, and then go up to $1,800 per year. Supposedly for that amount of money, you’re going to get “telemedicine access,” but what does that mean exactly? This cost does not include the cost of an optional “cost-sharing ministry,” apparently. Tokens are also extra, and you need five to meet with a physician:

• The current price of a GoldCare™ token is $20. Here’s the breakdown of the current rates based on each 15-minute block of time:

  • Physician: 5 tokens ($100)

  • Nurse practitioner or physician’s assistant: 4 tokens ($80)

  • Coach (such as a registered dietitian or nurse): 3 tokens ($60)

• The cost of GoldCare™ tokens will increase over time due to inflation and demand.

This is starting to sound like a Ponzi scheme to me, but maybe that’s just me. Here’s the thing...if you don’t use those tokens, or your membership, basically the company gets to keep all that money most likely, which is where the profits lie.

I also don’t know what all the fine print is, in terms of how much more you still have to pay out of pocket. What about testing, bloodwork, MRI scans? In fact, hilariously, they sell the fact that they’ll order as few tests as possible:

Necessary testing only

Because of our unbiased approach, our providers recommend only the tests and labs that are in your best interest. We aren’t locked into restrictive governmental protocols that require a myriad of unnecessary test or treatments.

In short, already I can tell this is a bad deal, and given that the website itself does not give any information about its location, nor clarifications about its corporate status, nor any searchable list of providers...but only plays off of the AFLDS name for street cred...this is red flag city.

But I’ll tell you what the huge red flag is right now, and this is me burying the lead here...but this really shocked me.

The actual organization that supposedly runs this company is GoldCare Health & Wellness, LLC. To find this name, I first searched the web and unfortunately found it on Quackwatch (which is a pharma-funded website that I really dislike because they are against alternative medicine). So I looked up GoldCare on the Florida corporation database and guess what I found?

There is a GoldCare Holdings, LLC that is registered with Simone Gold.

A registered agent in Florida is an entity that maintains residence in Florida so someone can basically send you a subpoena. You do not have to live in Florida to have an LLC there...I have one, my registered agent is in St. Petersburg (same one Gold uses for her new nonprofit, which you’ll see below, yes another questionable organization!). Gold’s registered agent for her LLCs is a lawfirm, BOATMAN RICCI, P.A.

In addition to GoldCare Holdings, LLC, a second LLC was registered on February 2, 2022, GoldCare Health and Wellness, LLC. This second LLC was registered not with Simone Gold directly but has no actual person listed as “Title AMBR” (the authorized member or “head” of the LLC), but GoldCare Holdings, LLC is listed instead.

I believe that Title: AMBR is supposed to be a person…it even says so in the stock electronic articles of incorporation filed:

Article V

The name and address of the person(s) authorized to manage LLC:

Title: AMBR
GOLDCARE HOLDINGS, LLC

Why set up a sub-corporation at all here? It’s weird. Well…

On January 6, 2023 (date chosen on purpose?), Gold Care Health and Wellness LLC was voluntarily dissolved.

WTF is going on here? Are they closing “GoldCare™ Health & Wellness”? If they were moving all the assets into GoldCare holdings, why not note that in the document?

Why is the website still up? What is happening to all that money? Or patient tokens? Are they shutting down? Or are they going to continue the business under GoldCare Holdings, LLC? But I’m not finding “GoldCare™ Health & Wellness” listed in the “fictitious names” search - worse, there was some other medical group already using “Gold Care” prior to Simone Gold, starting in 2020.

This is extremely alarming, especially when you consider how many people might have given their money to this organization.

Now it is also interesting to note that as of December 2, 2022, Simone Gold has now registered a new nonprofit in Florida called FRONTLINE FREEDOM FOUNDATION INC. Clearly she is looking to take all of the media assets that she’s been controlling from America’s Frontline Doctors and transfer them to her new “nonprofit.”

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Some people think that Simone Gold is controlled opposition. I’m more convinced that she’s simply an opportunist...a greedy one at that.

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Gold Care Violates HIPAA Privacy Regulations

Here’s something else that’s extremely alarming on the goldcare.com website and right off the bat tells you that it’s an organization that you cannot trust with your healthcare. It’s unethical. And frankly, if Simone Gold is still working directly with patients, it could get her medical license revoked.

Literally on the GoldCare website they say they are not HIPAA compliant. And they act like this is a good thing. This one thing, forget about everything else I’ve written about, is a reason for you to run not walk from GoldCare. (Archive link here.)

What this basically means is that they are saying that they aren’t responsible for keeping your medical records private.

This is huge.

Furthermore, they are lying when they say (emphasis mine):

No HIPAA here

We are not a HIPPA-covered entity. Every GoldCare™ member’s information is secure, and we don’t share your information with anyone — insurance, governmental institutions, or anyone! With the insurance middleman gone, we can get to the business of taking care of your health needs — without harmful coverage policies.

“We are not a HIPPA-covered entity.” This is a flat-out LIE. If GoldCare is providing diagnostic medical services and treatments under the banner of Western medicine, they absolutely are required to abide by HIPAA.

So what is HIPAA? HIPAA is the Health Insurance Portability and Accountability Act. This law is actually helpful to patients in that it creates strict guidelines for how healthcare providers can manage and store your health records. It gives you privacy rights over your medical information. HIPAA also outlines exactly how medical information can be stored electronically, requiring robust encryption to make sure that your information cannot be easily seen or stolen by unauthorized people.

Anyone who is a physician in the United States is required to abide by HIPAA. Now, I am an Ayurvedic Practitioner and involved in holistic health. Because I am not a licensed health professional in the United States, and I’m not required to be registered with the government, I am not required to follow HIPAA. However, I am also not allowed to practice “medicine.”

Still, ethically, all Ayurvedic Practitioners in the United States voluntarily agree to abide by HIPAA guidelines, and furthermore, most Ayurvedic associations and schools encourage this. This is because as ethical health professionals, we take our patient privacy seriously. I am also a yoga therapist, and yoga therapists also take HIPAA very seriously.

So if holistic health practitioners and yoga therapists understand the importance of HIPAA, why doesn’t Simone Gold, who is supposedly a board-certified physician? This is so egregious and shocking, I just can’t even understand what they were thinking when they put that on the website.

They are either actively trying to scrape people’s medical information, and thus literally put on the website that you can expect no patient record privacy with their HIPAA notice…or, the website developers are simply ignorant people, who shouldn’t be trusted with your healthcare information, because they are so clearly clueless.

I decided to look up Simone Gold’s medical license to see if she was even still allowed to practice medicine in the United States. It looks like she’s spent more time in involved in things like getting her law degree and fitzing around with people in Congress than actually being a medical clinician much of her career – but, she has kept up her medical licenses in both California and Florida, assuming there are no other Dr. Simone Golds floating around.

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But this actually means she has to take HIPAA seriously, and if she’s not protecting patient medical data, it could be problematic for her medical licensing.

In fact, if you have been Dr. Gold’s patient, or a patient of GoldCare, and you are concerned about your medical records, you have every right to complain to the Florida state medical board (as much as I’m not happy with medical boards right now).

Guess what? In September 2021, the AFLDS patient database was hacked, in an apparently exceptionally easy hack job, and patient information was provided to the Intercept, the publication Glenn Greenwald founded and later left because they had gotten too rigid and partisan (this bias shows in their coverage of the AFLDS). So here’s the damage:

The hacked data includes information on 281,000 patients created in the Cadence Health database between July 16 and September 12, 2021 — 90 percent of whom were referred from America’s Frontline Doctors. In just those two months, patients paid an estimated $6.7 million for consultations. The data also includes notes from patients’ phone consultations, which sometimes include medical histories and prescription information.

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The hacker also provided records of 340,000 prescriptions that Ravkoo has filled between November 3, 2020, and September 11, 2021 — amounting to an estimated $8.5 million in drug costs. Forty-six percent of the prescriptions are for hydroxychloroquine or ivermectin, and another 30 percent are for zinc or azithromycin, two other ineffective medications that the SpeakWithAnMD physicians, who America’s Frontline Doctors claims it trains, prescribe in their Covid-19 consultations.

Thus, AFLDS, under Simone Gold’s watch, raked in millions in patient consultations, some of which were not fulfilled, and failed to properly protect patient data because HIPAA guidelines weren’t being rigorously followed.

It gives me no joy to write all this up. I hate that this is going on, because it just makes the entire medical freedom movement look really, really bad. But I’m also not going to shove this under the rug, because innocent people may be scammed and give away money that they shouldn’t to a healthcare organization whose LLC is now voluntarily dissolved.

So I’ll give a few final notes.

First of all, any real nonprofit organization worth their salt has an annual report that they make public which provides an accurate accounting of all of their expenses and income. It also notes who the major donors are usually. With the annual report, you can get an idea of what corporations are supporting the nonprofit organization, who is involved in running the organization, and where the money is going.

Nonprofit organizations that use a large percentage of their expenses towards executive salaries are generally considered to be bad nonprofits that you should not donate money to. On the other hand, good nonprofits are nonprofit organizations that funnel the majority of the money towards programs that directly impact the population they’re trying to help.

What we need to see from AFLDS and GoldCare are accurate financial documents letting us know how much money they are bringing in, who their major donors are, and where that money is going and why. I would not give them one cent otherwise, even if AFLDS relaunches without Gold.

Now if one of Simone Gold’s lawyers happens to stumble across this page and wants to write some nasty letter cease and desist to me, I would request that along with sending me your nasty letter, that you also send me some financial documents that show exactly what’s going on with these organizations that are being marketed as charitable efforts for the public good, and prove they aren’t being used to put money into Simone Gold’s pockets.

I also want to know what legal entity is now doing business as “GoldCare™ Health & Wellness.”

Furthermore, I’ll be happy to publish any sort of clarifications that show some clear due diligence with the finances of these intertwined organizations.

Otherwise, everything that I have said in terms of the dissolved LLC, HIPAA, and Gold’s excessive compensation, is all publicly available, and therefore fair game to write about. I am also allowed to express my opinion that this all looks unethical to me personally. And any good lawyer worth their salt would know that. So save your threatening letter.

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Besides, I, unlike Simone Gold, am not making $50,000/month and you can’t really make much from me in a lawsuit regardless.

UPDATE: FRAUD REPORT

I Have Reported Simone Gold to the FTC for Fraud

1. I’d also like to note that giving Gold a blank check for “expenses” is also not kosher. I’m not an accounting expert, but even I know enough that you wouldn’t just give someone $50,000/month to cover miscellaneous airline tickets and hotel costs. It’s one thing for the consultant to have fixed costs for doing business (like office space and equipment) that would be used in the day to day running of the consulting business. But it’s another thing to have ad hoc expenses (especially large ones) involving travel costs and the like. For Gold’s speaking engagements, travel costs, by the way, may have been covered by the organization hosting the event, not her personally. If not, and she had to fly herself somewhere to represent AFLDS, then AFLDS should have paid for the costs either directly, or get an itemized accounting of expenses to reimburse her. A “blank check” of $50,000/month is not the proper way to handle such expenses.

2. As much as I’ve been busting Alex Berenson’s balls this past week, he’s not claiming he’s running a nonprofit organization, nor is he claiming to offer healthcare to people. I don’t think he’s acting fraudulently, and as much as I have been upset with him for gaslighting vaccine victims, I honestly think that he’s just clueless and genuinely believes his own hype. In effect, I think he’s a bit full of himself and arrogant, but ultimately passionate about what he’s doing, and is not trying consciously trying to hurt the movement. I want to make this clear. What Simone Gold has been up to may be quite serious in comparison.

3. I have learned since I wrote this article that 501(c)(3) nonprofits cannot engage in excessive lobbying, which means attempting to influence legislation (such as with lawsuits - see this IRS page). This begs the question, why was AFLDS promoting themselves so strongly as an legislative advocacy organization involved in so-called legal battles for medical freedom.

4. Since I first published this article, I found out that Simone Gold is already soliciting donations online for this new “foundation,” but the donation page copy is duplicitous in that it says, “To protect your donation, this gift is conditional on Dr. Simone Gold as President and Chairman of FFF.” This is deceptive in that Gold is already in total control of “Frontline Freedom Foundation,” as it is an entirely separate legal entity from AFLDS, which is owned by the Free Speech Foundation. As such, this donation page might constitute fraud, but I’m not a lawyer. (Archive link here.)

5. After I published this piece, a reader found a few more LLCs Gold has registered in Florida. Here’s what they found:

There are two other active LLCs:

(1) GoldCare Marketing Services, LLC L22000057197

(2) GoldCare Naples, LLC L22000057243

Note same principle & mailing addresses and the same registered agent; Boatman Ricci. However; Article V each have different entities not a person listed as the AMBR:

(1) GoldCare Holdings, LLC

(2) Tenere, LLC

Also GoldCare Media G22000035608 is another fictitious name.

6. On the mission statement page of (one of the) AFLDS websites is an interesting sidebar claiming that Gold was “formerly Board-certified, voluntary refusal to recertify.” This is not true as she has active medical licenses in two states, and typically to keep a license you need to log a certain number of CEUs (continuing education units) on a regular basis. In other words, these licenses will expire without regular action to maintain them. (Archive link here.)

7. For shits and giggles, here’s the threatening letter I got from the lawyer of the Ayurveda school when we filed the complaints. Note, I had previously been tapped by the school to work in their online clinic, which is what he was referring to in terms of “employment”…but the clinic work never materialized. Sufficed to say, we all got these letters and had a good collective laugh about it:

Dear Miss Braile,

Please be advised that this office represents [SCHOOL WITHHELD]. It has come to our attention that you have been asserting defamatory information against our client. Immediately cease and desist and retract any such information. Furthermore, it appears that attempts have or are being made to contact current or former members of the school in a derogatory manner. Immediately cease and desist and retract any such information that exists since this can be considered as tortious interference with a business relationship. 

Lastly, I believe that you have listed yourself as being either currently employed or previously employed with my client. This is as you know totally inaccurate. Immediately remove any such indication from any source in your control.

We will be closely monitoring the situation. Please give this matter your immediate attention.

GOVERN YOURSELF ACCORDINGLY

Sincerely,

[SILLY LAWYER’S NAME WITHHELD]

For the firm