Reston Casino Developer Creates New $244K Political Action Committee

RESTON, VA — Comstock, the developer planning to build a casino at or near the Wiehle-Reston East Metro Station, recently formed the Building a Remarkable Virginia Political Action Committee “to elect candidates committed to building a better Commonwealth,” according to state financial filing records.

Comstock submitted the PAC's statement of organization to the Virginia Board of Elections on Sept. 22, listing the developer's chief financial officer, Christopher Guthrie, as its treasurer and Chief Accounting Officer Michael Gualtieri its custodian.

A few days after the PAC was launched, Comstock had to file two amendments. One was to quickly remove the Comstock email address used by Gualtieri and to correct the spelling of his name. The second amendment was to change Gualtieri's email address a second time.

Between Oct. 5 and Oct. 18, eight Comstock employees ($49,500), 13 Comstock entities ($80,000), and 12 vendors ($115,000), primarily from the building and construction industry, donated a total of $244,500 to the PAC, according to state financial records.

Comstock Employees/Associates- $49,500 In Donations

• Christopher Clemente, Chairman of the Board/CEO at Comstock Holdings, contributed $25,000.00 to Building a Remarkable Virginia PAC on 10/17/2023
• Christopher Guthrie, the Chief Financial Officer & Executive Vice President at Comstock contributed $2,500.00 to Building a Remarkable Virginia PAC on 10/17/2023
• John Harrison, the Executive Vice President of Development at Comstock contributed $2,500.00 to Building a Remarkable Virginia PAC on 10/12/2023
• Jubal Thompson, the General Counsel & Executive Vice President-Investments at Comstock contributed $2,500.00 to Building a Remarkable Virginia PAC on 10/05/2023
• Paul Schwartz, the Senior Vice President of Human Resources at Comstock contributed $1,000.00 to Building a Remarkable Virginia PAC on 10/17/2023
• Stuart Schar, a Financial Analyst at Comstock Companies contributed $4,000.00 to Building a Remarkable Virginia PAC on 10/10/2023
• Teresa Schar, the Homebuilder at Comstock Homes Inc contributed $9,500.00 to Building a Remarkable Virginia PAC on 10/05/2023
• Brian Winterhalter, a partner at DLA Piper LLP, contributed $2,500 to Building a Remarkable Virginia PAC on 10/18/2023

On Sept. 25, Patch broke the story that Comstock was seeking to build a casino on the Silver Line in Reston, according to multiple local officials. Currently, no mechanism is in place that would allow a casino to be built in Fairfax County.

Between 2019 and 2023, Comstock Development Services, Comstock Partners LC, and Dwight Schar contributed a total of $485,277 to candidates or political action committees. In addition to being the founder of NVR, Inc. and a former partial owner of the Washington Commanders, Schar is the father of Teresa Schar and father-in-law to Comstock CEO Chris Clemente.

Patch previously reported that 14 Comstock employees gave $29,525 to the re-election campaign of Virginia Del. Wren Williams (R-Stuart). In January, Williams and state Sen. Dave Marsden (D-Burke) introduced identical bills that would've allowed Fairfax County to authorize a referendum being put on the ballot in an upcoming election. Both bills were withdrawn after a few days.

Related:

• Reston Developer's Casino Plan Target Of Online Petition
• Casino: Reston Station Fundraiser To Feature Warner As Special Guest
• 14 Comstock Employees Gave $29K To VA Delegate Who Backed Casino Bill
• Casino Developer Linked To Obscure Political Donation, Filings Show

Read all of Patch's reporting on the proposed casino at the Weihle-Reston East Station at Silver Line Casino.

If lawmakers approved a casino bill and Virginia Gov. Glenn Youngkin signed it, Fairfax County voters would get to decide whether they wanted a casino or not.

The bills also narrowed the location of a "casino gaming establishment" to "within one quarter of a mile of an existing station on the Metro Silver Line, (ii) part of a coordinated mixed-use project development, (iii) outside the Dulles airport flight path, and (iv) outside the Interstate 495 Beltway."

There are seven Silver Line stations outside the Capital Beltway in Fairfax County: Tysons, Greensboro, Spring Hill, Wiehle-Reston East, Reston Town Center, Herndon, and Innovation Center.

The one person on the Comstock Employees/Associates list (above) who is not an actual employee of the company is attorney Brian Winterhalter, a partner with DLA Piper LLP. Not only did he contribute $2,500 to Building a Remarkable Virginia PAC, he also contributed $1,000 to Del. Wren Williams' campaign on April 29, 2023.

Winterhalter's name was not included on the list of the 14 employees who made donations to Williams' campaign, as reported in an earlier Patch story. However, his donation was made within a few days of donations made by eight Comstock employees that totaled $9,500.

Comstock Entities - $80,000 In Donations

• 11465 SH I, LC, a Comstock entity, contributed $5,000.00 to Building a Remarkable Virginia PAC on 10/13/2023 [1900 Reston Metro Plz Fl 10, Reston, VA, 20190 - 5218, USA]
• CLS Bldg C, LC, a Comstock entity, $5,000.00 to Building a Remarkable Virginia PAC on 10/13/2023 [1900 Reston Metro Plz Fl 10, Reston, VA, 20190 - 5218, USA]
• CLS Parking, LC, a Comstock entity, contributed $5,000.00 to Building a Remarkable Virginia PAC on 10/13/2023 [1900 Reston Metro Plz Fl 10, Reston, VA, 20190 - 5218, USA]
• CLS Phase 1, LC, a Comstock entity, contributed $5,000.00 to Building a Remarkable Virginia PAC on 10/13/2023 and another $5,000.00 to Building a Remarkable Virginia PAC on 10/16/2023 [1900 Reston Metro Plz Fl 10, Reston, VA, 20190 - 5218, USA]
• CLS Phase 2, LC, a Comstock entity, contributed $5,000.00 to Building a Remarkable Virginia PAC on 10/13/2023 [1900 Reston Metro Plz Fl 10, 4th Floor, Reston, VA, 20190 - 5218, USA]
• CLS Phase 3, LC, a Comstock entity, contributed $5,000.00 to Building a Remarkable Virginia PAC on 10/13/2023 [1900 Reston Metro Plz Fl 10, Reston, VA, 20190 - 5218, USA]
• Comstock Loudoun Station, LC, a Comstock entity, contributed $5,000.00 to Building a Remarkable Virginia PAC on 10/13/2023 [1900 Reston Metro Plz Fl 10, Reston, VA, 20190 - 5218, USA]
• Comstock Reston Station Holdings, LC, a Comstock entity, contributed $5,000.00 to Building a Remarkable Virginia PAC on 10/13/2023 [1900 Reston Metro Plz Fl 10, Reston, VA, 20190 - 0000, USA]
• CRS Commerce Center UB, LC, a Comstock entity contributed $5,000.00 to Building a Remarkable Virginia PAC on 10/13/2023 [1900 Reston Metro Plz Fl 10, Reston, VA, 20190 - 5218, USA]
• CRS Commerce Center VI, LC, a Comstock entity, contributed $5,000.00 to Building a Remarkable Virginia PAC on 10/13/2023 [1900 Reston Metro Plz Fl 10, Reston, VA, 20190 - 5218, USA]
• CRS Commerce Center, LC, a Comstock entity, contributed $15,000.00 to Building a Remarkable Virginia PAC on 10/13/2023 [1900 Reston Metro Plz Fl 10, Reston, VA, 20190 - 5218, USA]
• CRS Hotel Holdings, LC, a Comstock entity, contributed $5,000.00 to Building a Remarkable Virginia PAC on 10/13/2023 [1900 Reston Metro Plz Fl 10, Reston, VA, 20190 - 5218, USA]
• CRS-RR Holdings, LLC, a Comstock entity, contributed $5,000.00 to Building a Remarkable Virginia PAC on 10/13/2023 [1900 Reston Metro Plz Fl 10, Reston, VA, 20190 - 5218, USA]

Winterhalter represents Comstock for the properties it owns on the south side of the Wiehle-Reston East Metro Station, which include 1850 and 1900 Centennial Park Drive; and 11400, 11440, and 11480 Commerce Park Drive.

Winterhalter also represented Comstock in its Site Specific Plan Amendment proposal seeking to increase density for those five properties, which collectively cover 15.97 acres of land to south of the Dulles Toll Road and linked to the Wiehle-Reston East Metro Station by a bridge.

On Oct. 2, 2023, Patch reported that Comstock had made a $10,000 donation to the re-election campaign of Loudoun County Supervisor Matthew Letourneau (R-Dulles) using the entity CRS Commerce Center UB LC rather than another person or source that could easily be linked to Comstock or one of its employees.

Patch has since learned that CRS Commerce Center UB LC is an LLC created by Comstock and is one of three corporations identified as the owners of the five properties on Commerce and Centennial Park drives, which were the subject of the Site Specific Plan Amendment proposal. The other two corporations are CRS Commerce Center, LC and CRS Commerce Center VI. The three LLCs donated a combined $25,000 to the Building a Remarkable Virginia PAC.

As to the other 10 entities listed above, Patch has determined that they are all LLCs connected in some way to Comstock. Some are linked to other Comstock projects, but each lists one of the developer's properties as its principal business address in its filing with the State Corporation Commission.

This means that Comstock not only formed the Building a Remarkable Virginia PAC, but also a total of $115,000 in donations to the PAC came from Comstock employees, associates, family members, and the 13 Comstock-created LLCs between Oct. 5 and Oct. 18. In fact, all of the 13 entities made donations on the same day, Oct. 13.

Patch acknowledges that Comstock, its employees, associates, and family members have a right to make donations to any candidate whose campaign they wish to support. They are also within their rights to create a political action committee to do so. The same is true for the 12 construction industry vendors who contributed to the Building a Remarkable Virginia PAC.

Patch is reporting this publicly available information; it is not saying that Comstock, its employees, associates, and family members or the construction vendors who were involved in the creation of the PAC or contributed to it did anything illegal.

Earlier this month, Saurav Ghosh, the director of the nonprofit Campaign Legal Center's Federal Campaign Finance Reform initiative, told Patch that it was common for corporations and even wealthy individuals who have certain goals for the political process to work in their favor to make political contributions.

"For optics reasons or to avoid the perception that they're trying to essentially put a finger on the scale to achieve their desired policy outcomes, they often will try to conceal the fact that they're making a political contribution to crucial, influential policymakers or even to sway a ballot measure one way or the other in the hopes of advancing their company's goals," Ghosh said. "They often will try to avoid that being done openly and transparently."

On Thursday, Patch reached out by email to the eight Comstock employees and associates who contributed to the Building a Remarkable Virginia PAC for comment. Similar emails were sent to the two Comstock employees identified as the custodian and treasurer of the PAC. As of Friday at 3 p.m., no responses had been received.