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LAW OFFICES OF

J . W HITFIELD L ARRABEE
TRIAL AND APPELLATE LAWYERS
251 HARVARD STREET, SUITE 9
BROOKLINE, MASSACHUSETTS 02446

TELEPHONE: (617) 566-3670


FACSIMILE: (617) 507-6435
JW.LARRABEE@VERIZON.NET
WWW.LARRABEELAW.COM

February 27, 2017

VIA FAX AND FIRST CLASS MAIL

Keith Sellen, Director


Office of Lawyer Regulation
110 East Main Street, Suite 315
Madison, WI 53703-3383

In Re: Reince Priebus

Dear Director Sellen:

Enclosed for filing please find a disciplinary complaint and grievance form concerning
professional misconduct by attorney Reince Priebus, a member of the Wisconsin bar.

Thank you for your time and consideration of this matters.

Very truly yours,

J. Whitfield Larrabee

Enclosures
JWL/hg
OFFICE OF LAWYER REGULATION
WISCONSIN SUPREME COURT

IN THE MATTER OF: )


REINCE PRIEBUS ) COMPLAINT
)
)

1. There is probable cause to charge attorney Reince Priebus (Priebus) with violations of

Wisconsins Rules of Professional Conduct for Attorneys, Supreme Court Rules, Chapter

20. The violations of these rules relate to Priebus corrupt attempt to influence

investigations by the United States Federal Bureau of Investigation (FBI) into criminal

activity involving associates of Donald J. Trump (Trump) and Russian government

officials.

2. Priebus is a lawyer admitted to practice law before the Courts of Wisconsin. As a lawyer

licensed to practice law in Wisconsin, Priebus is required to comply with Wisconsin

Supreme Court Rules (SCR), Chapter 20. He is presently employed as the Chief of

Staff for President Trump.

3. It is a violation of SCR 20:8.4 (b) for a lawyer to commit a criminal act that reflects

adversely on the lawyer's honesty, trustworthiness or fitness as a lawyer in other

respects. It is a violation of SCR 20:8.4 (c) to engage in conduct involving dishonesty,

fraud, deceit or misrepresentation. There is probable cause to charge Priebus with such

serious violations of these particular ethical requirements that it will be necessary and

appropriate to revoke his license to practice of law if the charges are established.

4. The FBI and the United States Department of Justice (DOJ) are currently investigating

links between associates of Trump and the Russian Government. Phone records and

intercepted calls show that staff members and other associates of Trumps 2016
presidential campaign had repeated contacts with senior Russian intelligence officials in

the year before the election. During this time period, Russian intelligence officials

interfered in the United States election in aid of Trumps election campaign. There are

reasonable grounds to suspect collusion between the Trump campaign and the Russian

government to influence the federal election that occurred on November 8, 2016.

5. According to reliable news reports and records, the FBI and DOJ investigations concern

former National Security Advisor Michael Flynn, former Trump campaign manager Paul

Manafort, Trumps foreign policy advisor Carter Page, Trump associate Roger Stone and

other Trump associates.

6. The Federal Campaign Finance Act, 52 U.S.C. 3012, prohibits the solicitation or receipt

of contributions and donations of anything of value from foreign nationals to a federal

election. Collusion with Russia by individuals associated with a political campaign in

order to solicit or receive assistance in a political campaign connected to the election of

the President of the United States is a criminal violation of 30121. There are serious

and substantial reasons for the FBI and the Department of Justice to investigate Trump

and his associates to determine whether or not any of these individuals committed

criminal violations of the Federal Campaign Finance Act.

7. The Foreign Agents Registration Act, 22 U.S.C. 611 et. seq., requires individuals acting

for political purposes on behalf of or in cooperation with a foreign government to register

with the Justice Department and to publicly disclose their identities, activities and

financial information. Collusion with Russian intelligence officers by individuals

associated with a political campaign in order to aid Russia in influencing the election of

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the President of the United States is a criminal violation of the Foreign Agents

Registration Act.

8. A conspiracy to violate either 52 U.S.C. 30121 or the Foreign Agents Registration Act

by a presidential candidate is a criminal offense. The FBIs investigations are focused on

violations of these and other criminal laws by Trump and his associates.

9. There are serious and substantial reasons for the FBI and the Department of Justice to

investigate Trump and his associates to determine whether or not any of these individuals

committed criminal violations of the Foreign Agents Registration Act and the Federal

Campaign Finance Act or if they engaged in a criminal conspiracy to violate these

statutes.

10. While FBI investigations were occurring, on or about February 15, 2017, Priebus

corruptly contacted and communicated with FBI Deputy Director Andrew McCabe

(McCabe) about one or more of these investigations. Shortly after communicating

with McCabe, Priebus corruptly communicated with FBI Director James Comey

(Comey) about one or more of these investigations.

11. Priebus requested McCabe and Comey to talk with certain reporters who disputed stories

in the New York Times and other news reports that phone records and intercepted calls

show that members of Donald Trumps 2016 presidential campaign had repeated contacts

with senior Russian intelligence officials in the year before the election.

12. Priebus contact with the FBI concerning its investigation of Trump and his associates

corruptly violated longstanding practices and guidelines of the Justice Department.

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13. A 2009 Justice Department memorandum provides: Initial communications between the

[Justice] Department and the White House concerning pending or contemplated criminal

investigations or cases will involve only the Attorney General or the Deputy Attorney

General, from the side of the Department, and the Counsel to the President, the Principal

Deputy Counsel to the President, the President, or the Vice President from the side of the

White House.

14. Priebus sought and obtained comment on the investigation from Comey and McCabe in

violation of Justice Department Guidelines that provide: The Department of Justice shall

not respond to questions about the existence of an ongoing investigation or comment on

its nature or progress, including such things as the issuance or serving of a subpoena,

prior to the public filing of the document.

15. Longstanding written controls, based on authority given to the Attorney General under an

executive order issued by Ronald Reagan in 1981 and on several statutes, require the

Attorney Generals approval for most contacts between the FBI and the White House

regarding foreign intelligence matters that involve domestic political activities. The

written controls provide: Compromising information concerning domestic officials or

political organizations, or information concerning activities of United States persons

intended to affect the political process in the United States, may be disseminated to the

White House only with the approval of the Attorney General, based on a determination

that such dissemination is needed for foreign intelligence purposes, for the purpose of

protecting against international terrorism or other threats to the national security, or for

the conduct of foreign affairs. There was no lawful authorization from the Attorney

General for Priebus to communicate with Comey or McCabe.

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16. Priebus corrupt communications implicitly threatened Comey and McCabe with

termination of their employment because Trump has the power to remove McCabe from

his position as Deputy Director of the FBI and to remove Comey from his position as

Director of the FBI if they do not comply with the requests of the President as

communicated through his agent and Chief of Staff.

17. Priebus communications with Comey and McCabe were dishonest and corrupt because of

the conflict of interest inherent in his communications with the FBI during its

investigations of Trump and his associates. Priebus dishonestly abused his authority as

White House Chief of Staff to elicit information from Comey and McCabe that

compromised the integrity of the FBIs investigation.

18. There is probable cause to establish that the purpose of Priebus contact with the FBI was

to interfere in the investigation, to cover-up illegal conduct, and to influence, obstruct or

impede the due administration of justice.

19. 18 U.S.C. 1503, the United States obstruction of justice statute, makes it a crime for any

individual by any threatening letter or communication to influence, obstruct or impede, or

to endeavor to influence, obstruct or impede the due administration of justice.

20. There is probable cause to establish that Priebus violated 18 U.S.C. 1503 by attempting

to influence the FBIs investigations through communications with Comey and McCabe

that carried an explicit or implicit threat of adverse action against Comey, McCabe and the

FBI.

21. There is probable cause to establish that Priebus violated of SCR 20:8.4 (b) by attempting

to obstruct justice and that his criminal acts reflect adversely on the his honesty,

trustworthiness or fitness as a lawyer in other respects.

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22. There is probable cause to establish that Priebus acted corruptly by endeavoring to

influence, obstruct and impede the FBIs investigations and to influence, obstruct or

impede the due administration of justice and that his actions involved dishonesty, fraud,

deceit and misrepresentation in violation of SCR 20:8.4 (c).

WHEREFORE, the complainant respectfully requests the Office of Lawyer Regulation to

fully investigate the violations set forth in this complaint and that it duly and properly enforce the

Rules of Professional Conduct for Attorneys by requesting that the Wisconsin Supreme Court

revoke Reince Priebuss licence to practice law.

Respectfully submitted,

______________________________
J. Whitfield Larrabee
Law Offices of J. Whitfield Larrabee
251 Harvard Street, Suite 9
Brookline, Massachusetts 02446
jw.larrabee@verizon.net
BBO # 553499
(617) 566-3670

CERTIFICATE OF SERVICE

I, J. Whitfield Larrabee, hereby certify that I served a copy of this complaint together with
a completed and signed grievance form upon the Office of Lawyer Regulation by fax and first
class mail on February 27, 2017.

______________________________
J. Whitfield Larrabee

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