Beruflich Dokumente
Kultur Dokumente
J . W HITFIELD L ARRABEE
TRIAL AND APPELLATE LAWYERS
251 HARVARD STREET, SUITE 9
BROOKLINE, MASSACHUSETTS 02446
Enclosed for filing please find a disciplinary complaint and grievance form concerning
professional misconduct by attorney Reince Priebus, a member of the Wisconsin bar.
J. Whitfield Larrabee
Enclosures
JWL/hg
OFFICE OF LAWYER REGULATION
WISCONSIN SUPREME COURT
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
officials.
2. Priebus is a lawyer admitted to practice law before the Courts of Wisconsin. As a lawyer
Supreme Court Rules (SCR), Chapter 20. He is presently employed as the Chief of
3. It is a violation of SCR 20:8.4 (b) for a lawyer to commit a criminal act that reflects
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
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
6. The Federal Campaign Finance Act, 52 U.S.C. 3012, prohibits the solicitation or receipt
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
7. The Foreign Agents Registration Act, 22 U.S.C. 611 et. seq., requires individuals acting
with the Justice Department and to publicly disclose their identities, activities and
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
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
statutes.
10. While FBI investigations were occurring, on or about February 15, 2017, Priebus
corruptly contacted and communicated with FBI Deputy Director Andrew McCabe
with McCabe, Priebus corruptly communicated with FBI Director James Comey
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
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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
its nature or progress, including such things as the issuance or serving of a subpoena,
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
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
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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
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
18. There is probable cause to establish that the purpose of Priebus contact with the FBI was
19. 18 U.S.C. 1503, the United States obstruction of justice statute, makes it a crime for any
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,
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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,
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
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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