LAW OFFICES OF

J . W HITFIELD L ARRABEE
TRIAL AND APPELLATE LAWYERS
251 HARVARD STREET, SUITE 9
BROOKLINE, MASSACHUSETTS 02445

TELEPHONE: (857) 991-9894

WWW.LARRABEELAW.COM
JWLARRABEE@VERIZON.NET

June 14, 2018

Hon. Rod J. Rosenstein

Deputy Attorney General
U.S. Department of Justice
950 Pennsylvania Avenue NW
Washington, D.C. 20530-0001

Re: Request to Appoint a Special Counsel

Dear Deputy Attorney General Rosenstein:

This is a request under 28 C.F.R. § 600.1 to appoint a Special Counsel to conduct a

criminal investigation of Donald J. Trump and his campaign, Donald J. Trump for President, Inc.
I am delivering this request to you because Attorney General Sessions has recused himself from
matters concerning the Trump campaign and § 600.1 provides that you as the Acting Attorney
General are responsible for determining whether appointing a Special Counsel is warranted.

The Attorney General of the State of New York filed the enclosed verified petition today
in the Supreme Court of the State of New York describing how “Mr. Trump used charitable
assets to pay off legal obligations of entities he controlled, to promote Trump hotels, to purchase
personal items, and to support his presidential campaign.” (emphasis supplied). The accusation
that charitable funds were used to support Mr. Trump’s presidential campaign were supported by
an email from Trump’s campaign manager Corey Lewandowski directing that charitable funds be
used for political purposes. Emails gathered by the New York Attorney General and described in
the complaint “show extensive coordination between the [Trump] Campaign and the [Trump]
Foundation.” The receipt and expenditure of charitable funds by the campaign was prohibited by
the Internal Revenue Code and they were not disclosed to the Federal Election Commission in
violation of the Federal Election Campaign Act. The petition and records of the Federal Election
Commission provide probable cause to believe that Mr. Trump, Mr. Lewandowski, and others
participants criminally violated the Federal Election Campaign Act and the Internal Revenue
Code. There is also reasonable suspicion or probable cause to believe that other federal laws
prohibiting wire fraud, mail fraud and criminal conspiracy were violated.
Hon. Rod J. Rosenstein
Deputy Attorney General
June 14, 2018
Page 2 of 2

The investigation or prosecution of Mr. Trump or Donald J. Trump for President, Inc. by
a United States Attorney's Office or litigating Division of the Department of Justice would
present a conflict of interest for the Department and is an extraordinary circumstance where it is
in the public interest to appoint an outside Special Counsel to assume responsibility for the
matter.

Thank you for your time and consideration of this matter.

Very truly yours,

J. Whitfield Larrabee

JWL/hg
Enclosure