UNITED STATES HOUSE OF REPRESENTATIVES

OFFICE OF CONGRESSIONAL ETHICS

THE DEMOCRATIC COALITION, )

SCOTT DWORKIN, JON COOPER and )
J. WHITFIELD LARRABEE )
Complainants )
)
)
v. ) COMPLAINT
)
REPRESENTATIVE MATTHEW GAETZ )
Member )
)

INTRODUCTION

1. This is a complaint against Matthew Gaetz (“Gaetz”), a Member of the House of

Representatives. Gaetz violated the House Code of Official Conduct (House Rule 23,
clauses 1 and 2) by attempting to obstruct justice and intimidate a witness, Michael
Cohen (“Cohen”), in his testimony before the House of Representatives.

PARTIES

2. The complainant Democratic Coalition is a nationwide political action committee

working to promote democracy and the rule of law. It is headquartered in Washington,
D.C..

3. The complainant Jon Cooper is an individual. He is chairman and co-founder of the

Democratic Coalition. He resides in New York.

4. The complainant Scott Dworkin is an individual and co-founder of the Democratic

Coalition. He resides in Washington, D.C..

5. The complainant, J. Whitfield Larrabee, is an attorney licensed to practice law in the

Commonwealth of Massachusetts. He is a citizen of the United States. His address is
229 Harvard Street, Brookline, Massachusetts 02446.

6. Gaetz is a Member of the United States House of Representatives presently representing

Florida’s 1st Congressional district. He has served in Congress since 2017.

FACTUAL AND LEGAL BASIS FOR THE COMPLAINT

7. President Donald Trump’s former fixer and personal attorney was scheduled to give
testimony on February 27, 2019 in the House of Representatives.
8. On Tuesday, February 26, 2019, Florida Rep. Matt Gaetz sent the following tweet to
Donald Trump’s former fixer Michael Cohen:

Hey @MichaelCohen212 - Do your wife & father-in-law know

about your girlfriends? Maybe tonight would be a good time for
that chat. I wonder if she’ll remain faithful when you’re in prison.
She’s about to learn a lot...

— Matt Gaetz (@mattgaetz) February 26, 2019

9. In threatening to expose embarrassing facts about Cohen on the eve of Cohen’s public
testimony about criminal activity involving Donald Trump, Gaetz engaged in an attempt
to intimidate a witness, an attempt to obstruct justice, and an attempt to interfere with the
proceedings of the House of Representatives.

10. 18 U.S.C. § 1512(b) prohibits using intimidation or threats in an attempt to influence,

delay or prevent the testimony of any person in an official proceedings. Violation of this
section may be punished by up to 20 years imprisonment. 18 U.S. Code § 1505 prohibits
obstructing or attempting to obstruct the investigations and proceedings of the House of
Representatives and its committees by any threatening communication.

11. By attempting to intimidate a witness and to obstruct justice, in violation of § 1505 and §
1512(b), Gaetz violated the House Code of Official Conduct, House Rules 23, clauses 1
and 2. Clauses 1 and 2 provide:

1. A Member, Delegate, Resident Commissioner, officer, or

employee of the House shall behave at all times in a manner that
shall reflect creditably on the House.

2. A Member, Delegate, Resident Commissioner, officer, or

employee of the House shall adhere to the spirit and the letter of
the Rules of the House and to the rules of duly constituted
committees thereof.

12. Gaetz’s threatening and intimidating tweet at Cohen was a criminal and unethical act that
did not reflect creditably on the House in violation of Clause 1 and otherwise violated the
spirit and letter of the Rules of the House.

2
 WHEREFORE, the complainants demand:

A. that the Office of Congressional Ethics review and investigate this complaint;
B. that the Office of Congressional Ethics issue and publicly release a report
concerning this complaint;
C. that the Office of Congressional Ethics refer the matter to the House Ethics
Committee for appropriate action; and,
D. such other relief as is just, lawful, equitable or proper.

I affirm that to the best of my knowledge and ability all evidence submitted was not
obtained in violation of any law, rule, or regulation. I acknowledge that Section 1001 of title 18
of the United States Code (popularly known as the False Statements Act) applies to the
information provided.

Scott Dworkin

I affirm that to the best of my knowledge and ability all evidence submitted was not
obtained in violation of any law, rule, or regulation. I acknowledge that Section 1001 of title 18
of the United States Code (popularly known as the False Statements Act) applies to the
information provided.

Jon Cooper

I affirm that to the best of my knowledge and ability all evidence submitted was not
obtained in violation of any law, rule, or regulation. I acknowledge that Section 1001 of title 18
of the United States Code (popularly known as the False Statements Act) applies to the
information provided.

J. Whitfield Larrabee
Law Office of J. Whitfield Larrabee
229 Harvard Street
Brookline, MA 02446
jw.larrabee@verizon.net
(857) 991-9894