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LAW OFFICES OF

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

TELEPHONE: (617) 566-3670


WWW.LARRABEELAW.COM
JWLARRABEE@LARRABEELAW.COM

July 4, 2017

Honorable Robert S. Muller, III, Special Counsel


U.S. Department of Justice
950 Pennsylvania Avenue, NW
Washington, DC 20530-0001

Honorable Channing D. Phillips


United States Attorney for the District of Columbia
United States Attorney's Office
555 4th Street, NW
Washington, DC 20530

Honorable Raymond Hulser, Chief, Public Integrity Section


U.S. Department of Justice, Criminal Division
950 Pennsylvania Avenue, NW
Washington, DC 20530-0001

Re: Foreign National Donor Scheme and Straw Donor Scheme Involving Representative
Dana Rohrabacher, Representative Edward Royce, Senator Jim Risch, Lobbyist Paul
Manafort, Lobbyist John Vincent Weber, Lobbyist Edward Kutler, Lobbyist Michael
McSherry, et al.

Dear Special Counsel Muller, Public Integrity Chief Hulser and U.S. Attorney Phillips:

Enclosed please find a complaint against Representative Dana Rohrabacher and


Representative Edward Royce filed today with the House of Representatives Office of
Congressional Ethics. I request that the Department of Justice investigate the complaint as it
concerns a scheme to illegally contribute funds from foreign nationals to candidates for federal
office. The complaint also describes an illegal straw donor scheme. One of the lobbyists who
participated in the scheme, Paul J. Manafort, Jr., is reportedly under investigation by the office of
Special Counsel. Since there are potential links to the Russia investigation, I have requested the
Special Counsel to investigate the matter. The complaint concerns illegal activities of lobbyists
and unregistered foreign agents in Washington, D.C. that are likely within the purview of U. S.
Attorney Phillips. Finally the complaint concerns criminal activity by elected officials and
therefore may fall within the purview of the Public Integrity Section.
Honorable Robert S. Muller, III, Special Counsel
Honorable Channing D. Phillips, U.S. Attorney
Honorable Raymond Hulser, Chief, Public Integrity Section
July 4, 2017
Page 2 of 2

Although the complaint describes the illegal acceptance of contributions by Members of


the House of Representatives, the criminal scheme extended to the United States Senate. Jim
Risch is an Idaho Senator who served on the Senate Foreign Relations Committee in 2013.
Three lobbyists from Mercury Public Affairs met with Senator Risch on November 13, 2013.
The lobbyists were John Vincent Weber, Edward Kutler and Michael McSherry. The purpose of
the meeting was to lobby on behalf of the European Centre for a Modern Ukraine (ECFMU) a
foreign national. These facts were disclosed in Mercurys registration statement under the
Foreign Agents Registration Act that it recently filed. On December 4, 2013, according to
Mercurys statement and Federal Election Commission (FEC) records, Weber, Kutler and
McSherry each contributed $1,000 to the Jim Risch for U. S. Senate Committee. Mercury was
reimbursed for the lobbyists contributions between March 31, 2014 and April 7, 2014, when the
ECFMU paid Mercury over $218,000 in fees and reimbursement. Risch accepted the
contributions, knowing that they were paid through a straw, and that the funds came from the
ECFMU, or other foreign nationals of Ukrainian or Russian origin who where laundering money
though the ECFMU. 52 U.S.C. 30121 prohibits the giving and receiving of contributions from
foreign nationals. 52 U.S.C. 30122 prohibits the giving and receiving of contributions made by
one person in the name of another. By receiving and accepting the contributions, Risch
knowingly and willfully violated 52 U.S.C. 30121 and 30122.

It is likely that other Senators, Representatives, lobbyists, foreign agents and foreign
nationals also participated in this expansive criminal scheme.

As the five year statute of limitations for filing criminal charges against many of the
individuals participating in the scheme may pass shortly, I respectfully request that the
Department of Justice conduct an expedited investigation of the activities described in the
complaint and in this letter.

Thank you for your time and consideration of these matters.

Very truly yours,

J. Whitfield Larrabee

JWL/hg
Enclosure

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