f@™ STATE BAR OF GEORGIA ES GRIEVANCE CONFIDENTIAL PLEASE TYPE OR PRINT LEGIBLY IN BLACK INK ONLY DO NOT ALTER THIS FORM YOUR NAME: (Mrntrs/Ms) _J- WHITFIELD LARRABEE 14 SEARLE AVENUE BROOKLINE Ma, 244s Tate 7 MAILING ADDR Sieet or PO. Bow ‘YOUR PHONE NUMBERS: (Ww) _(657) 991-9894 “ DI NAME OF THE ATTORNEY: __SHERIA DILLON ‘io a separ Tr or each allomey, Do not ist Taw Hrs MORGAN LEWIS, 1111 PENNSYLVANIA AVENUE, NW, WASHINGTON, DC 20004-2541 ADDRESS OF THE ATTORNEY DATE OF FIRST CONTACT WITH ATTORNEY: NA DATE OF LAST CONTACT WITH ATTORNEY: Lina DOES THIS ATTORNEY CURRENTLY REPRESENT YOU? YES NOG WAS THIS YOUR ATTORNEY? YES NOG ISYOURCASE: CRIMINALO CIVILD CASES ee Coonry, eee ____ OR FEDERAL DISTRCTT: NORTHERN MIDDLE. SOUTHERN CLEARLY DESCRIBE YOUR COMPLAINT AND ATTACH SUPPORTING DOCUMENTS: ‘See tached complaint and supporting documents fmore space is needed, please attach other pages. Please do not write on the back. Return to: State Bar of Georgia “afr that have read and understand he infomation and nsractons. GaeeCoa ea ‘The afomaton have provided hae su the aot my Knledge” 104 Marietta St. NW, Suite 100 SIGNATURE: GJ Drager acuaben Atlanta, GA 30303 DATE: Rpefzalq OPTIONAL: PLEASE PROVIDE THE NAME AND PHONE NUMBER OF SOMEONE WE CAN CONTACT IF WE HAVE DIFFICUTLTY CONTACTING YOU. NAME OF CONTACT PERSON: PHONE NUMBERS OF CONTACT PERSON: (W) __ —_ —— Revised 05.05.16J, WHITFIELD LARRABEE v. SHERI A. DILLON STATE BAR OF GEORGIA COMPLAINT AGAINST AN ATTORNEY Sheri A. Dillon (“Dillon”) is an attomey licensed to practice law in Georgia. In representing her client, Donald J. Trump (“Trump”), Dillon violated Rule 8.4(a)(4) of Georgia Rules of Professional Conduct that provides that a lawyer shall not “engage in professional conduct involving dishonesty, frand, deceit or misrepresentation.” As described in the attached letter written by Representative Elijah Cummings, Dillon engaged in dishonesty, fraud, deceit or misrepresentation, and assisted Trump in engaging in such behavior, by repeatedly making false and misleading statements to the United States Office of Government Bthies. Dillon and Trump repeatedly made false statements about Trump's reimbursement of hush money paid out by Attomey Michael Cohen to adult film star Stormy Daniels and about other payments to Michael Cohen. Dillon violated Rule 3.4 (b)(2) by aiding, abetting, counseling and assisting Trump to testify falsely. Rule 3.4 (b\(2) provides that a lawyer shall not “counsel or assist a witness to testify falsely.” Dillon violated Rule 3.3 by making false statements of material fact to the Office of Government Ethics. Rule 3.3 provides in relevant part: (@) A lawyer shall not knowingly: (1) make a false statement of material fact or law to a tribunal;(2) fail to disclose a material fact to a tribunal when disclosure is necessary to avoid assisting a criminal or fraudulent act by the client; (3) fail to disclose to the tribunal legal authority in the controlling jurisdiction known to the lawyer to be directly adverse to the position of the client and not disclosed by opposing counsel; or (4) offer evidence that the lawyer knows to be false. If a lawyer has offered ‘material evidence and comes to know of its falsity, the lawyer shall take reasonable remedial measures. In making false statements to the Office of Government Ethics, concealing and covering up the scheme involving Michael Cohen, Trump and Dillon, acting in concert, violated and conspired to violate 18 U.S.C. § 1001. 18 U.S.C. § 1001 provides in relevant part: (a) Except as otherwise provided in this section, whoever, in any matter within the jurisdiction of the executive, legislative, or judicial branch of the Government of the United States, knowingly and willfully— (1) falsifies, conceals, or covers up by any trick, scheme, or device a material fact; (2) makes any materially false, fictitious, o fraudulent statement or representation; or G) makes or uses any false writing or document knowing the same to contain any ‘materially false, fictitious, or fraudulent statement or entry; shall be fined under this title, imprisoned not more than 5 years or, if the offense involves international or domestic terrorism (as defined in section 2331), imprisoned not more than 8 years, or both. Ifthe matter relates to an offense under chapter 109, 109B, 110, or 117, or section 1591, then the term of imprisonment imposed under this section shall be not more than 8 years. Dillon violated the Georgia Rules of Professional Conduct by interfering with the investigation of the Office of Government Ethics and proper administration of justice by the OGE.