CONGRESSMAN
PASCRELL
‘November 20, 2020
State of New York Grievance Committee for the
Second, Eleventh & Thirteenth Judicial Districts
Renaissance Plaza
335 Adams Street, Suite 2400
Brooklyn, New York 11201-3745
To Whom It May Concern:
J write you today to file a complaint against Rudolph W. Giuliani (New York Supreme Court
Identification No, 1080498). In his capacity as a public spokesman and attomey representing the
presidential campaign of Donald Trump, Mr. Giuliani has participated in frivolous lawsuits and
used our nation’s courts to assault public confidence in the United States electoral system, violating
the New York Rules of Professional Conduct. Therefore, I request your office commence an
immediate investigation of his actions and consider sanctions for his conduct up to and including
revocation of Mr. Giuliani’ s licenses to practice law in your jurisdiction
As of today, President-elect Joe Biden has won the states of Arizona (by 10,457 votes, or 0.31
percent), Georgia (13,554 votes, or 0.27 percent), Michigan (by 154,187 votes, or 2.79 percent),
Nevada (by 33.596 votes, or 2.39 percent), and Pennsylvania (81.487, or 1.18 percent) by margins
virtually uncertain to be reversed by any recounts.’ Despite the difficult circumstances of this
pandemic, these states’ administration of their elections were strong and there is no evidence of
systematic malfeasance or fraud in any of them. Nevertheless, Mr. Giuliani has participated in the
filing a series of absurd lawsuits seeking to overturn the will of the voters in these states and has
caused irreversible damage to public trust in the fair administration of our electians
The New York Rules of Professional Conduct necessarily govern the actions of your licensed
attorneys. Mr. Giuliani has violated Rule of Professional Conduct 3.1 which requires that “[a]
lawyer shall not bring or defend a proceeding, or assert or controvert an issue therein, unless there
a basis in law and fact for doing so that is not frivolous.” Mr. Giuliani has also violated Rule
8.4(c) which posits that it is professional misconduct for a lawyer “to engage in conduct involving
dishonesty, fraud, deceit, or misrepresentation."*
We live together in extraordinary and increasingly dangerous national circumstances. At present,
our sitting President has refused to accept the outcome of our national election and is attacking the
2 https://uselectionatlas.org/RESULTS/
* See https://www.nycourts.gov/LegacyPDFS/rules/jointappellate/NY-Rules-Prof-Conduct-1200.pat
* https:// www nycaurts.gov/LegacyPDFS/rules/jointappellate/NY-Rules-Prof-Conduct-1200.pdfintegrity of our electoral system to keep himself in power. The egregious pattern of behavior by
Mr. Giuliani to effectuate Mr. Trump’s sinister arson is a danger not just to our legal system but is
also unprecedented in our national life. In carrying out that perversion, Mr. Giuliani has clearly
violated the New York Rules of Professional Conduct he swore to uphold and should face the
severest sanction your body can mete out: revocation of his law licensure, The holding of a law
license is a sacred responsibility. You have an opportunity here to make a powerful statement in
support of our democracy and deter future charlatans and miscreants from warping our legal and
political systems for their own profit. Thank you for your prompt attention to this matter
Bill Pascrell, Jr
United States Congressman