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Bondy Letter to Barr Requesting Barr's Recusal from Parnas Investigation/Prosecution Whistleblower Complaint on Ukraine (Kelly Smith, comp.) 1 (1/20/2020)

handle is hein.presidents/usgvtwht0314 and id is 1 raw text is: 
Case  1:19-cr-00725-JPO Document 73-1 Filed 01/20/20 Page 1 of 38

                                   THE  LAW   OFFICES   OF

                  JOSEPH A. BONDY

 JOSEPH A. BONDY                                                 1776 BROADWAY
                                                                 SUITE 2000
 STEPHANIE SCHUMAN                                               NEW  YORK NY  10019
 (OF COUNSEL)                                                    TEL 212.219.3572
                                                                 FAX 212.219.8456


                                                  January  20, 2020

 :B Flax: 102 307-6777    Id M  il)
 William P Barr
 Attorney General
 United States Department of Justice
 950 Pennsylvania Ave NW
 Washington, DC  20530

        Re:    Reque t for RecusaL Lev Pai s

Dear Attorney General Barr,

       We  are counsel to Lev Parnas regarding the Federal Election Act charges for which he is under
indictment in the Southern District of New York and the investigation of his alleged involvement in the
subject matter of the Presidential impeachment. As explained below, due to the conflict of interest of your
being involved in these matters as Attorney General, and in an effort to preserve the public trust in the
rule of law, we request that you recuse yourself and allow the appointment of a special prosecutor from
outside the Department of Justice to handle this case.

       The  public record is replete with requests for your recusal, the reasons for that request, and public
outcry that you have not. Federal ethics guidelines bar federal employees from participating in matters in
which their impartiality could be questioned, including matters in which they were personally involved or
about which they have personal knowledge. 5 CER. § 2635.502; Justice Manual § 1-4.020.

       TheJuly 25, 2019 transcript of President Trump's call with Ukrainian President Volodymyr
Zelensky contains multiple references to you, alone and in conjunction with the President's attorney,
Rudolf Giuliani, as being the point person for the Zelensky administration to work with in commencing
an investigation into the President's chief political rival, Joe Biden. (Exhibit A).

       In the August 12, 2019, whistleblower complaint, you were personally named as a participant in
the President's abuse of the power of his office to solicit interference with the government of Ukraine in
connection with the 2020 election, including pressuring Ukraine to investigate one of the President's
political opponents, Joe Biden. (Exhibit B).

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