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Page 3 of 4 
10. 
At all relevant times, the Office had approximately 20 Assistant U.S. 
Attorneys assigned to the West Palm Beach location. The prosecutor assigned 
to the Epstein case, I
I end I were assigned to different 
sections within the Office. We reported to different supervisors. 
11. 
I did not participate in any way in the Office's investigation of Epstein. I was 
not involved in any of the Office's decisionmalcing with regard to the Epstein 
matter. 
12. 
I never learned any confidential, non-public information about the Epstein 
matter. 
13. 
In late December 2007, I had an "exit meeting" with Dexter Lee, the Office's 
ethics officer. As part of that meeting, Mr. Lee reviewed with me the 
Department of Justice's post-employment restrictions. 
Based on our 
conversation, it was my understanding that I could work on any matter so long 
as I had not participated in it personally and substantially as a government 
employee. I also understood that I could not use non-public Government 
information for any purpose. 
14. 
After opening my private practice on January 2, 2008, I was retained to 
represent 
r purposes of civil depositions in causes of action to 
which the United States was not a party. At a later time, I was retained to 
represent several other members of Mr. Epstein's staff in their civil 
depositions. 
I5.. 
After leaving the Office, I did not participate in any of the negotiations over 
Mr. Epstein's non-prosecution agreement 
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Page 4 of 4 
16. 
After leaving the Office, I did not communicate with the Office, in person or 
in writing, about any matters relating to possible criminal charges against Mr. 
Epstein. 
17. 
Because I did not have any, I did not share non-public confidential 
information about the Epstein investigation with any of Epstein's attorneys. 
18. 
Prior to the filing of Plaintiff's Motion for Finding of Violations of the Crime 
Victims' Rights Act, neither Mr. Edwards, nor Judge Cassell, nor anyone on 
their behalf contacted me to determine if the allegations in Paragraphs 52 and 
53 of that Motion were true. 
I declare under penalty of perjury that the foregoing is true and correct. 
Executed on May 3, 2011. 
Brace E. Reinhart 
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EXHIBIT 2 
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§ 2641.201 Parrnanent restriction on any former employee's..., 5 C.F.Ft. § 2641.201 
Code of Federal Regulations 
Title 5. Administrative Personnel 
Chapter XVI. Office of Government Ethics 
Subchapter B. Government Ethics 
Part 2641. Post-Employment Conflict of Interest Restrictions (Refs & Annos) 
Subpart B. Prohibitions 
5 C.F.R. § 2641.201 
§ 2641.201 Permanent restriction on any former employee's representations to United States 
concerning particular matter in which the employee participated personally and substantially. 
Effective July 25, 2008 
Currentness 
• 
(a) Basic prohibition of 18 U.S.0 207(a)(l). No former employee shall knowingly, with the intent to influence, make any 
communication to or appearance before an employee of the United States on behalf of any other person in connection with a 
particular matter involving a specific party or parties, in which he participated personally and substantially as an employee, and 
in which the United States is a party or has a direct and substantial interest 
(b) Exceptions and waivers, The prohibition of 18 U.S.C. 207(aX1) does not apply to a former employee who is: 
(1) Acting on behalf of the United Staves. See § 2641.301(a). 
(2) Acting as an elected State or local government official. See § 2641.301(b). 
(3) Communicating scientific or technological information pursuant to procedures or certification. See § 2641.301(e). 
(4) Testifying under oath. See § 2641.3010). (Note that this exception from § 2641.201 is generally not available for expert 
testimony. See § 2641.301(1)(2).) 
(5) Acting on behalf of an international organization pursuant to a waiver. See § 2641.301(h). 
(6) Acting as an employee of a Government-owned, contractor-operated entity pursuant to a waiver. See § 2641.301(1). 
(c) Commencement and length of restricfion. 18 U.S.C. 207(aX I) is a pennenent restriction that commences upon an employee's 
termination from Government service. The restriction lasts for the life of the particular matter involving specific parties in 
which the employee participated personally and substantially. 
(d) Communication or appearance—
(1) Communication. A former employee makes a communication when he imparts or tranamits information of any kind, 
including facts, opinions, ideas, questions or direction, to an employee of the United States, whether orally, in written 
correspondence, by electronic media, or by any other means. This includes only those communications with respect to 
which the loaner employee intends that the information conveyed will be attributed to himself, although it is not steamy 
that any employee of the United States actually recognize the former employee as the source of the information. 
(2) Appearance. A former employee makes an appearance when he is physically present before an employee of the United 
Slates, in either a formal or informal setting. Although an appearance also may be accompanied by certain communications, 
an appearance need not involve any communication by the former employee. 
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§ 2641.201 Permanent restriction on any former empioyee's_., a C.F.R. § 2641.201 
(3) Behind-the-scenes assistance. Nothing in this section prohibit a former employee from providing assistance to another 
person, provided that the assistance does not involve a communication to or an appearance before an employee of the 
United States. 
Example 1 to paragraph (d): A former employee of the Federal Bureau of Investigation makes a brief telephone call to a.
colleague in her former office concerning an ongoing investigation. She has made a communication. If she personally attends 
an informal meeting with agency personnel concerning the matter, she will have made an appearance. 
Example 2 to paragraph (d): A former employee of the National Endowment for the Humanities (NEH) accompanies other 
representatives of an NEH grantee to a meeting with the agency. Even if the former employee does not say anything at the 
meeting, he has made an appearance (although that appearance may or may not have been made with the intent to influence, 
depending on the circumstances). 
Example 3 to paragraph (d): A Government employee administered a particular contract fix agricultural research with Q 
Company. Upon termination of ha Government employment, she is hired by Q Company. She works on the matter covered by 
the contact, but has no direct contact with the Government. At the request of a company vice president, she prepares a paper 
describing the persons at ha former agency who should be contacted and what should be said to them in an effort to increase 
the scope of funding of the contact and to resolve favorably a dispute over a contract clause She may do so. 
Example 4 to paragraph (d): A firmer employee of the National Institutes of Health (NIN) prepares an application for an NIH 
research grant on behalf of her university employer. The application is signed and submitted by another university officer, but it 
lists the loaner employee as the principal investigator who will be responsible for the substantive work under the grant. She has 
not made a communication. She also may sign an assurance to the agency that shewill be personally responsible for the direction 
and conduct of the research under the grant, pursuant to § 264 l.201(e)(2Xiv). Moreover, she may personally communicate 
scientific or technological information to NIB concerning the application, provided that she does so under circumstances 
indicating no intent to influence the Government pursuant to § 2641.20I(eX2) or she makes the communication in accordance 
with the exception for scientific or technological information in § 2641.301(e). 
Example 5 to paragraph (d): A former employee established a small government relations firm with a highly specializedpractice 
in certain environmental compliance issues. She prepared a report for one of her clients, which she knew would be presented 
to her former agency by the client. The report is not signed by the former employee, but the document does bear the name 
of her firm. The former employee expect that it is commonly known throughout the industry and the agency that she is the 
author of the report If the report were submitted to the agency, the former employee would be making a oonununication and not 
merely confining herself to behind-the-scenes assistance, because the cimumstanoes indicate that she intended the information 
to be attributed to herself. 
(e) With the intent to influence—
)Basic concept The prohibition applies only to communications or appeal-wan made by a former Government employee 
with the intent to influence the United States. A communication or appearance is made with the intent to influence when 
made for the purpose of. 
(i) Seeking a Government ruling, benefit, approval, or other discretionary Government action; or 
(ii) Affecting Government action in connection with an issue or aspect of a matter which involves an appreciable element 
of actual or potential dispute or controversy. 
Example 1 to paragraph (e)(1): A former employee of the Administration on Children and Families (ACF) signs a grant 
application and submits it to ACE on behalf °fa nonprofit organization for which she now works. She has made a communication 
with the intent to influence an employee of the United States because her communication was made for the purpose of seeking 
a Government benefit. 
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Example 2 to paragraph (e)(l): A former Government employee calls an agency official to complain about the auditing methods 
being used by the agency in conr.ection with an audit of a Government contractor for which the former employee serves as 
a consultant. The former employee has made a communication with the intent to influence because his call was made for the 
purpose of seeking Government action in connection with an issue involving an appreciable element of dispute. 
(2) Intent to influence not present. Certain communications to and appearances before employees of the United States are 
not made with the intent to influence, within the meaning of paragraph (e)(I) of this section, including, but not limited to, 
communications and appearances made solely for the purpose of: 
(i) Making a routine request not involving a potential controversy, such as a request for publicly available documents or 
an inquiry as to the status of a matter; 
(ii) Making factual statements or asking factual questions in a context that involves neither an appreciable element of 
dispute nor ar. effort to seek discretionary Government action, such as conveying factual information regarding matters 
that are not potentially controversial during the regular course of performing a contract; 
(iii) Signing and filing the tax return of another person as preparet; 
(iv) Signing an assurance that one will be responsible as principal investigator for the direction and conduct of research 
under a Federal grant (see example 4 to paragraph (d) of this section); 
(v) Filing a Securities and Exchange Commission (SEC) Porn 10-K or similar disclosure forms required by the SEC; 
(vi) Making a communication, at the initiation of the Government, concerning work performed or to be performed under a 
Government contract or grant, during a routine Government site visit to premises owned or occupied by a person other than 
theUnited States where the work is performed or would be performed, in the ordinary course of evaluation, administration, 
or performance of an actual or proposed contract or gran or 
(vii) Purely social contacts (see example 4 to paragraph (0 of this section). 
Example Ito paragraph (e)(2): A former Government employee calls an agency to ask for the dam ofa scheduled public hearing 
on her client's license application. This is a routine request not involving a potential controversy and is not made with the intent 
to influence. 
Example 2 to paragraph (e)(2): In the previous example, the agency's hearing calendaris quite frill, as the agency has a significant 
backlog of license applications. Tae former employee calls a Conner colleague at the agency to ask if the hearing date for her 
client could be moved up on the schedule, so that her client can move forward with its business plans more quickly. This is a 
communication made with the intent to influence. 
Example 3 to paragraph (e)(2): A former employee of the Department of Defense (DOD) now works for a firm that has a DOD 
contract to produce an operator's manual for a radar device used by DOD. In the coarse of developing a chapter about certain 
technical features of the device, the former employee asks a DOD official certain factual questions about the device and its 
properties. The discussion does rot concern any matter that is known to involve a potential controversy between the agency 
and the contractor. The former employee has not made a communication with the intent to influence. 
Example 4 to paragraph (e)(2): A former medical officer of the Food and Drug Administration (FDA) sends a letter to the 
agency in which he sets out certain data from safety and efficacy test on a new drug for which his employer, ABC Drug Co., 
is seeking FDA approval. Even if the letter is confined to arguably "factual" matters, such as syncpses of data from clinical 
trials, the communication is made for the purpose of obtaining a discretionary Government action, i.e., approval of a new drug. 
Therefore, this is a communication made with the intent to influence. 
Example 5 to paragraph (eX2): A former Government employee now works for a management consulting firm, which has • 
Government contract to produce a study on the efficiency of certain agency operations. Among other things, the contract calls 
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§ 2641.201 Permanent restrle0on on any former employee's..., 5 O.F.R. § 2641.201 
for the contractor to develop a range of alternative options for potential restructuring of certain internal Government procedures. 
The former employee would like to meet with agency representatives to present a tentative list of options developed by the 
contractor. She may not do so. There is a potential for controversy between the Government and the contractor committing the 
extent and adequacy of any options presented, and, moreover, the oor.tractor may have its own interest in emphasizing certain 
options as opposed to others because some options may be more difficult and expensive for the contractor to develop fully 
than others. 
Example 6 to paragraph (eX2): A former employee of the Internal Revenue Service (IRS) prepares his client's tax return, signs 
it as prepare:, and mails it to the IRS. He has not made a communication with the intent to influence. In the event that any 
controversy should arise concerning the return, the former employee may not represent the client in the proceeding, although 
he may answer direct factual questions about the records be used to compile figures for the return, provided that he does not 
argue any theories or positions tojustify the use of ore figure rather than another. 
Example 7 to paragraph (eX2): An agency officialvisitsthepremises of a prospective contractor to evahmte the testing procedure 
being proposed by the contractor for a research contract on which it has bid. A former employee of the agency, now employed 
by the contractor, is the person most ferniliar with the technical aspects of the proposed testing procedure. The agency official 
asks the former employee about certain technical features of the equipment used in connection with the testing procedure. The 
former employee may provide factual information that is responsive to the questions posed by the agency official, as such 
information is requested by the Government under circumstances for its convenience in reviewing the bid. However, the former 
employee may not argue for the appropriateness of the proposed testing procedure or otherwise advocate any position on behalf 
of the contractor. 
(3) Change in circumstances. If, at any time during the course of a communication or appearance otherwise permissible 
under paragraph (e)(2) of this section, it becomes apparent that circumstances have changed which would indicate that 
any further communication or appearance would be nude with the intent to influence, the former employee must refrain 
from such further communication or appearance. 
Example 1 to paragraph (eX3): A former Government employee accompanies another employee of a contractor to a routine 
meeting with agencyofficials to deliver technical data called for under a Government contract. During the course of the meeting. 
an unexpected dispute arises concerning certain terms of the contract. The former employee may cotparticipate in anydiscussion 
of this issue. Moreover, if the oitvumstances clearly indicate that even her continued presence during this discussion would be 
en appearance made with the intent to influence, she should excuse herself from the meeting. 
(4) More physical presence intended to influence. Under some circumstances, a former employee's mere physical Presence, 
without any communication by the employee concerning any material issue or otherwise, may constitute an appearance 
with the intent to influence an employee of the United States. Relevant considerations include such factors as whether. 
(i) The former employee has been given actual or apparent authority to make any decisions, commitments, or substantive 
arguments in the course of the appearance; 
(I i)The Comment employee before whom the appearance is made has substantive responsibility for the matter and does 
not simply perform ministerial functions, such as the acceptance of paperwork; 
(ii) The former employee's presence is relatively prominent; 
(iv) The former employee is paid for tasking the appearance; 
(v) It is anticipated that others present at the meeting will make reference to the views or past or present work of the 
former employee; 
(vi) Circumstances do not indicate that the former employee is present merely for informational purposes, for example, 
merely to listen and record information for later use; 
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§ 21141.201 Permanent restriction on any former employes's—, 5 C.F.R. § 2841201 
(vii)Thefonner employee has entered a formal appearance in connection withalegal proceeding at which he is present and 
(viii) The appearance is before former subordinates or others in the same chain of command as the former employee. 
Example Ito paragraph (e)(4): A formerRegional Administrator ofthe Occupational Safety and Health Administration (OSHA) 
becomes a consultant for a company being investigated for possible enforcement baton by the regional OSHA Office. She is 
hired by the company to coordinate and guide its response to the OSHA investigation. She accompanies company officers to 
an informal meeting with OSHA, which is held for the purpose of airing the company's explanation of certain findings in en 
adverse inspection report. The former employee is introduced at the meeting as the company's compliance and governmental 
affairs adviser, but she does not make any statements during the meeting concerning the investigation. She is paid a fee for 
attending this meeting. She has made an appearance with the intent to influence 
Example 2 to paragraph (eXt): A former employee of an agency row works for a manufacturer that seeks agency approval for a 
new product. The agency convenes a public advisory committee meeting for the purpose of receiving expert advice concerning 
the product. Representatives of the manufacturer will make an extended presentation of the data supporting the application for 
approval, and a special table has been reserved for them in the meeting room for this purpose. The former employee does not 
participate in the manufacturer's presentation to the advisory carmine* and does not even sit in the section designated for the 
manufacturer. Rather, he sits in the back of the room in a large area reserved for the public and the media. The manufacturer's 
speakers make no reference to the involvement or views of the former employee with respect to the matter. Even though the 
former employee may be recognized in the audience by certain agency employees, he las not made an appearance with the 
intent to influence because his presence is relatively inconspicuous and there is little to identif}, him with the mannfacturer or 
the advocacy of its representatives at the meeting. 
(I) To or before an employee of the United States—
(1) Employee of the United States. For purposes of this paragraph, an "employee of the United States" means the President, 
the Via President, and any current Federal employee (including an individual appointed as an employee or detailed to the 
Federal Government under the Intergovernmental Personnel Act (5 U.S.C. 3371-3376)) who is detailed to or employed 
by any: 
(i) Agency (including a Government corporation); 
(ii) Independent agency in the executive, legislative, or judicial branch; 
(lil) Federal court or 
(iv) Court-martial. 
(2) To or before. Except as provided in paragraph (0(3) of this section, a communication "to" or appearance "before" an 
employee of the United States is one: 
(i) Directed to and received by an entity specified in paragraphs (f)( WO through (f)(1)(iv) of this section even though 
not addressed to a particular employee, e.g., as when a former employee mails correspondence to an agency but not to 
any named employee; or 
(ii) Directed to and received by an employee in his capacity as an employee of an entity specified in paragraphs )(1) 
(i) through (f)(1)(iv) of this section, e.g., as when a former employee directs remarks to an employee representing the 
United States as a party or intervenor in a Federal or non-Federal judicial proceeding. A former employee does not direct 
bis communication or appearance to a bystander who merely happens to overhear the communication or witness the 
appearance. 
(3) Public conuner.tary. 
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§ 2541.201 Pemsanent restriction on any former employee's—, 5 C.P.R. § 2641.201 
(i)A former employee who addresses a public gathering or a conference, seminar, or similar forum as a speaker or panel 
participant will not be considered to be making a prohibited communication or appearance if the forum: 
(A) Is not sponsored or co
-sponsored by an entity specified in paragraphs (f)(1Xi) through (f)(1Xiv) of this section; 
(B) Is attended by a large number of people; and 
(C) A significant proportion of those attending ate not employees of the United States. 
(ii) In the circumstances described in paragraph (f)(3)(i) of this section, a former employee may engage in exchanges with 
any other speaker or with any member of the audience. 
(iii) A former employee also may permit the broadcast or publication of a commentary provided that it is broadcast or 
appears in a newspaper, periodical, or similar widely available publication. 
Example 1 to paragraph (f): A Federal Trade Commission (FTC) employee participated in the Fit's decision to initiate an 
enforcement proceeding against a particular company. After terminating Government service, the former employee is hired 
by the company to lobby key Members of Congress concerning the necessity of the proceeding. He may contact Members of 
Congress or their staff since a communication to or appearance before such persons is not made to or before an "employee of 
the United States" as that term is defined in paragraph (0(1) of this section. 
Example 2 to paragraph (t): In the previous example, the former FTC employee arranges to meet with a Congressional staff 
member to discuss the necessity of the proceeding. A current FTC employee is invited by the staff member to attend and is 
authorized by the FTC to do so k order to present the agency's views. The former employee may not argue his new employer's 
position at that meeting since his arguments would unavoidably be directed to the FTC employee in hie capacity as an employee 
of the FTC. 
. 
. 
Example 3 to paragraph (0: Tho Department of State granted a waiver pursuant to 18 U.S.C. 208(b)(1) to permit one of its 
employees to serve in his official capacity on the Board of Directors of a private association. The employee participates in a 
Board meeting to discuss what position the association should take concerning the award of a recent contract by the Depanment 
of Energy (DOE). When a former DOE employee addresses the Board to argue that the association should object to the award 
of the contract, she is directing her communication to a Department of State employee in his capacity as an employee of the 
Department of State. 
Example 4 to paragraph (0: A Federal Communications Commission (FCC) employee participated in a proceeding to review 
the renewal of a license for a television station. After terminating Government service, he is hired by the company that holds 
the license. At a cocktail party, the former employee meets his former supervisor who is still employed by the FCC and begins 
to discuss the specifics of the license renewal case with him. The former employee is directing his communication to an FCC 
employee in his capacity as an employee of the FCC. Moreover, as the conversation concerns the license renewal matter, it is 
not a purely social contact and satisfies the element of the intent to influence the Government within the meaning of paragraph 
(e) of this section. 
Example S to paragraph (0: A Federal Trade Commission economist participated in her agency's review of a proposed merge• 
between two companies. After terminating Government service, she goes to work for a trade association that is interested in 
the proposed merger. She would like to speak about the proposed merger at a conference sponsored by the made association. 
The conference is attended by 100 individuals, 50 of whom arc employees of entities specified in paragraphs (TX1X0 through 
(fX1Xiv) of this section. The former employee may speak at the conference and may engage in a discussion of the merits of the 
proposed merger in response to a question posed by a Department of Justice employee in attendance. 
Example 6 to paragraph (f): The former employee in the previous example may, on behalf of her employer, write and permit 
publication of an op-ed piece in a metropolitan newspaper in support of a particular resolution of the merger proposal. 
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§ 2641.201 Permanent restriction on any former employee's_., 5 C.F.R. §2641.201 
Example 7 to paragraph (f): ABC Company has a contract with the. Department of Energy which requires that contractor 
personnel work closely with agency employees in adjoining offices and work stations in the same building. After leaving the 
Department, a former employee goes to work for another corporation that has an interest in performing certain work related to 
the same contract, and he arranges a meeting with certain ABC employees at the building where he previously worked on the 
project_ At the meeting, he asks the ABC employees to mention the interest of his new employer to the project supervisor, who 
is an agency employee. Moreover, he tells the ABC employees that they can say that ho was the source of this information. The 
ABC employees in tuna convey this information to the project supervisor. The former employee has made a comnr.usicati on to 
art employee of the Department of Energy. His communication is directed to an agency employee because he intended that the 
information be conveyed to an agency employee with the intent that it be attributed to himself, and the circumstances indicate 
such a close working relationship between contractor personnel and agency employees that it was likely that the information 
conveyed to contractor personnel would be received by the agency. 
(g) On behalf of any other person—
(1) On behalf of. 
(i) A former employee makes a communication or appearance on behalf of another person if the Conner employee is acting 
as the other person's agent or attorney or if: 
(A)The former employee is acting with the consent of the other person, whether express or implied; and 
(B) The former employee is acting subject to some degree of control or direction by the other person in relation to 
the communication or appearance. 
(ii) A former employee does not act on behalf of another merely because his communication or appearance is consistent 
with the interests of the other pawn, is in support of the other person, or may cause the other person to derive a benefit 
as a consequence of the former employee's activity. 
(2) Any other person. The term "person" is defined in § 2641.104. For purposes of this paragraph, the term excludes the 
former employee himself or any tole proprietorship owned by the former employee. 
Example t to paragraph (g): An employee of the Bureau of Land Management (BIM) participated in the decision to grant ■ 
private company the right to explore for minerals on certain Federal lands After retiring from Federal service to pursue her 
hobbies, the former employee becomes concerned that BLM is misinterpreting a particular provision of the lease. The former 
employee may contact a current BLM employee on her own behalf in order to argue that her interpretation is correct. 
Example 2 to paragraph (g): The former BLM employee torn the previous example later joins an environmental organization 
as an uncompensated volunteer. The leadership of the organization authorizes die former employee to engage in any activity 
that she believes will advance the interests of the organization. She makes a communication on behalf of the organization 
when, pursuant to this authority, she writes to BLM on the organization's letterhead in order to present an additional 
argument concerning the interpretation of the lease provision. Although the colonization did not direct her to sand the specific 
communication to BLM, the circumstances establish that she made the communication with the consent of the organization and 
subject to a degree of control or direction by the organization. 
Example 3 to paragraph (g): An employee of the Administration for Children and Families wrote the statement of work for a 
cooperative agreement to be issued to study alternative workplace arrangements. After terminating Government service, the 
former employee joins a nonprofit group formed to promote family togetherness. He is asked by his former agency to attend a 
meeting in order to offer his recommendations concerning the ranking of the pant applications he had reviewed while still a 
Government employee. The management of the nonprofit group agrees to permit him to take leave to attend the meeting in order 
to present his personal views concerning the ranking of the applications. Although the former employee is a salaried employee 
of the non-ptofit group and his recommendations may be consistent with the group's interests, the circumstances establish that 
he did not make the communication subject to the control of the group. 
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Example 4 to paragraph (g): An Assistant Secretary of Defense participated in a meeting at which a defense contractor pressed 
Department of Defense (DOD) officials to continue lording the contractor's sole source contract to develop the prototype of a 
specialized robot. After terminating Government service, the former Assistant Secretary approaches the contractor and sugges:s 
that she can convince her former DOD colleagues to pursue development of the prototype robot. The contractor agrees that the 
former Assistant Socretatts proposed efforts could be useful and asks her to set up a meeting with key DOD officials for the 
following week. Although the former Assistant Secretary is not an employee of the contractor, the circumstances establish that 
she is acting subject to some degree of control or direction by the contractor. 
(h) Particular matter involving a specific party or panics—
(1) Basic concept The prohibition applies only to communications or appearances made in connection with a "particular 
manor involving a specific party or parties." Although the statute defines "particular matter" broadly to include 
"any investigation, application, request for a ruling or determination, rulemaking, contract, controversy, claim, charge, 
accusation, arrest, or judicial or other proceeding," 18 U.S.C. 207(1)(3), only those particular matters that Involve a specific 
party or parties fall within the prohibition of section 20700(4 Such a matter typically involves a specific proceeding 
erecting the legal rights of the parties or an isolatable transaction or related set of transactions between identified parties, 
such as a specific contract, grant, license, product approval application, enforcement action, administrative adjudication, 
Or COUR Case 
Example I to paragraph (hX1): An employee of the Department of Housing and Urban Development approved a specific citys 
application for Federal assistance for a renewal project. After leaving Government service, she may not represent the city 
in relation to that application as it is a particular matter involving specific parties in which she participated personally and 
substantially as a Government employee. 
Example 2 to paragraph (h)(I): An attorney in the Department of Justice drafted provisions of a civil complaint that is filed in 
Federal court alleging violations of certain environmental laws by ADC Company. The attorney may not subsequent:), represent 
ABC before the Government in connection with the lawsuit, which is a particular matter involving specific parties. 
(2) Matters of general applicability not covered. Legislation or rulemaking of general applicability and the formulation 
of general policies, standards of objectives, or other matters of general applicability are not particular matters involving 
specific parties. International agreements, such as treaties and trade agreements, must be evaluated in light of all relevant 
circumstances to determine whether they should be considered particular matters involving specific parties; relevant 
considerations include such factors as whether the agreement focuses on a specific property or territory, a specific claim, 
or addresses a large number of diverse issues or economic interests. 
Example 1 to paragraph (h)(2): A former employee of the Mine Safety and Health Administration (MSHA) participated 
personally and substantially in the development of a regulation establishing certain new occupational health and safety standards 
for mine workers. Because the regulation applies to the entire mining industry, it is a particular matter of general applicability, 
not a matter involving specific parties, and the former employee would not be prohibited from melting post-employment 
representations to the Government in connection with this regulation. 
Example 2 to paragraph (hX2): The lamer employee in the previous example also assisted MSHA in its defense of a lawsuit 
brought by a trade association challenging the same regulation. This lawsuit is a particular matter involving specific parties, 
and the former MSHA employee would be prohibited from representing the trade association or anyone else in connection 
with the case. 
Example 3 to paragraph (hX2): An employee of the National Science Foundation formciated policies for a grant program for 
organizations nationwide toproduce science education programs targeting elementary school age children. She is not prohibited 
from later representing a specific organization in connection with its application for assistance under the program. 
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Example 4 to paragraph (hX2): An employee in the legislative affairs office of the Department of Homeland Security 
(DHS) drafted official COMM= submitted to Congress with respect to a pending immigration reform bill. After leaving 
the Government, he contacts DHS on behalf of a private organization seeking to influence the Administration to insist on 
certain amendmer.ts to the bill. This is not prohibited. Generally, legislation is not a particular matter involving specific panics. 
However, if the same employee had participated as a D115 employee in formulating the agency's position on proposed private 
relief legislation granting citizenship to a specific individual, this matter would involve specific parties, and the employee would 
be prohibited from later making representational contacts in connection with this matter. 
Example 5 to paragraph (hX2): An mr.ployee of the Food and Drug Administration (FDA) dratted a proposed rule requiring 
all manufacturers of a particular type of medical device to obtain pre-market approval for their products. It was known at the 
time that only three or four manufacturers cun entry were marketing or developing such products. However, there was nothing 
to preclude other manufacturers from entering the market in the future. Moreover, the regulation on its face was not limited in 
application to those companies already known to be involved with this type of product at the time of promulgation. Because 
the proposed rule would apply to an open-coded class of manufacturers, not just specifically identified companies, it would not 
be a particular matter involving specific parties. After leaving Government, the former FDA employee would not be prohibited 
from representing a manufacturer in connection with the final rule or the application of the rule in any specific case. 
Example 6 to paragraph (hX2): A former agency attorney participated in drafting a standard form contract and certain standard 
terms and clauses for use in all future contracts. The adoption of a standard fonn and language for all contracts is a matter of 
general applicability, not a particular matter involving specific parties. Therefore, the attorney would not be prohibited from 
representing another person in a dispute involving the application of one of the standard terms or clauses in a specific contract 
in which he did not participate as a Government employee. 
Example 7 to paragraph (hX2): An employee of the Department of State participated in the development of the United States' 
position with respect to a proposed treaty with a foreign government concerning transfer of ownership with respect to a parcel 
of real property and certain operations there. After terminating Government employment, this individual seeks to represent the 
foreign government before the Department with respect to certain issues arising in the final stage of the treaty negotiations. 
This bilateral treaty is a particular matter involving specific parties, and the former employee had participated personally and 
substantially in this matter. Note also that certain employees may be subject to additional restrictions with respect to trade and 
treaty negotiations or representation of a foreign entity, pursuant to 3 U.S.C. 207(10 and (f). 
Example 8 to paragraph (h)(2): The employee in the previous example participated for the Department in negotiations with 
respect to a multilateral trade agreement concerning tariffs and other trade practices in regard to various industries in 50 
countries. The proposed agreement would provide various stages of implemer.tation, with benchmarks for certain legislative 
enactments by signatory countries These negotiations do not concern a particular matter involving specific parties. Even though 
the former employee would not be prohibited under section 207(a)(I) from representing another person in connection with this 
matter, she must comply with any applicable restrictions in 18 U.S.C. 2070) and (1). 
(3) Specific parties at all relevant times. The particular matter must involve specific parties both at the time the individual 
participated as a Government employee and at the time the former employee makes the communication or appearance, 
although the parties need not be identical at both times. 
Example 1 to paragraph (h)(3): An employee of the Department of Defense (DOD) performed certain feasibility studies and 
other basic conceptual work for a possible innovation to a missile system. At the time she was involved in the matter, DOD 
had not identified any prospective contractors who might perform the work on the project. After she left Government, DOD 
issued a request for proposals to comtruct the new system, and she now seeks to represent one of the bidders in connection 
with this procurement. She may do so. Even though the procurement is a particular matter involving specific parties at the 
time of her proposed representation, no parties to the matter had been identified at the time she participated in the project as 
a Government employee. 
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Example 2 to paragraph (h)(3): A former employee in an agency inspector general's office conducted the first investigation of 
its kind concerning a particular fraudulent accounting practice by a grantee. This investigation resulted in asignificant monetary 
recovery for the Government, as well as a sett:ement agreement in which the grantee agreed to use only certain specified 
accounting methods in the future. As a result of this case, the agency decided to issue a proposed rule expressly prohibiting 
the fraudulent accounting practice and requiring all grantees to use the same accounting methods that had been developed 
in connection with the settlement agreement. The former employee may represent a group of grantees submitting comments 
critical of the proposed regulation. Although the proposed regulation in some respects evolved from the earlier fraud case, 
which did involve specific parties, the subsequent rulemaking proceeding does not involve specific parties. 
(4) Preliminary or informal stages in a matter. When a particular mater involving specific parties begins depends on 
the facts. A particular matter may involve specific parties prior to any formal action or filings by the agency or other 
parties. Much of the work with respect to a particular riveter is accomplished before the matter reaches its final stage, 
and preliminary or informal action is covered by the prohibition, provided that specific parties to the matter actually have 
been identified. With mailers such as grants, contracts, and other agreements, ordinarily specific parties are first identified 
when initial proposals or indications of interest, such as responses to requests for proposals (RP?) or earlier expressions 
of interest, are received by the Government; in unusual circumstances, however, such as a sole source procurement or 
when there are sufficient indicia that the Government has explicitly identified a specific party in an otherwise ordinary 
prospective grant, contract, or agreement, specific parties may be identified even prior to the receipt of a proposal or 
expression of interest 
Example Ito paragraph (Ms): A Government employee participated in internal agency deliberations concerning the merits of 
taking enforcement action against a company for certain trade practices. He left the Government before any charges were filed 
against the company. lie has participated in a particular matter involving specific parties and may not represent another person 
in connection with die ensuing administrative or judicial proceedings against the company. 
Example 2 to paragraph (hX4): A former special Government employee (SOB) of the Agency for Health Care Policy and 
Research served, before leaving the agency, on a "peer review" committee that made a recommendation to the agency 
concerning the technical merits of a specific grant proposal submitted by a university. The committee's recommendations are 
nonbinding and constitute only the first of several levels of review within the agency. Nevertheless, the SOB participated in a 
particular matter involving specific parties and may not represent the university in subsequent efforts to obtain the same grant 
Example 3 to paragraph (hX4): Prior to filing a product approval application with a regulatory agency, a company sought 
guidance from the agency. The company provided specific information concerning the product, including its composition and 
intended uses, safety and efficacy data, and the results and designs of prior studies on the product. After a series of meetings, 
the agency advised the company concerning the design of additional studies that it should perform in order to address those 
issues that the agency still believed were unreso:ved. Even though no formal application had been filed, this was a particular 
matter involving specific parties. The agency guidance was sufficiently specific, end it was clearly intended to address the 
substar.ce of a prospective application and to guide the prospective applicant in preparing an application that would meet 
approval requirements. An agency employee who was substantially involved in developing this guidance could not leave the 
Government and represent the compony when it submits its formal product approval application. 
Example 4 to paragraph (hX4): A Government scientist participated in preliminary, internal deliberations about her 
agency's need for additional laboratory facilities. After she terminated Government service, the General Services 
Administration issued a request for proposals (R.1411) seeking private architectural services to design the new laborato:y 
apace for the agency. The former employee may represent an architectural firm in connection with its response to the 
RIP. During the preliminary stage in which the former employee participated, no specific architectural firms had been 
identified for the proposed work. 
Example 5 to paragraph (hX4): In the previous example, the proposed laboratory was to be an extension of a recently 
completed laboratory designed by XYZ Architectural Associates, and the Government had determined to pursue a sole 
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source contract with that same farm for the new work. Even before the firm was contacted or expressed any interest 
concerning the sole source contract, the former employee participated in meetings in which specifications fora potential 
sole source contract with the firm were dismissed. The former employee may not represent XYZ before the Government 
in connection with this matter. 
(5) Same particular matter—
(t) General. The prohibition applies only to communications or appearances in connection with the same particular matter 
involving specific parties in which the former employee participated as a Government employee. The same particular 
matter may continue in another form or in part. In determining whether two particular mitten involving specific parties 
are the same, all relevant factors should be considered, including the extent to which the matters involve the same basic 
facts, the satne or related parties, related lames, the same confidential information, and the amount of time elapsed. 
(ii) Considerations in the case of contracts, grants, and other agreements. With respect to matters such as contracts, grants 
or other agreements: 
(A) A new matter typically does not arise simply because there are amendments, modifications, or extensions of a 
contract (or other agreement), unless there are fundamental changes in objectives or the nature of the matter; 
(B) Generally, successive or otherwise separate contracts (or other agreements) will be viewed as different matters 
from each other, absent some indication that one contract (or other agreement) contemplated the other or that both 
are in support of the same specific proceeding;. 
(C) A contract is almost always a single particular matter involving specific parties. However, under compelling 
circumstances, distinct aspects or phases of certain large umbrella-type contracts, involving separate task orders or 
delivery orders, may be considered separate individual particular matters involving specific parties, if an agency 
determines that articulated lines of division exist. In making this determination, an agency should consider the relevant 
factors as described above. No single factor should be determinative, and any divisions must be based on the contract's 
characteristics, which may include, among other things, performance at different geographical locations, separate 
and distinct subject matters, the separate negotiation or competition of Individual task or delivery orders, and the 
involvement of different program offices or even different agencies. 
Example Ito paragraph (h)(5): An employee drafted one provision of an agency contract to procure new software. After she left 
Government, a dispute arose under the same contract concerning a provision that she did not draft. She may not represent the 
contractor in this dispute. The contract as a whole is the particular matter involving specific parties and may not be fractionalized 
into separate clauses for purposes of avoiding the prohibition of 18 U.S.C. 207(aX1). 
Example 2 to paragraph (hX5): la the previous example, anew software contract was awarded to the same contractor through a 
full and open competition, following the employee's departure from the agency. Although no major changes were made in the 
contract terms, the new contract is a different particular matter involving specific parties. 
Example 3 to paragraph (hX5): A former special Government employee (SOB) recommended that his agency approve a new 
food additive made by Good Foods, Inc., on the grounds that it was proven safe for human consumption. The Healthy Food 
Alliance (FIFA) sued the agency in Federal court to challenge the decision to approve the product. After leaving Government 
service, the former SGE may not serve as an expert witness on behalf of FIFA in this litigation because it is a continuation of 
the same product approval matter in which he participated personally and substantially. 
Example 4 to paragraph (h)(5): An employee of the Department of the Army negotiated and supervised a contract with 
Munitions, Inc. for four million mortar shells meeting certain specifications. After the employee left Government, the Army 
sought a contract modification to add another one million shells. All specifications and contractual terms except price, quantity 
and delivery date. were 'deadest to those in the original contract. The former Army employee may not represent Munitions 
in connection with this modification, because it is part of the same particular matter involving specific parties as the original 
comma 
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Example 5 to the paragraph (hX5): In the previous example, certain changes in technology occurred since the date of the 
original contract, and the proposed contract modifications would require the additional shells to incorporate new design 
features. Moreover, because of changes in the Army's internal system for storing and distributing shells to various locations, 
the modifications would require Munitions to deliver its product to several decentralized destination points, thus requiring 
Munitions to develop novel delivery and handling systems and incur new transportation costs. The Army considers these 
modifications to be fundamental changes in the approach and objectives of the contract and may determine that these changes 
constitute a new particular matter. 
Example 6 to paragraph (h)(5): A Government employee reviewed and approved certain wiretap applications. The prosecution 
of a person overheard during the wiretap, although not originally targeted, must be regarded as part of the same particular matter 
as the original wiretap application. Thc reason is that the validity of the wiretap may be put in issue and many of the facts giving 
rise to the wiretap application would be involved. 
Example 7 to paragraph (hX5): The Navy awards an indefinite delivery contract for environmental remediation services in the 
northeastern U.S. A Navy engineer is assigned as the Navy's technical representative on a task order for remediation of an oil 
spill at a Navy activity in Maine. The Navy engineer is personally and substantially involved in the task order (e.g., he negotiates 
the scope of work, the labor hours required, and monitors the contractor's performance). Following successful completion of the 
remediation of the oil spill in Maine, the Navy engineer leaves Government service and goes to work for the Navy's remediation 
contractor. In year two of the contract, the Navy issues a task order for the remediation of lead-based paint at a Navy housing 
complex in Connecticut The contractor assigns the former Navy engineer to be its project manager for this task order, which 
will require him to negotiate with the Navy about the scope of work and the labor hours under the task order. Although the task 
order is placed under die same indefinite delivery contract (the terms of which remain unchanged), the Navy would be justified 
in determining that the lead-based paint task order is a separate particular matter as it involves a different type of remediation, at 
a differed location, and at a different time. Note, however, that the engineer in this example had not participated personally and 
substantially in the overall contract Any former =04:yet who had—for example, by participating personally and substantially 
in the initial award or subsequent oversight of the umbrella contract—will be deemed to have also participated personally and 
substantially in any individual particular matters resulting from the agency's determination that such contract is divisible. 
Example 8 to paragraph (h)(5): An agency contracts with Company A to install a satellite system connecting the headquarters 
office to each of its twenty field offices. Although the field offices ere located at various locations throughout the country, each 
installation is essentially identical, with the terms of each negotiated in the main contract Therefore, this contract should not 
be divided into separate particular matters involving specific parties. 
(i) Participated personally and substantially—
(I) Participate. To "participate" means to take an action as an employee through decision, approval, disapproval, 
recommendation, die rendering of advice, investigation, or other such action, or to purposefully forbear in order to affect 
the outcome of a mater. An employee can participate in particular matters that are pending other than in his own agency. 
An employee does not participate in a matter merely because he tad knowledge of its existence or because it was pending 
under his official responsibility. An employee does not participate in a matter within the meaning of this section unless 
he does so in his official capacity. 
(2) Personally. To participate "personally" means to participate: 
(i) Directly, either individually or in combination with other persons; or 
(ii) Through direct and active supervision of the participation of any person he supervises, including a subordinate. 
(3) Substantially. To participate "substantially" means that the employee's involvement is of significance to the matter. 
Participation may be substantial even though it is not determinative of the outcome of a particular matter. However, it 
requires more than official responsibility, knowledge, perfunctory involvement, or involvement on an administrative or 
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peripheral issue. A finding of substantiality should be based not only on the effort devoted to a matter, but also on the 
importance of the effort. While a series of peripheral involvements may be insubstantial, the single as of approving or 
participating in a critical step may be substantial. Provided that an employee participates in the substantive merits of a 
matter, his participatien may be substantial even though his role in the matter, or the aspect of the matter in which he 
is participating, may be minor in relation to the matter as a whole. Participation in peripheral aspects of a matter or in 
aspects not directly involving the substantive merits of a matter (such as reviewing budgetary procedures or scheduling 
meetings) is not substantial. 
Example I to paragraph (i): A General Services Administration (GSA) attorney drafted a standard form contract and certain 
standard terms and classes for use in future contracts. A contracting officer uses one of the standard clauses in a subsequent 
contras without consulting the GSA attorney. The attorney did not participate personally in the subsequent contract. 
Examp!e 2 to paragraph (I): An Internal Revenue Service (IRS) attorney is neither in charge of nor does she have official 
responsibility for litigation involving a particular delinquent taxpayer. At the request of a co-worker who is assigned 
responsibility for the litigation, the lawyer provides advice concerning strategy during the discovery stage of the litigation. The 
IRS attorney participated personally in the litigation. 
Example 3 to paragraph (i): The IRS attorney in the previous example had no further involvement in the litigation. She 
participated substantially in the litigation notwithstanding that the post-discovery stages of the litigation lasted for ten years 
after the day she offered her advice. 
Example 4 to paragraph (i): The General Counsel of the Office of Government Ethics (OGE) contacts the CUE attorney who 
is assigned to evaluate all requests for "certificates of divestiture" to check on the status of the attorneys work with respect to 
all pending requests. The General Counsel makes no comment concerning the merits or relative importance of any particular 
request. The General Counsel did not participate substantially in any particular request when she checked on the status of all 
pending requests. 
Example 5 to paragraph (I): The 00E attorney in the previous example completes his evaluation of a particular certificate of 
divestiture request and forwards kis recommendation to the General Counsel. The General Counsel forwards the package to the 
Director of OGE with a note indicating her concurrence with the attomey's recommendation. The General Counsel participated 
substantially in the request. 
Example 6 to paragraph (i): An International Trade Commission (ITC) computer programmer developed software designed to 
analyze data related to unfair trade practice complaints. At the request of an ITC employee who is considering the merits of a 
particular complaint, the programmer enters all the data supplied to her, nuts the computer program, and forwards the results 
to the employee who will make a recommendation to an ITC Commissioner concerning the disposition of the complaint The 
programmer did not participate sibstantially in the complaint. 
Example 7 to paragraph (i): The director of an agency office must concur in any decision to grant an application for technical 
assistance to certain nonprofit entities. When a particular application for assistance comes into her office and is presented to 
her for decision, she intentionally takes no action on it because she believes the application will raise difficult policy questions 
for her agency at this time. As a consequence of her inaction, the resolution of the application is deferred indefinitely. She has 
participated personally and substantially in the matter. 
(j) United States is a party or has a direct and substantial interest—
(1) United States. For purposes of this paragraph, the "United States" means: 
(i) The executive branch (including a Government corporation): 
(ii) The legislative branch; or 
(iii) The judicial branch. 
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(2) Party or direct and substantial interest The United States may be a patty to or have a direct and substantial interest in 
a particular matter even though it is pending in a non-Federal forum, such as a State court. The United States is neither a 
party to nor does it have a direct and substantial interest in a particular muter merely because a Federal statute is at issue 
or a Federal court is serving as the forum for resolution of the matter. Whenit is not clear whether the United States is 
a patty to or has a direct and substantial interest in a particular matter, this determination shall be made in accordance 
with the folbwing procedure: 
(i) Coordination by designated agency ethics official. The designated agency ethics official (DAEO) for the former 
employee's agency shall have the primary responsibility for coordinating this determination. When it appears likely that 
a component of the United States Government other than the former employee's former agency may be a party to or have 
a direct and substantial interest in the particular matter, the DAEO shall coordinate with agency ethics officials serving 
in those components. 
(ii) Agency determination. A component of the United States Government shall determine if it is a party to or has a direct 
and substantial interest in a matter in accordance with its own internal procedures. It shall consider al: relevant factors, 
including whether. 
(A) The component his a financial interest in the matter; 
(D) The matter is likely to have an effect on the policies, programs, or operation of the component; 
(C) The component is involved in any proceeding associated with the matter, e.g., as by having provided witnesses 
or documentary evidence; and 
(D) The component has more than an academic interest in the outcome of the matter. 
Example l to paragraph (9: An attorney participated in preparing the Government's antitrust action against Z Company. After 
leaving the Government, site may not represent Z Company in a private antitrust action brought against it by X Company on 
the same facts involved in the Government action. Not may she represent X Company in that matter. The interest of the United 
Sates in preventing both inconsistent results and the appearance of impropriety in the same factual matter involving the same 
party, Z Company, is direct and substantial. However, if the Government's antitrust investigation or case is closed, the United 
. States no longer has a direct and substantial interest in the case. 
SOURCE: 73 FR 36186, June 25, 2008, unless otherwise noted. 
AUTHORITY: 5 U.S.C. App. (Ethics in Government Act of 1978); 18 U.S.C. 207; E.O. 12674,54 FR 15159, 3 CFR, 1989 
Comp., p. 215, as modified by 10. 12731, 55 PR 42547, 3 CPR, 1990 Comp., p. 306. 
Current through April 21, 2011; 76 PR 22602 
EM orDomnont 
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Case 9:08-cv-80736-KAM Document 79 Entered on FLSD Docket 05/03/2011 Page 1 of 4 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-80736-Civ 
JANE DOE #1 AND JANE DOE #2, 
Plaintiffs, 
v. 
UNITED STATES OF AMERICA, 
Defendant. 
MOTION TO INTERVENE 
OR IN THE ALTERNATIVE FOR A SUM SPONTE RULE 11 ORDER 
Comes now, Movant Bruce E. Reinhart, pursuant to Federal Rule of Civil Procedure 
24(b), and seeks leave to intervene as a party-in-interest in this matter. Movant seeks to 
intervene to file a Motion for Sanctions based on unfounded factual and legal accusations made 
about Movant in Plaintiff's Motion for Finding of Violations of the Crime Victims' Rights Act 
(the "Motion") [DE 48]. I In the context of a motion alleging that the U.S. Department of Justice 
violated Plaintiff's rights under the Crime Victims Rights Act, Plaintiffs make irrelevant and 
gratuitous accusations that Movant violated unspecified Florida Bar rules and Department of 
Justice regulations. Movant should be granted leave to intervene to rebut these false allegations, 
and to seek sanctions. Alternatively, the Court on its own initiative should require Plaintiffs and 
their counsel to show their compliance with Federal Rule of Civil Procedure 11. 
Without any attempt to tie the allegations to the asserted violation of the CVRA, 
Paragraphs 52 and 53 of the Motion falsely allege that Movant, a non-party to this matter, 
I Movant was not served with a copy of the pleading. Movant first saw the pleading on 
April 20, 2011. 
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violated Florida Bar rules and Department of Justice regulations by representing employees of 
Jeffrey Epstein ("Epstein") in civil litigation after the undersigned retired from the United States 
Attorney's Office for the Southern District of Florida (the "Office"). They also falsely allege 
that Movant, while still employed by the Office engaged in improper conduct relating to Epstein. 
The Motion does not make any effort to connect these allegations to the relief it seeks. It does 
not explain how the accusations against Movant are relevant to its claims under the CVRA, nor 
does it explain how Movant's alleged conduct can be imputed to any party in the action. 
Because there is no proper purpose for these allegations, they are made in bad faith, 
unreasonably, vexatiously, and for the improper purpose of harassing Movant. 
Plaintiff has injected into this action questions of law and fact relating to Movant's 
alleged conduct. Movant now seeks to assert a claim under Fed. Rule Civ. P. 11 and 28 U.S.C. 
§1927 arising from the same questions of law and fact that Plaintiff raised. Movant's claim 
shares with the main action common questions of law and fact. See New York News, Inc. v. 
Newspaper and Mail Deliverer's Union, 139 F.R.D. 291, 293 (S.D.N.Y. 1991Xfor purposes of 
Rule 24(b), claim that falsities in pleading impugned movant's reputation created a question of 
fact in common with underlying cause of action). Therefore, the Court has discretion to permit 
intervention. CI Id. (permissive intervention denied because it would unduly delay and 
prejudice imminent settlement of the original claims), aff'd sub nom New York News v. Klieel, 
972 F.2d 482, 487 (2d Cir. 1992). Here, the proposed intervention does not create a risk of 
undue delay or prejudice to the adjudication of the underlying claims. See Fed. R. Civ. P. 
24(b)(3). Movant should be permitted to intervene under Fed. R. Civ. P. 24(bX1)(B). 
Unless Movant is permitted to intervene, he cannot remedy the false accusations in 
Paragraphs 52 and 53. The Department of Justice has responded to the Motion. It declined to 
respond on the merits to the allegations in Paragraphs 52 and 53 because they are so obviously 
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irrelevant to the Government's alleged violation of the CVRA. As such, Movant's interest is not 
adequately protected by the existing parties. 
Alternatively, Movant asks the Court sua sponte to issue an Order to Show Cause under 
Rule 11(cX3X"On its own, the court may order an attorney, law firm, or party to show cause 
why conduct specifically described in the order has not violated Rule 11(b)"). This Court should 
not countenance a party making irrelevant, slanderous accusations against a non-party. On the 
face of Plaintiffs' Motion, it is cleat that the allegations in Paragraphs 52 and 53 are irrelevant to 
whether the CVRA was violated, and therefore are not being presented for a proper purpose. 
The Court should require Plaintiffs and their counsel to show what legal and factual inquiry they 
undertook to comply with Rule 11(b) before making the allegations in Paragraphs 52 and 53, and 
to articulate the proper purpose for which these allegations were included in their Motion. 
As required by Fed. R. Civ. P. 24(c), attached to this motion is a proposed Motion for 
Sanctions. If leave to intervene is granted, the Motion for Sanctions which will be served on 
Plaintiffs' counsel under Fed. R. Civ. P. 5, but not filed for 21 days thereafter. See Fed. R. Civ. 
P. 11(cX2). 
Pursuant to Local Rule 7.1(aX3), undersigned counsel contacted counsel for Plaintiffs 
and counsel for the United States. Assistant United States Attorney Dexter Lee reported that the 
United States does not oppose the Motion to Intervene. Bradley Edwards, Esq., counsel for 
Plaintiffs reported that they oppose the Motion to Intervene. 
Respectfully submitted, 
is/ Bruce E. Reinhart 
BRUCE E. REINHART,P.A. 
Florida Bar # 10762 
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