UNITED STATES OF AMERICA v. WOLKOFF

Filing 1

COMPLAINT against STEPHANIE WINSTON WOLKOFF (Fee Status:Filing Fee Waived) filed by UNITED STATES OF AMERICA. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Civil Cover Sheet, # 4 Summons)(Hall, Jeffrey)

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Case 1:20-cv-02935 Document 1-2 Filed 10/13/20 Page 1 of 3 Exhibit B Case 1:20-cv-02935 Document 1-2 Filed 10/13/20 Page 2 of 3 U.S. Department of Justice Civil Division ________________________________________________________________________ Office of the Assistant Attorney General Washington, D.C. 20530 Lorin L. Reisner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas New York, NY 10019 Dear Mr. Reisner: I write in response to recent press reports indicating that Simon & Schuster plans to publish, on September 1, 2020, a book by Stephanie Winston Wolkoff called Melania and Me. As you are aware, as part of her volunteer arrangement for providing services to the White House Office of the First Lady and the First Lady, Ms. Wolkoff signed a Gratuitous Services Agreement promising to protect information covered by the Agreement from disclosure. In signing the Agreement, Ms. Wolkoff acknowledged that she “may have access to nonpublic, privileged and/or confidential information,” and expressly agreed to “protect from inadvertent or intentional release or unauthorized disclosure any and all information furnished to me under this Agreement.” Furthermore, Ms. Wolkoff acknowledged that she is “specifically prohibited from publishing, reproducing or otherwise divulging any such information to any unauthorized person or entity in whole or in part,” and she agreed to “take all reasonable measures to protect it from unauthorized disclosure.” According to press reports, Ms. Wolkoff’s book appears to violate these commitments. Portions of the book relate to “her role as the First Lady’s trusted advisor” and “her abrupt and very public departure” from that role in February 2018. See https://www.usatoday.com/story/ entertainment/books/2020/07/07/melania-trump-former-confidante-stephanie-winston-wolkoffpens-book/5388770002/. See also https://www.vanityfair.com/news/2020/07/stephanie-winstonwolkoff-book-melania (observing that the book will cover her time “navigating the White House and East Wing”). If these reports are true, the book appears to contain government information that Ms. Wolkoff expressly promised to not disclose. Case 1:20-cv-02935 Document 1-2 Filed 10/13/20 Page 3 of 3 Please confirm immediately, but no later than July 17, that Ms. Wolkoff’s book will not contain any information covered by the Agreement. If you are unable to do so, the government will pursue all available legal remedies. Sincerely, s/ Ethan P. Davis Ethan P. Davis Acting Assistant Attorney General CC: Elizabeth McNamara Counsel for Simon and Schuster

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