JW V DOJ 01239 DOJ Public Integrity IRS 11515

Obtained by Judicial Watch, Inc.
via FOIA
U.S. Department of Justice
Criminal Division
Office of Enforcement Operations
Washington, D.C. 20530
January 15, 2015

Via Electronic Delivery
Ramona Raula Cotca, Esq.

Kate Bailey
Judicial Watch
425 Third Street, SW, Suite 800
Washington, DC 20024
rcotca@judicialwatch.org
Re: CRM-300444674
KWC:PR3
Dear Ms. Cotca:

This letter serves as the second installment of the Criminal Division's rolling production
in Judicial Watch, Inc. v. U.S. Department of Justice, 14-cv-1239, (D.D.C.), pursuant to the Meet
and Confer Report filed September 23, 2014. Your request seeks records concerning meetings
and/or communications between the Department of Justice Criminal Division Public Integrity
Section and the Internal Revenue Service Tax Exempt and Government Entities Division, the
White House, Members of Congress and/or congressional staff, and any non-government entity,
regarding 501(c)(4) or other tax-exempt organizations.
After carefully reviewing 938 pages of records, this Office has determined that thirty four
pages are appropriate for release with excisions and 904 pages are being withheld in full
pursuant to:
5 U.S.C. 552(b)(3), which concerns matters specifically exempted from release
by statute (in this instance, 26 U.S.C. 6103, which pertains to tax return
information);
5 U.S.C. 552(b)(5), which concerns certain inter- and intra-agency
communications protected by the deliberative process privilege, and the attorney
work-product privilege;
5 U.S.C. 552(b)(6), which concerns material the release of which would
constitute a clearly unwarranted invasion of the personal privacy of third parties;
and
5 U.S.C. 552(b)(7)(C), which concerns records or information compiled for law
enforcement purposes the release of which could reasonably be expected to
constitute an unwarranted invasion of the personal privacy of third parties.
Obtained by Judicial Watch, Inc. via FOIA
Additionally, fifty five pages of the reviewed records originated with the Federal Bureau
of Investigation. In accordance with 28 C.F.R. 16.4(c) (2014), this Office has referred that
material to the FBI for processing and response to you. If you have any questions regarding this
referral, you may contact the FBI at the following:
David Hardy, Chief
Records Management Division
Federal Bureau of Investigation
170 Marcel Drive
Winchester, Virginia 22602-4843
For your information, Congress excluded three discrete categories of law enforcement
and national security records from the requirements of the FOIA. See 5 U.S.C. 552(c). This
response is limited to those records that are subject to the requirements of the FOIA. This is a
standard notification that is given to all requesters and should not be taken as an indication that
excluded records do, or do not, exist.
Although I am aware that your request is the subject of ongoing litigation and that
appeals are not ordinarily acted on in such situations, I am required by statute and regulation to
inform you of your right to an administrative appeal of this determination. Your appeal must be
in writing and addressed to the Director, Office of Information Policy, United States Department
of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, DC 20530-0001. Your
appeal must be received within sixty days from the date of this letter. Both the letter and the
envelope should be clearly marked "Freedom of Information Act Appeal."
Sincerely,
Kenneth Courter
Chief
FOIA/PA Unit
Enclosures
cc:
Bradley Cohen, Esq.

P.O. Box 883
Washington, DC 20044
bradley.cohen@usdoj.gov
/o=crm/ou=exchan e
From:
(b)(6), (7)(C)
To:
Cc:
Bcc:
Subject:
Date:
Attachments:
RE:
Wed Jun 12 2013 16:45:09 ED
Consent Form_Garrity Waiver
image001.jpg
image002.png
image003.png
Proffer Agreement -
(b)(6), (7)(C)
(b)(6), (7)(C)
We are good with Wednesday let's book.
Attached, please find a proffer letter and the Garrity waiver we discussed. Please call me with any
questions. Apart from the paperwork though, could you please call me to discuss one or two logistical
issues? Among them, as you can glean from the Garrity waiver, we would appreciate getting it
ap, prior to the proffer, so that we can review your client's prior statements
executed and return
We believe that will make the proffer more efficient for all us.
before meeting with
(b)(6), (7)(C)
Finally,WI my colleague in the Civil Rights Division, who will also be at the proffer
session, is cc on this email ,
From
SeWednesday. June 12, 2013 4:26 PM
To:
(b)(6), (7)(C)
Cc
Subject:
(b)(6), (7)(C)
Are we confirmed for Wed in Cincy? If so, we will book flights.
(b)(6), (7)(C)
(b)(6), (7)(C)
(b)(6), (7)(C)
a law firm, arid may contain legally
This e-mail message is from the Law Offices of
privileged and/or confidential information. If the reader of this message is not the intended recipient, or
the employee or agent responsible for delivering the message to the intended recipient, you are hereby
notified that any dissemination, distribution or copying of this e-mail message is strictly prohibited. If
you have received this message in error, please notify the sender immediately and delete this e-mail
message and any attachments from your computer without retaining a copy.
IRS Circular 230 disclosure: Any tax advice contained in this communication (including any attachments
or enclosures) was not intended or written to be used, and cannot be used, for the purpose of (i)
avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to
another party any transaction or matter addressed in this communication. (The foregoing disclaimer has
been affixed pursuant to U.S. Treasury regulations governing tax practitioners.)
CONSENT AND WAIVER FORM

, am an employee of the IRS. I understand that there is a
Depai. went of Justice criminal investigation related to public allegations that IRS officials unlawfully
discriminated against applicants for tax-exempt status. I understand that statements I have made in
connection with my IRS employment, if induced by threat of termination or other significant adverse
employment consequence, may not be used against me in any criminal investigation or proceeding
under the principles announced in Garrity v. New Jersey, 385 U.S. 493 (1967).
I have made statements on dates prior to this Consent and Waiver Foini to IRS personnel,
including TIGTA agents and supervisory personnel, and to the U.S. Congress or its agents, which
relate to the matters under investigation (hereinafter "my prior statements"). I hereby acknowledge
that my prior statements were made voluntarily and were not induced by threat of termination or other
significant adverse employment consequence. Moreover, I waive any claims I may otherwise have
under Garrity regarding my prior statements, including any argument that my prior statements (or any
evidence derived from my prior statements) cannot be used against me in any criminal investigation or
proceeding. I voluntarily consent to all of my prior statements being furnished to special agents of the
FBI and TIGTA, as well as attorneys from the Department of Justice, to be used for any reason relevant
to the pending criminal investigation and any future criminal proceeding.
By my signature below, in consultation with my attorney, I hereby voluntarily, knowingly, and
intelligently give the above described consent and waive any rights I may have under Garrity related to
my prior statements.
Printed Name
Attorney Name
Signature
Attorney Signature
Date
Date
(b)(6), (7)(C)
PROFFER AGREEMENT
The United States of America, represented by its undersigned attorney, an
o agents and
enter into this proffer agreement with respect to a proffer to be made by
knowledge about matters that are the subject
attorneys of the United States concerning

of the instant criminal investigation.
(7)(C)
ill
answer
honestly,
truthfully and completely all questions posed to
iii
v
1. Ilin
(b)(6), (7)(C)
by agents and attorneys of the United States.
roffer, the United States
By discussing these matters and by acceptin
2.
for
does not intend in any way to agree to, or represent that it will, confer immunity upon
ior has the United States made any
any possible federal criminal acts committed by
representation or agreement about the disposition of any federal criminal charges which might be
(b)(6), (7)(C)
filed agains
y the United States, the
Should any prosecution be brought against
(b)(6), (7)(C) 3.
or at sentencing of
United States will not offer in evidence in its case-in-chief against

any statements made by
pursuant to this proffer agreement, except in a
(b)(6) (7)(C)
prosecution for false statements, obstruction o justice in the current investigation, or perjury, or as
(b)(6), (7)(C)
noted in paragraph 5.
4.
The United States can use information derived from statements by
the proffer agreement directly or indirectly for the purpose of obtaining leads to other evidence,
which evidence may be used by the United States against
5.
Should any prosecution ot
in any prosecution of
ie undertaken, the United States may use
(b)(6), (7)(C)
statements as substantive evidence for the purpose of cross-examination o
should
stify at any phase of the case, including motions, trial, or sentencing. The United States
'
(b)(6), (7)(C)
(b)(6), (7)(C)
(b)(6), (7)(C)
statements as substantive evidence to oppose any motions or to rebut any
may also us
evidence, factual assertions or arguments offered by or on behalf of
(b)(6), (7)(C)
or sentencing phase.
6.
at any pretrial, trial
The provisions of Rule 410 of the Federal Rules of Evidence and Rule 11(f) of the
Federal Rules of Criminal Procedure do not apply to any statements made by
(b)(6), (7)(C)
waives any right to challenge the
evidence derived from those statements, and

admissibility of such evidence under either of these rules.
Dated:
FOR THE *UNITED STATES
(b)(6), (7)(C)
emor ega ounse na
orney
FOR THE WITNESS:
lip.111111111
or any
(7)(C)
ess
(b)(6), (7)(C)
Attorneys
(b)(6), (7)(C)
lo=c
From:
u=exchan e
To:
(b)(6), (7)(C)
Cc:
crt,usdoj.gov
crt.usdoj.gov>
Bcc:
Subject:
Date:
Attachments:
Re: RE:
Wed Jun 12 2013 22:35:17 EDT
Let's talk in am if they don't get back to you. Thanks.

03)(6), (7)(C)
From:
Time
:PPas
ernIandard
une
Sent: Wednesday JIPPRII
To
crt.usdoj.gov 11111(b ) ( 6 ) , (7)(C)
>
crt.usdoj.gov
(b)(6), (7)(C)
Subject: Re: RE:
(b)(6), (7)(C)
They are at IRS counsel's office. I am

nd his supervisor
We are dealing w
ground
in
the
morning,
out
we
iind
it amazing that they didn't immediately
happy to give you more bac
respond giving us the green light to meet with you. Feel free to reach out to them (I can provide
contact if you needed).
(b)(6), (7)(C)
On Jun 12, 2013, at 10:28 PM,IllialEaiallMusdoj.gov> wrote:
(b)(6), (7)(C)
Who at IRS are you in touch with, if you don't mind me asking?
From:
Sent.
To:
Cc
crt.us oi.gov>
Subject: Re: RE:
(b)(6), (7)(C)
andard Time
(b)(6), (7)(C)
Lets do Friday at 3 pm. Tell us where we should call, or I can send around a call in number.
We also spoke to IRS Counsel late today re authorization. I will let you knoW when we hear back.
Depending on their speed, we may ask for assistance.
(b)(6), (7)(C)
usdoj.gov> wrote:
On Jun 12, 2013, at 5:49 PM, '
(b)(6), (7)(C)
aTIA6a)reCaNailable b/w 12 and 3 on Friday - will sometime in that time frame work for you
guys? can provide a conference line that we can call into.

From
Se
To.
Cc:
Subject: RE:
(b)(6), (7)(C)
(b)(6), (7)(C)
CRT)
We are good with Wednesday - let's book.
executed and returned asap, prior to the proffer, so that we can review your client's prior statements
before meeting with him. We believe that will make the proffer more efficient for all us.
WI (b)(6), (7)(C ie Civil Rights Division, who will also be at the proffer
my c011eague in
Finally,
session, is cc on is email.
From
Se
To.
Cc:
(b)(6), (7)(C)
(b)(6), (7)(C)
Subject:
(b)(6), (7)(C)
<image002.png><image003.png>
(b)(6), (7)(C)
a law firm, and may contain legally

(b)(6), (7)(C)
From:
To:
administrative group
Cc:
Bcc:
Subject:
Date:
Attachments:
crt.usdoj.gov
crtusdoj.gov>
RE: RE:
Thu Jun 13 2013 15:14:50 EDT
image001.jpg
image006.png
image007.png
image008.jpg
Just tried you back. I am in the office.
(b)(6), (7)(C)
(b)(6), (7)(C)
or enclosures) was not intended or written to be used, and cannot be used, for the purpose of (I)
From:
Se
To.
Cc:
Subjec
usdoj.gov]
(b)(6), (7)(C)
c .us oj gov
(b)(6), (7)(C)
Just tried calling liar someone who can receive the unredacted documents and
o receive them. Please give me a call so we can discuss.
who can then arrange for me and
Would love to get them before we speak on the phone tomorrow, if possible.
(b)(6), (7)(C)
From:
Se
To
Cc
Su
(b)(6), (7)(C)
(b)(6), (7)(C)
crt.usdoj.gov
We are good to go with meeting with you next week, but please give me a call when you can to discuss
documents. Thanks.
(b)(6), (7)(C)
(b)(6), (7)(C)
(b)(6), (7)(C)
privileged and/or confidential information. If the reader or mis message is not the intended recipient, or
(b)(6), (7)(C)
From:11111101011111111011Lusdoj.gov)
Se
(b)(6),
To:
crt.usdoj.gov`
Cc:
Subject: Re: RE:
30 ends. Thank you.
We'll be flexible as well for when

From
Se
To
Su jec
(7)(C)
(b)(6), (7)(C)
Standard Time
11=PAlittOKNORCIMIA
1
crt.usdoj.gov11111111.crt. usdoj.gov>
(b)(6), (7)(C)
(b)(6), (7)(C)
All good with 2:30 here.
(b)(6), (7)(C)
Sent from my iPhone

On Jun 12, 2013, at 10:35 PM
(b)(6), (7)(C)
I have a 130 that should be done by 230. We will make it work.
(b)(6), (7)(C)
(b)(6) (7)(C)
usdoj.gov> wrote:
On Jun 12, 2013, at 10:34 PM,

Also, might 230 work for you guys
time. I will circulate the dial in tomorrow.
From:
Se
To
ill be on the road and that will give us more flexibility with
(b)(6), (7)(C)
t
rd
crt.usdoj.gov'
crt.usdoj.gov>
Subject: Re: RE:
Who at IRS are you in touch with, if you don't mind me asking?
(b)(6), (7)(C)
From:
Sent: Wednesday. June 12. 2013 08:43 PM Eastern Standard Time
Tc
C
@crt.usdoj.gov>
(b)(6),
Subject: e: RE:
(CRT)
(7)(C)
Lets do Friday at 3 pm. Tell us where we should call, or I can send around a call in number.
We also spoke to IRS Counsel late today re authorization. 1 will let you know when we hear back.
Depending on their speed, we may ask for assistance.
(b)(6), (7)(C)
(b)(6), (7)(C)
(b)(6), (7)(C)
usdoj.gov> wrote:
On Jun 12, 2013, at 5:49 PM,
(b)(6), (7)(C)
and I are both available b/w 12 and 3 on Friday will sometime in that time frame work for you
il
guys? can provide a conference line that we can call into.
From
Sen
To:
Cc:
Subject: RE:
(b)(6), (7)(C)
0
PM
(CRT)
(b)(6), (7)(C)
We are good with Wednesday let's book.
executed and returned asap, prior to the proffer, so that we can review your client's prior statements
We believe that will make the proffer more efficient for all us.
before meeting witi
(b)(6), (7)(C)
my colleague in the Civil Rights Division, who will also be at the proffer
Finally,
session, is cc'd on this email.
From:
Sen WednesdayJune ,
To:
(b)(6), (7)(C)
(b)(6), (7)(C)
(b)(6), (7)(C)
u jec
(b)(6), (7)(C)
<image002.png><image003.png>
(b)(6), (7)(C)

Bcc:
Subject:
Date:
Attachments:
RE: Received the documents

Thu Jun 13 2013 17:55:52 EDT
image001.jpg
image002.png
image003.png
Yes. If for any reason you, guys are comfortably ready by 230,,drop us a line,
From
Se. IL 1111-Il
To
Cc
Subject: RE: Received the documents
(b)(6), (7)(C)
(b)(6), (7)(C)
(CRT)
Can we do 245? I know I keep inching a bit later. I just want to make sure my 130 is over.
(b)(6), (7)(C)
This e-mail message is from the Law Offices oBM a law firm, and may contain legally
(b)(6), (7)(C)
From:
Is rs a une
Se
To:
Cc:
Subject: RE: Receive t e ocumen s
usdoj.govi
(b)(6), (7)(C)
(CRT)
Our filter team has the documents and I anticipate they will be forwarding them to us shortly.
For our 2:30 call tomorrow, please use the below.
Toll Free Dialing;
(b)(6), (7)(C)
Participants Passcode:
(b)(6), (7)(C)
From
Sent: Thursday. June 13, 2013 5:
To
(b)(6), (7)(C)
Subject: FW: Received the documents
FYI
(b)(6), (7)(C)
(b)(6), (7)(C)
(b)(6), (7)(C)
This e-mail message is from the Law Offices o
sage
is not the intended recipient, or
privileged and/or confidential information, If the
(b)(6), (7)(C)
From
Sent: Thursday, June 13, 2U13 b:2b
To:
(b)(6), (7)(C)
Subject: Received the documents
tigta.treas.gov]
(b)(6), (7)(C)
received the documents and was able to open the file without any difficulty.
Thanks,
(b)(6), (7)(C)
(b)(6), (7)(C)
Operations Division
(b)(6), (7)(C)
From:
To:
Cc:
Bcc:
Subject:
Date:
Attachments:
RE: garrity
Mon Jun 17 2013 13:46:48 EDT
image001.jpg
image002.png
image003.png
Thank you. I will get you the address this afternoon. Yes 10am it is.
From
Sent: Monday, June 17, 2013 1:12 PM
To
(b)(6), (7)(C)
RT)
(b)(6), (7)(C)
Subject: garrity
(b)(6), (7)(C)
See inserted Garrity waiver.
Do you have the exact address of where we are meeting on Wed? Can we do 10 am?
Please let me know if you have any other thoughts or questions after our call last week.
(b)(6), (7)(C)
(b)(6), (7)(C)
(b)(6), (7)(C)
sage is not the intended recipient, or
privileged and/or confidential information. If the
you have received this message In error, please notify the sender immediately and delete this e-mail
P. 02
(b)(6), (7)(C)
(b)(6), (7)(C)
COILSENI' AND WAIVER FORM

am an employee of the IRS. I understand that there is a
Department of Justice criminal investigation related to public allegations that IRS OnCial$ unlawfully
connection with my IRS employment, if induced by threat of teMilnation or other significant adverse
under the principles announced in. Garrity v, New Jer4ty, 385 il.S. 493 (1967).
I have made statements on dates prior to this Consent and Waiver Form to IRS personnel.
including TIGTA agents and supervisory personnel, and to the U.S. Congress or its agents, which
relate to the matters under investigation (hereinafter "my prior staternents). I hereby acknowledge
that my prior statements were made voluntarily and were not induced by threat of termination or other
significant adverse employment consequence. Moreover, I waive any claims I may otherwise have
under Garrity regarding my prior statements, including any argument that my prior statements (or any
evidence derived from my prior statements) cannot be used against me in any criminal investigation or
proceeding. I voluntarily consent to all fifty prior statements being furnished to special agents of the
FBI and TIGIA, as well as attorneys from the Department oflustice, to be used for any reason relevant
to the pending criminal investigation and any future criminal proceeding.
By my signature below, in consultation with my attorney, Thereby voluntarily, knowingly. and
intelligently give the above described consent and waive any rights I may have under Garrity
Printed Name
Attorney Name
Date
related to
2,a5
-
(7)(C)
Attorney Sipature
Date
lUINL
(b)(6), (7)(C)
From:
To:
CRT)
</o=crm/ou=washion=recipients/on
Cc:
Bcc:
Subject:
Date:
Attachments:
(b)(6), (7)(C)
Proffer Material
0 2013 19:46:59 EDT
Thu
onsent and Waiver.pdf
roffer Agreement.pdf
(b)(6), (7)(C)
I look forward to working with you on this matter. I cc'd my
of DOJ's Civil Rights Section on this email.
Pleasure speaking
partner on this case,
(b)(6), (7)(C)
Per our conversation, attached is a standard proffer agreement and the waiver/consent we discussed.
Once you have had an opportunity to review them, please feel free to contact me so we can discuss
whether we can schedule a meeting with you and your client.
(b)(6), (7)(C)
Trial Attorney
Public Integrity Section
Criminal Division
United States Department of Justice
1400 New York Ave, NW, 12th Floor
(b)(6), (7)(C)
CONSENT AND WAIVER FORM

, am an employee of the IRS. I understand that there is a
Department of Justice criminal investigation related to public allegations that IRS officials unlawfully
connection with my IRS employment, if induced by threat of termination or other significant adverse
under the principles announced in Garrity v. New Jersey, 385 U.S. 493 (1967).
I have made statements on dates prior to this Consent and Waiver Form to IRS personnel,
including TIGTA agents and supervisory personnel, which relate to the matters under investigation
(hereinafter "my prior statements"). I hereby acknowledge that my prior statements were made
voluntarily and were not induced by threat of termination or other significant adverse employment
consequence. Moreover, I waive any claims I may otherwise have under Garrity regarding my prior
statements, including any argument that my prior statements (or any evidence derived from my prior
statements) cannot be used against me in any criminal investigation or proceeding. I voluntarily
consent to all of my prior statements being furnished to special agents of the FBI and TIGTA, as well
as attorneys from the Department of Justice, to be used for any reason relevant to the pending criminal
investigation and any future criminal proceeding.
By my signature below, in consultation with my attorney, Thereby voluntarily, knowingly, and
intelligently give the above described consent and waive any rights I may have under Garrity related to
my prior statements.
Printed Name
Signature
Date
Attorney Name
Attorney Signature
Date
(b)(6), (7)(C)
PROFFER AGREEMENT
The United States of America, represented by its undersigned attorney, an

o agents and
enter into this proffer agreement with respect to a proffer to be made b
owledge about matters that are the subject
attorneys of the United States concerning

of the instant criminal investigation. (b)(6), (7)(C)
ill answer honestly, truthfully and completely all questions posed to
1.
y agents and attorneys of the United States.
(b)(6), (7)(C)
(b)(6), (7)(C)
roffer, the United States
By discussing these matters and by acceptin
2.
does not intend in any way to agree to, or represent that it will, confer immunity upon
(b)(6), (7)(C)
nor has the United States made any
for any possible federal criminal acts committed by
representation or agreement about the disposition of any federal criminal charges which might be
filed against!. (b)(6), (7)(C)
(b)(6), (7)(C)
iy the United States, the
Should any prosecution be brought against
3.
or at sentencing of
United States will not offer in evidence in its case-in-chief against

any statements made b
pursuant to this proffer agreement, except in a
(b)(6), (7)(C)
prosecution for false statements, obstruction of justice in the current investigation, or perjury, or as
(b)(6), (7)(C)
noted in paragraph 5.
The United States can use information derived from statements b
4.
the proffer agreement directly or indirectly for the purpose of obtaining leads to other evidence,
which evidence may be used by the United States _against
5.
Should any prosecution of
(b)(6), (7)(C)
in any prosecution of
(b)(6), (7)(C)
be undertaken, the United States may use
(b)(6), (7)(C)
statements as substantive evidence for the purpose of cross-examination of her should
testify at any phase of the case, including motions, trial, or sentencing. The United States
(b)(6), (7)(C)
statements as substantive evidence to oppose any motions or to rebut
may also usII
it any pretrial,
any evidence, factual assertions or arguments offered by or onbehalfot

trial or sentencing phase.
6.
(b)(6), (7)(C)
The provisions of Rule 410 of the Federal Rules of Evidence and Rule 11(f) of the
Federal Rules of Criminal Procedure do not apply to any statements made by

evidence derived from those statements, an
admissibility of such evidence under either of these rules.
Dated:
FOR THE UNITED STATES
(b)(6), (7)(C)
Senior Legal Counsel/Trial Attorney
U.S. Depat tment of Justice
FOR THE WITNESS:
(b)(6), (7)(C)
itness
(7)(C)
ttomey
or any
aives any right to challenge the
(b)(6), (7)(C)
From:
To:
Cc:
Bcc:
Subject:
Date:
Attachments;
(b)(6), (7)(C)
crtusdoj.gov
bittittlej:gOV>aswdlaw.com>
(b)(6), (7)(C)
Re; Proffer Material

Wed Jul 10 2013 16:05;58 EDT
Yes we can accommodate. No worries.

Sent from my iPhone - please excuse any spelling errors
usdoj.gov> wrote:
On Jul 10, 2013, at 4:03 PM,
(b)(6), (7)(C)
(b)(6), (7)(C)
We don't want to overwhelm your conference room, but we intend to bring 5 folks tomorrow; two DOJ
attorneys, two FBI agents, and a TIGTA agent Can you accommodate us? Don't worry - this will not be
a scatter shot interview; having our team all there will actually make this more efficient
(b)(6), (7)(C)
From:
Sent: Monda , July 08, 2013 09;59 AM Eastern Standard Time
To:
crtusdaj.gov>;
crt. usdoj.gov'
Cc:
asw aw.com>
corn
(b)(6), (7)(C)
ffer Material
Subjec
(b)(6), (7)(C)
No worries on getting back to us. In transit; will be in touch this afternoon.
)(e6), (7)(C)
(Tbim
Pard
as ern
an
Milil
13 09:lOPP
II
Frani
crt.usdoj.gov>;
Su ec
(b)(6), (7)(C)
ro er V a ena
(b)(6), (7)(C)
Tardily getting back to you re the proffer agreement in anticipation of Thurs proffer. Looks fine to me w
the exception if the provision re using the statements as substantive evidence. That differs from the
same provision of the standard proffer agreement as issues by the local US Attys offices, which limit
use to impeachment purposes. Would you consider that alteration?
(b)(6), (7)(C)
usdoLgov> wrote:
On Jun 20, 2013, at 7:48 PM,
(b)(6), (7)(C)
(b)(6), (7)(C)
(look forward to working with you on this matter. I cc'd my
of DOJ's Civil Rights Section on this email.
Pleasure speaking w
partner on this case,
(b)(6), (7)(C)
Per our conversation, attached is a standard proffer agreement and the waiver/consent we discussed.
Once you have had an opportunity to review them, please feel free to contact me so we can discuss
whether we can schedule a meeting with you and your client.
(b)(6), (7)(C)
Trial Attorney
Criminal Division
(b)(6), (7)(C)
CONFIDENTIAL WARNING
This email message, together with any attachments, is intended only for the
personal and confidential use of the recipient(s) named above. This message
may be an attorney-client communication and as such is privileged and
confidential.
If you are not the intended recipient, you are hereby notified that you have
received this document in error and that any review, dissemination,
distribution, or copying of this message is strictly prohibited. If you have
received this message in error, please notify us immediately by telephone
0r by return email and delete this message, along with any
1.11.(b)(6), (7)(C)
attachments, from your computer.
Thank You
confidential.
or by return email and delete this message, along with any
(b)(6), (7)(C)
Thank You
From:
To:
(b)(6), (7)(C)
Cc:
Bcc:
Subject:
Date:
Attachments:
bit usdbj:gov>;'
tigta.treas.gov>
ocuments
Re
Fri Jul 12 2013 08:03:14 EDT
Will get on it. Thank you
(b)(6), (7)(C)

On Jul 12, 2013, at 6:06 AM,
usdoj.gov> wrote:
(b)(6), (7)(C)
Thank you again for meeting with us yesterday. I write to follow up on the two document related issues
we discussed.
(b)(6), (7)(C)
appreciate receiving the time line related to the "TAG spreadsheet" and "BOLO" that
repared. As we stated, that timeline will be covered by the proffer agreement she
executedyesterday. (I will scan and email you a copy of the proffer agreement when I return to
Washington.)
'
(b)(6), (7)(C)
(b)(6), (7)(C)
we would also appreciate obtaining the email communications that you obtained from
pertaining to the 501(c)-application issues we discussed yesterday, i.e., the public allegations
that the IRS "targeted" certain groups based on their political viewpoints, in particular groups associated
with the 'Tea Party." As I explained yesterday, due to the filter procedures we have in place, could you
please divide the communications into two groups, those dated before and those dated on or after
March 1, 2012? To the extent practical, the emails dated on or after March 1, 2012, should be placed in
a sealed envelope or otherwise clearly separated from the first batch (i.e., if they are scanned and
emailed, please do so in separate files). To the extent any of these applications contain taxpayer
information, return information, and/or taxpayer return information, the Department of Justice and the
FBI have referral authority under 18 U.S.C. 6103(h) to view thistion by virtue of our participation
who was present at the meeting
in a joint investigation with TIGTA. I have cc'd T1GTA SA
yesterday and confirmed this orally, to further confirm it by way of this writing. Please let us know if you
(b)(6), (7)(C)
have any questions concerning that.
We are happy to receive the documents via email or hard copy whatever is easiest for you. If you
prefer to send the documents by email, please encrypt them to the extent they contain information
covered by 6103 (this function is available on PDF); if you prefer to provide them by hard copy, please
let me us know that and we can make arrangements to pick them up.
Thank you again for your cooperation in this matter we appreciate it.
(b)(6), (7)(C)
Trial Attorney
Criminal Division
(b)(6), (7)(C)
confidential.
11.111or by return email and delete this message, along with any
(b)(6), (7)(C)
'.
Thank You
--.
From:
To:
(b)(6), (7)(C)
Cc:
rt. us. oj.gov>;

ig a. reas.gov
ti ta.treas. ov>
(b)
Bcc:
Subject:
Date:
Attachments:
Documents
15:12 EDT
Docs (after 3-1-12) Provided to TIGTA.PDF
Does (prior to 3-1-12) Provided to TIGTA.PDF
(b)(6), (7)(C)
As we discussed, I am sending you two attachments. One is the emails from before 3/1/12 and one is
after. Please be aware though that in organizing by date we went with the most recent date on the email
chain, so something that was forwarded or replied to after 3/1/12 may still have emails further back in
the chain that pre-date 3/1/12. Let me know if you have any questions or have any trouble with the
attachments.
(b)(6), (7)(C)
From
Sent: Friday, July 12, 2013 6:05 AM
To
CRT);
Cc:
ocumen s
Subject
usdoj.gov]
(b)(6), (7)(C)
tigta.treas.gov
(b)(6), (7)(C)
Thank you again for meeting with us yesterday. I write to follow up on the two document related issues
we discussed.
(b)(6), (7)(C)
d appreciate receiving the time line related to the "TAG spreadsheet" and "BOLO" that
repared. As we stated, that timeline will be covered by the proffer agreement she
executed yesterday. (I will scan and email you a copy of the proffer agreement when I return to
Washington.)
(b)(6), (7)(C)
Second we would also appreciate obtaining the email communications that you obtained from
pertaining to the 501(c)-application issues we discussed yesterday, i.e., the public allegations
(b)(6), (7)(C)
that the IRS "targeted" certain groups based on their political viewpoints, in particular groups associated
with the "Tea Party." As I explained yesterday, due to the filter procedures we have in place, could you
please divide the communications into two groups, those dated before and those dated on or after
March 1, 2012? To the extent practical, the emails dated on or after March 1, 2012, should be placed in
a sealed envelope or otherwise clearly separated from the first batch (i.e., if they are scanned and
emailed, please do so in separate files). To the extent any of these applications contain taxpayer
information, return information, and/or taxpayer return information, the Department of Justice and the
FBI have referral authority under 18 U.S.C. 6103(h) to vie" fhk.rfr,rrntion by virtue of our participation
ho was present at the meeting
in a joint investigation with TIGTA. I have cc'd TIGTA S
yesterday and confirmed this orally, to further confirm it by way ot this writing. Please let us know if you
have any questions concerning that.
(b)(6), (7)(C)
We are happy to receive the documents via email or hard copy whatever is easiest for you. If you
prefer to send the documents by email, please encrypt them to the extent they contain information
covered by 6103 (this function is available on PDF); if you prefer to provide them by hard copy, please
let me us know that and we can make arrangements to pick them up.
Thank you again for your cooperation in this matter we appreciate it.
(b)(6), (7)(C)
Trial Attorney
Criminal Division
(b)(6), (7)(C)
confidential.
(b)(6), (7)(C)
or by return email and delete this message, along with any

Thank You

JW V DOJ 01239 DOJ Public Integrity IRS 11515

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

JW V DOJ 01239 DOJ Public Integrity IRS 11515

Uploaded by

Copyright:

Available Formats

Obtained by Judicial Watch, Inc.

U.S. Department of Justice

Office of Enforcement Operations

Washington, D.C. 20530

January 15, 2015

Ramona Raula Cotca, Esq.

Dear Ms. Cotca:

Obtained by Judicial Watch, Inc. via FOIA

Bradley Cohen, Esq.

Obtained by Judicial Watch, Inc. via FOIA

We are good with Wednesday let's book.

Are we confirmed for Wed in Cincy? If so, we will book flights.

Obtained by Judicial Watch, Inc. via FOIA

Obtained by Judicial Watch, Inc. via FOIA

CONSENT AND WAIVER FORM

Obtained by Judicial Watch, Inc. via FOIA

enter into this proffer agreement with respect to a proffer to be made by

knowledge about matters that are the subject

attorneys of the United States concerning

By discussing these matters and by acceptin

ior has the United States made any

any possible federal criminal acts committed by

y the United States, the

Should any prosecution be brought against

United States will not offer in evidence in its case-in-chief against

pursuant to this proffer agreement, except in a

The United States can use information derived from statements by

Should any prosecution ot

ie undertaken, the United States may use

statements as substantive evidence for the purpose of cross-examination o

Obtained by Judicial Watch, Inc. via FOIA

evidence, factual assertions or arguments offered by or on behalf of

at any pretrial, trial

Federal Rules of Criminal Procedure do not apply to any statements made by

waives any right to challenge the

evidence derived from those statements, and

FOR THE *UNITED STATES

FOR THE WITNESS:

Obtained by Judicial Watch, Inc. via FOIA

Let's talk in am if they don't get back to you. Thanks.

They are at IRS counsel's office. I am

On Jun 12, 2013, at 10:28 PM,IllialEaiallMusdoj.gov> wrote:

Obtained by Judicial Watch, Inc. via FOIA

On Jun 12, 2013, at 5:49 PM, '

guys? can provide a conference line that we can call into.

We are good with Wednesday - let's book.

Obtained by Judicial Watch, Inc. via FOIA

Are we confirmed for Wed in Cincy? If so, we will book flights.

a law firm, and may contain legally

Obtained by Judicial Watch, Inc. via FOIA

Just tried you back. I am in the office.

Obtained by Judicial Watch, Inc. via FOIA

Obtained by Judicial Watch, Inc. via FOIA

30 ends. Thank you.

We'll be flexible as well for when

All good with 2:30 here.

Sent from my iPhone

Obtained by Judicial Watch, Inc. via FOIA

I have a 130 that should be done by 230. We will make it work.

On Jun 12, 2013, at 10:34 PM,

Obtained by Judicial Watch, Inc. via FOIA

On Jun 12, 2013, at 5:49 PM,

We are good with Wednesday let's book.