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CERTIFICATE OP SERVICE 
I hereby certify that a true and correct copy of the foregoing Motion to Intervene or in the 
Alternative for a Sua Sponte Rule 11 Order was served on all counsel of record by CMIECF on 
May 3, 2011. 
/s/Bruce Reinhart 
BRUCE REINHART 
4 
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ATTACHMENT TO MOTION 
TO INTERVENE OR IN THE 
ALTERNATIVE FOR A SUA 
SPONTE RULE 11 ORDER 
08-80736CV-INARIZA 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-80736-Civ-Marra/Jolmson 
JANE DOE #1 AND JANE DOE #2, 
Plaintiffs, 
I 
UNITED STATES OF AMERICA, 
Defendant. 
BRUCE E. REINHART, 
Intervenor 
INTERVENOR'S MOTION FOR SANCTIONS 
Comes now, Bruce B. Reinhart, intervenor and party in interest (hereinafter 
"Movant"), and moves this Honorable Court to impose sanctions under Federal Rule of 
Civil Procedure 11(b) and 28 U.S.C. 1927 based on intentional or reckless false, bad 
faith, vexatious factual and legal assertions made about Movant in Paragraphs 52 and 53 
of Plaintiff's Motion for Finding of Violations of the Crime Victims' Rights Act (the 
"Motion") (DE 48]. 
BACKGROUND 
The instant cause of action involves claims by Plaintiffs that Defendant violated 
the Crime Victims Rights Act (CVRA), 18 U.S.C. §3771, in its handling of a criminal 
investigation of Jeffrey Epstein ("Epstein") and others. The investigation ultimately 
resulted in a non-prosecution agreement between the United States and Epstein. On 
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March 21, 2011, Plaintiffs filed their Motion.l Numbered paragraphs 1-50 of the Motion 
are a chronological review of the background of the Epstein investigation, including the 
interactions among the victims' counsel, counsel for Epstein, the Government and the 
FBI. Paragraph 51 asserts that at all relevant times it was feasible for the Government to 
provide certain notifications to Plaintiffs. 
Without attempting to make any connection to the asserted violation of the 
CVRA, Paragraphs 52 and 53 falsely allege that Movant violated Florida Bar rules and 
Department of Justice regulations by representing Epstein's employees in civil litigation 
after Movant retired from the United States Attorney's Office for the Southern District of 
Florida ("Office"). They also falsely allege that Movant, while still employed by the 
Office engaged in improper conduct relating to Epstein. These allegations are made in 
bad faith, unreasonably, without reasonable inquiry into the law and facts, vexatiously, 
and for the improper purpose of gratuitously harassing Movant. 
LEGAL STANDARDS 
Federal Rule of Criminal Procedure 11 
Federal Rule of Civil Procedure 11 states that a lawyer signing any pleading in 
federal court is certifying that: 
[Ty° the best of the person's knowledge, information, and belief, formed 
after an inquiry reasonable under the circumstances: 
(1) it is not being presented for any improper purpose, such as to harass, 
cause unnecessary delay, or needlessly increase the cost of litigation; 
(2) the claims, defenses, and other legal contentions are warranted by 
existing law or by a nonfrivolous argument for extending, modifying, or 
reversing existing law or for establishing new law; 
Movant was not served with a copy of the pleading. Movant first saw the 
pleading on April 20, 2011. 
2 
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1 
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(3) the factual contentions have evidentiary support or, if specifically so 
identified, will likely have evidentiary support after a reasonable 
opportunity for further investigation or discovery. 
Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan ! DaintlerChrysler, 
A.G., 331 F.3d 1251, .1255 (11th Cir. 2003). The analysis is whether "a reasonable 
• 
attorney in like circumstances could believe that his actions were factually and legally 
justified." Id (citing Placard I. Prudential Ira. Co., 307 F.3d 1277, 1294 (11th Cir. 
2002)). Violations of Rule 11 are punishable by monetary and non-monetary sanctions 
against both the lawyer filing the pleading and the lawyer's client. Fed: R Civ. P. 11(c). 
28 U.S.C. 61927 
Title 28, United States Code, Section 1927 states: 
Any attorney or other person admitted to conduct cases in any court of the 
United States or any Territory thereof who so multiplies the proceedings 
in any case unreasonably and vexatiously may be required by the court to 
satisfy personally the excess costs, expense, and attorneys' fees reasonably 
incurred because of such conduct. 
To impose sanctions under § 1927, the Court must find that the attorney's conduct is 
"'tantamount to bad faith.'" Amlong & Amlong, 500 F.3d 1230, 1239 (11th Cir. 2007) 
(quoting Avirgani. Hull, 932 F.2d 1572, 1582 (11th Cir. 1991)). "(Tjhe attorney must 
knowingly or recklessly pursue a frivolous claim." Id at 1242. The finding of bad faith 
does not turn on "the attorney's subjective intent, but on the attorney's objective 
conduct." Id. at 1239. The standard is "whether, regardless of the attorney's subjective 
intentions, the conduct was unreasonable and vexatious when measured against an 
objective standard." Hudson.. Intl Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (11th 
Cir. 2007). 
3 
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DISCUSSION 
Paragraphs 52 and 53 contain inflammatory claims that are false, misleading, and 
irrelevant to the relief sought in the Motion. See generally Declaration of Bruce E. 
Reinhart (attached as Exhibit 1 and incorporated by reference). They ultimately allege, 
"[Movant's) representations [of Epstein's employees] are in contravention of Justice 
Department regulations and Florida bar rules. Such representations also give, at least, the 
improper appearance that Roinhart may have attempted to curry [sic] with Epstein and 
then reap his reward through favorable representation." Plaintiff's Motion at 153. They 
do not cite to any particular bar rule or regulation that they believe was violated. They do 
not explain how the alleged conduct contributed to the Department of Justice's alleged 
violation of the CVRA. Nor do they explain how the alleged conduct is imputable to the 
Department of Justice. These otherwise slanderous accusations against a non-party are 
false. They were made in bad faith, without a factual inquiry reasonable under the 
circumstances, or elementary research into the legal basis for the allegations. 
Paragraphs 52 and 53 omit the following true facts, which Plaintiffs should have 
investigated before making their allegations: (1) Movant did not participate in any way in 
the Office's investigation of Epstein, (2) after leaving government employment, Movant 
did not represent Epstein before the Department of Justice, nor did Movant communicate 
with the Department of Justice about Epstein, and (3) Movant did not use confidential 
information obtained during his Government employment to the detriment of the United 
States. See Declaration of Bruce E. Reinhart at 111-12, 17. 
Rather than conducting the required inquiry, Plaintiffs simply make two 
irresponsible and unsupported leaps. First, they incorrectly conclude that merely because 
4 
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Movant worked in the Office at the time of the Epstein case, Movant Must have been 
involved in the internal decisionmaking at the Office about Epstein. Second, they 
incorrectly conclude that because Movant later represented Epstein's employees in 
private civil litigation, Movant must have used confidential Government information 
improperly in his representation of Epstein's employees, and for his own financial gain. 
It is ipparent that Plaintiffs conducted no factual inquiry to substantiate their 
accusations before making them. They never contacted Movant. On information and 
belief, they did not speak to any current or former personnel from the Office or the FBI 
who were familiar with the structure of the West Palm Beach Office or with Movant's 
role (or lack thereof) in the Epstein investigation. Had they done so, they would have 
learned that there were approximately 20 Assistant United States Attorneys in the West 
Palm Beach Office during the relevant time period. See Declaration of Bruce E. Reinhart 
at ¶10. They would have learned that Movant was not assigned to the same section as the 
prosecutor handling the Epstein matter. Id. They would have learned that Movant had a 
different chain of supervision from the prosecutor assigned to the Epstein matter. Id. 
They would have learned that Movant had no involvement in the Epstein investigation. 
See Declaration of Bruce E. Reinhart at ¶111-12. 
Further, Plaintiffs did not conduct an adequate inquiry into the applicable 
Department of Justice regulations. 
As discussed below, to violate the relevant 
regulations, a former employee must appear before, or communicate with, the 
Department of Justice, about a particular matter in which the former employee 
participated personally and substantially while employed at the Department of Justice. 
See 5 C.F.R. §2641.201(a). The Motion contains approximately 50 paragraphs of a 
5 
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detailed historical litany of the interactions among the parties to the Epstein matter. The 
Motion does not allege that Movant paiticipated at all, let alone personally and 
substantially, as a government employee in the Epstein investigation. The Motion does 
not allege that that Movant subsequently appeared before, or communicated with, the 
Department of Justice about Epstein. To the contrary, the Motion alleges only that, after 
leaving the Office, Movant represented Epstein's employees in litigation with non-
Governmental third parties. Had Plaintiffs conducted rudimentary research into the 
applicable regulations, they would have known that any allegation that Movant violated 
these regulations was frivolous. 
Movant Did Not Violate Any Florida Bar Rule 
Relevant Florida Bar Rules 
The potentially applicable Florida'Bar rules are Rule 4-1.6(a) (Confidentiality of 
Information), Rule 4-1.9 (Conflict of Interest; Former Clients), and Rule 4-1.11 (Special 
Conflicts of Interest for Former and Current Government Officers and Employees). For 
purposes of these rules, the U.S. Department of Justice was Movant's client during his 
employment in the Office. Movant did not violate any of the bar rules. 
Rule 4-1.6(a) states: 
A lawyer shall not reveal information relating to representation of a client 
except as stated in subdivisions (b), (c), and (d), unless the client gives 
informed consent. 
Rule 4-1.6 was not violated because Movant did not know any confidential 
information about the Epstein matter, so none could be revealed. 
Rele 4-1.9 states: 
A lawyer who has formerly represented a client in a matter shall not 
thereafter: 
6 
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(a) represent another person in the same or a substantially related matter 
' in which that person's interests are materially adverse to the interests, 
of the former client unless the former client gives informed consent; or 
(b) use information relating to the representation to the disadvantage of 
the former client except as these rules would permit or require with 
respect to a client or when the information has become generally 
known; or, 
(c) reveal information relating to the representation except as these rules 
would permit or require with respect to a client. 
Rule 4-1.9 was not violated because Movant never represented the United States in the 
Epstein matter. 
Rule 4-1.11 states in pertinent parts: 
(a) A lawyer who has formerly served as a public officer or employee of 
the government: 
(1) is subject to rule 4-1.9(b); and 
(2) shall not otherwise represent a client in connection with a 
matter in which the lawyer participated personally and substantially as a 
public officer or employee, unless the appropriate government agency 
gives its informed consent, confirmed in writing, to the representation. 
(c) A lawyer having information that :he lawyer knows is confidential 
government information about a person acquired when the lawyer was a 
public officer or employee may not represent a private client whose 
interests are adverse to that person in a matter in which the information 
could be used to the material disadvantage of that person. As used in this 
rule, the term "confidential government information" means information 
that has been obtained under governmental authority and which, at the 
time this rule is applied, the government is prohibited by law from 
disclosing to the public or has a legal privilege not to disclose and which is 
not otherwise available to the public. 
(d) A lawyer currently serving as a public officer or employee: 
(1) is subject to rules 4-1.7 and 4.1.9; and 
7 
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(2) shall not: 
(A) participate in a matter in which the lawyer participated 
personally and substantially while in private practice or 
nongovernmental employment, unless the appropriate government 
agency gives its informed consent; or 
(B) negotiate for private employment with any person who 
is involved as a party or as attorney fora party in a matter in which 
the lawyer is participating personally and substantially. 
Rule 4-1.11(a) was not violated because Movant did not participate personally and 
substantially in the Epstein matter. Rule 4-1.11(c) was not violated because Movant did 
not have any confidential Government information within the meaning of the rule, so he 
did he use any confidential Government information about a third party to the detriment 
of that third party. Rule 4-1.11(d) was not violated because Movant did not participate 
personally and substantially in the Epstein matter. 
Maya* Did Not Violate Department of Justice Regulations 
Department of Justice Regulations 
The Department of Justice regulation containing post-employment restrictions, 5 
C.P.R. §2641.201. states in most pertinent part: 
(a) Basic prohibition of 18 U.S.C. 207(aX1). 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 
(i) Participate: To "participate" means to take an action as an employee through 
decision, approval, disapproval, recommendation, the rendering of advice, 
investigation, or other such action, or to purposefully forbear in order to affect 
the outcome of a matter .. . An employee does not participate in a matter 
8 
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31 
merely because he had knowledge of its existence or because it was pending 
under his official responsibility.
Mov.ant did not violate S C.F.R. §2641.201 because he did not participate personally and 
substantially in the Epstein matter as a Government employee. He did not appear before 
the United States on behalf of Epstein after leaving Government employment. He did 
not communicate with the United States on behalf of Epstein after leaving Government 
employment. 
He represented Epstein's employees in civil cases in which the 
Government was not a party. 
' 
It is clear from the face of the regulations that Movant's representing Epstein's 
employees in civil matters not involving the Government did not violate §2641(a). In 
fact, had Plaintiffs and their counsel properly investigated the facts and law, they would 
have seen that §2641(a) would have permitted Movant to represent Epstein, himself, 
openly against the Department of Justice. Movant did not. The allegation that Movant 
violated Department of Justice regulations is frivolous. 
2 A complete copy of this regulation is attached to this Motion as Exhibit 2. 
9 
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CONCLUSION 
The allegations in Paragraph 52 and 53 of the Motion are false, made in bad faith, 
and made without sufficient inquiry into the law and fac. They are irrelevant to whether 
the United States Attorney complied with the CVRA. Notably, the Motion does not 
attempt to tie the allegations against Movant to the alleged violation of the CVRA. The 
allegations are included gratuitously in the Motion solely to harass Movant in a forum 
where the accusations are not legally slanderous. The allegations are made without 
reasonable pre-filing inquiry into the facts or law. This Court should issue an Order to 
Show Cause why sanctions should not be imposed under Rule 11 or 28 U.S.C. §1927. 
Respectfully submitted,
/s/ Bruce E. Reinhart 
BRUCE E. REINHART,P.A. 
Florida Bar # 10762 
250 S. Australian Avenue, Suite 1400 
West Palm Beach, Florida 33401 
(561) 202-6360 fax (561) 202-6976 
Breinhart®BruceReinhartLaw.com 
CERTIFICATE OF SERVICE 
I hereby certify that a true and correct copy of the foregoing Intervenor's Motion 
For Sanctions was served on all counsel of record by CM/ECF on 
2011. 
/s/Bruce Reinhart 
BRUCE REM MART 
10 
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EXHIBIT 1 
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31 
PECLARATION OF BRUCE E. RELN HART 
I, Bruce E. Reinhart, make the following declaration pursuant to 28 U.S.C. §1746. 
1. 
I am a licensed attorney in solo practice as Bruce E. Reinhart, P.A. My office 
is located at 250 S. Australian Avenue, Suite 1400, West Palm Beach, Florida, 
33401. 
2. 
I am a member in good standing of the bars of the states of Florida, 
Pennsylvania, and New Jersey. I am also admitted to the practice in the 
United States District Court for the Southern District of Florida, the U.S. 
Court of Appeals for the Eleventh Circuit, the U.S. Supreme Court, and 
several other federal courts. 
3. 
I graduated from Princeton University in 1984 with a B.S.E. in civil 
engineering cum laude. I graduated from the University of Pennsylvania Law 
School in 1987, cum laude. I also served as an Editor of the University of 
Pennsylvania Law School. 
4. 
After graduating from law school, I served as judicial law clerk to the 
Honorable Norma L. Shapiro, United States District Judge for the Eastern 
District of Pennsylvania. 
5. 
In 1988, I began working at the Criminal Division of the United States 
Department of Justice in Washington, D.C., through the Attorney General's 
Honors Program. From 1988-1994, I worked in the Public Integrity Section 
of the Criminal Division. 
While working there, I received two Special 
Achievement Awards for Meritorious Acts and Service from the 
Department of Justice. 
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Page 2 of 4 
6. 
While at the Public Integrity Section, I was involved in investigating and 
prosecuting people who violated federal conflict of interest and post-
employment statutes. I attended multiple training conferences where federal 
conflicts of interest laws and regulations were discussed. 
7. 
From in or about July 1994 to on or about May 1, 1996, I served as Senior 
Policy Advisor to the Undersecretary of the Treasury for Enforcement at the 
United States Department of the Treasury. 
In that position, I helped. the 
Undersecretary, the Deputy Secretary, and the Secretary of the Treasury to 
develop law enforcement policies for U.S. Customs, ATF, Secret Service, and 
IRS Criminal Investigations. I also acted as principal staff liaison to the 
Deputy Attorney General, the FBI and the other Department of Justice law 
enforcement agencies. For my service, I was awarded the Undersecretary for 
Enforcement's Award for Exceptional Service. 
8. 
I am the former Vice Chair of the Palm Beach County Bar's Professionalism 
Committee. I am the former President of the Palm Beach County Chapter of 
the Federal Bar Association. I currently serve as an Ethics Commissioner on 
the Palm Beach County Commission on Ethics. 
9. 
From May 1, 1996 to January 1, 2008, I served as an Assistant United States 
Attorney in the Southern District of Florida, assigned to the West Palm Beach 
office. From in or about July 1998 to in or about October 2002, I was a 
Supervisory Assistant United States Attorney. From October 2002 to January 
2008, I was a non-supervisory Assistant United States Attorney handling my 
own docket of cases. 
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....
. 
. 
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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, Ann Marie Villafana, and 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 decisionmaking 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 "odt 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 Sarah Kellen for 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 seven] other members of Mr. Epstein's staff in their civil 
depositions. 
15. 
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. 
Beesnse 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 Plaintiffs 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. 
1 declare under penalty of perjury that the foregoing is true and correct. 
Executed on May 3,2011. 
Bruce E. Reinhart 
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EXHIBIT 2 
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•ic 
••••••••• ....... 
• • 
• 
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§ 2641.201 Permanent restriction on any fanner employee's..., II C.F.R. *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 ln which the employee participated personally and substantially. 
Effective: July 25, 2008 
Currentness 
(a) Basic prohibition of till U.S.C. 207(aX1). No forma 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 die United States is a party or has a direct and substantial interest 
(b) Exceptions and waiver. The prohibition of 18 U.S.C. 207(aXI) does not apply to a forma employee who is: 
(1) Acting on behalf of the United States. See § 2641.301(a). 
(2) Acting as an elected State or local government official. See § 2641301(b). 
(3) Communicating scientific or technological information pursuant to procedures or certification. See § 2641.301(e). 
(4) Testifying under oath. See *2641_301(0. (Note that this exception from 12641.201 is generally not available for expert 
testimony. See § 2641.301(f)(2).) 
(5) Acting on behalf of an international organization pursuant to a waiver. See § 2641.301(h). 
(6) Acting as an employee of a Govemment-owned, contractor-operated entity pursuant to a waiver. See § 2641.301(i). 
(e) Commencement and length of restriction. 18 U.S.C. 207(a)(1) is a permanent 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 transmits 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 comrnunicatiors with respect to 
which the former employee intends that the information conveyed will be attributed to himself, although it is not necessary 
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 
States, in either a formal or informal setting. Although an appearance also maybe accompanied by certain communications, 
an appearance need not involve any communication by the former employee. 
WrAlloMslext 0 2011 Thomson Reuters. No clalin to original U.B. Government Works. 
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2541.201 Permanent restriction on any former employee's.., 5 C.F.R. 12641.201 
(3) Behind-the-scenes assistance. Nothing in this section prohibits a former employee from providing assistance to another 
person, provided that the insistence 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 muter, she will have made an appearance. 
Example 2 to paragraph (O 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 for agricultural research with Q 
Company. Upon termination of her Government employment, she is hired by Q Company. Stn 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 her former agency who should be contacted and what should be said to them in an effort to increase 
the scope of funding of the contract and to resolve favorably a dispute over a contract clause. She may do so. 
Example 4 to paragraph (d): A former employee of the National Institutes of Health (NIH) prepares an application for an NTH 
research grant on behalf of her university employer. The application is signed and submitted by another university officer, but it 
lists the former employee as the principal investigator who will be responsible for the substantive work under the grant She has 
cot madea communication. She also may sign an assurance to the agency that she will bepersonally responsible for the direction 
and conduct of the research under die grant, pursuant to § 2641.201(eX2)(v). Moreover, aka may personally communicate 
scientific or technological information to NM concerning the application, provided that she does so under circumstances 
indicating no intent to influence the Government pursuant to § 2641.201(0)(2) or she makes the communication in accordance 
with the exception for scientific or technological information is § 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 expects 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 communication and not 
merely confining herself to behind-the-scenes assistance, because the circumstances indicate that she intended the information 
to be attributed to herself: 
(e) With the intent to influence
-
(I) Basic concept. The prohibition applies only to communications or appearanece made by a former Governmentemployee 
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 poundal dispute or controversy. 
Example I to paragraph (eXI): A former employee of the Administration on Children and Families (ACF) signs a grant 
application and submits it to ACE onbehalfof a nonprofit organization for which shenow works. Site hasmade 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. 
WestlawNext 0 2011 Thomson Reuters. No claim to original U.S. Government Works. 
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