UNITED STATES HOUSE OF REPRESENTATIVES

OFFICE OF CONGRESSIONAL ETHICS

THE DEMOCRATIC COALIATION, )

SCOTT DWORKIN AND )
J. WHITFIELD LARRABEE )
Complainants )
)
v. )
) COMPLAINT
)
REPRESENTATIVE LAUREN BOEBERT )
Member )
)

INTRODUCTION

1. This is a complaint against Lauren Boebert (“Boebert”), who is a Member of the House of
Representatives. Boebert violated the House Code of Official Conduct (House Rule 23,
clauses 1 and 4, House Rule 25, clause 5) by accepting a firearm and other gifts valued in
excess of $100.00 while in office and by behaving in a manner that brings discredit to the
House of Representatives. By unlawfully accepting gifts from “Boots on the Ground
Bikers for Trump,” Boebert has violated the ethical code of the House, has corruptly
profited from her office, has acted dishonestly, and has violated the duties she owes to the
people of Colorado and to the people of the United States.

PARTIES

2. The complainant, The Democratic Coalition, is a political committee based in Washington,

D.C..

3. The complainant, Scott Dworkin, is a United States citizen and resident of Washington,
D.C.. He is the Executive Director of The Democratic Coalition.

4. The complainant, J. Whitfield Larrabee, is an attorney licensed to practice law in the

Commonwealth of Massachusetts. He is a citizen of the United States. His address is 891
Centre Street, Suite 200, Jamaica Plain, Massachusetts 02130.

5. Lauren Boebert is a newly elected Member of the United States House of Representatives
presently representing Colorado's 3rd Congressional District.

FACTUAL AND LEGAL BASIS FOR THE COMPLAINT

6. On Sunday, January 24, 2020, Boebert accepted prohibited gifts having a value of greater
than $100 from a group called “Boots on the Ground Bikers for Trump.”
7. Rule 25, Clause 5, only permits Members to accept gifts with “a value of less than $50 and
a cumulative value from one source during a calendar year of less than $100.”

8. Boebert accepted a gift from Bikers for Trump of a personalized Glock 22 .40 caliber
firearm engraved with the words “Congresswoman Lauren Boebert” and “Bikers for
Trump” along with the Congressional insignia. Online retailer GlockStore.com of San
Diego, California, sells a comparable Glock firearm, without custom engravings, for
$499-$549.

9. Below is an image of a Facebook post where Boebert can be observed in a video accepting
the gifts. The complainants’ attorney can provide a copy of the video to House
investigators upon request.

10. Below is an image captured from the video of Broebert holding the firearm after she
unlawfully accepted the gift.

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11. In addition, Boebert accepted a gift from Bikers for Trump of a customized “shadow box”
container for the firearm together with a box of ammunition with an estimated value of
over $100.00.

12. There is no indication from the member’s conduct or statements that she declined the gift,
paid for it, or otherwise donated it. There is no indication that this illegal gift falls under the
exceptions of House Rule 25, Clause 5.

13. The purpose of the House rules limiting Members’ acceptance of gifts is to prevent
members from corruptly profiting from their offices and to prevent them from being
improperly influenced by gifts and bribes. By violating the rules, Boebert acted corruptly
and brought discredit to the House of Representatives.

WHEREFORE, the complainants demand:

 that the Office of Congressional Ethics review and investigate this complaint;

 that the Office of Congressional Ethics issue and publicly release a report

concerning this complaint;

 that the Office of Congressional Ethics refers the matter to the House Ethics

Committee for appropriate action; and

 such other relief as is just, lawful, equitable, or proper.

I affirm that to the best of my knowledge and ability all evidence submitted was not
obtained in violation of any law, rule, or regulation. I acknowledge that Section 1001 of title 18
of the United States Code (popularly known as the False Statements Act) applies to the
information provided.

[Continued on the following page.]

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DATED: January 26, 2021

Respectfully submitted,
J.Whitfield Larrabee, individually and
as attorney for Scott Dworkin and
The Democratic Coalition,

J. Whitfield Larrabee
Law Office of J. Whitfield Larrabee
891 Centre Street, Suite 200
Jamaica Plain, MA 02130
jw.larrabee@verizon.net
(857) 991-9894

CERTIFICATE OF SERVICE AND FILING

I, J. Whitfield Larrabee, hereby certify that on January 26, 2021, I filed this complaint
with the Office of Congressional Ethics by emailing it to oce@mail.house.gov.

J. Whitfield Larrabee