Brian R.

Della Rocca, Esquire

51 Monroe Street, Suite 408
Rockville, Maryland 20850
Phone: 240/560-3030
Fax: 301/740-2297
Email: bdellarocca@compass-law.com

February 6, 2023

VIA FEDEX AND EMAIL

Merrick B. Garland
Attorney General of the United States of America
U.S. Department of Justice
950 Pennsylvania Avenue, NW
Washington, DC 20530

Re: Hunter Biden’s Request for Investigation of

John Paul Mac Isaac and Yaacov Apelbaum

Dear Attorney General Garland:

I represent both John Paul Mac Isaac and Yaacov Apelbaum, two individuals named in the letter
to Mr. Matthew G. Olsen, Esquire, Assistant Attorney General for National Security, dated February 1,
2023 (“Biden Demand Letter”), from Hunter Biden’s attorney, Abbe David Lowell (“Mr. Lowell”). I
write in response to the baseless allegations contained in the Biden Demand Letter and to correct the
many inaccuracies contained in the letter. While I respect your office’s ability to differentiate between a
political ploy and a real legal request, I am compelled to write because my clients have become the
victim of these unethical political games masked as a legal request.

I am concerned, as I am sure you are, that the Biden Demand Letter not only contains potential
violations of U.S. law – using false information to report an alleged crime – but also ethical violations –
Mr. Lowell knowingly using false information to report an alleged crime and allowing that information
to be disseminated to the media.

As many of the “facts” in the Biden Demand Letter are false, I offer the information below to
provide the verifiable facts in the event you are actually considering acting on Mr. Lowell’s request.

Yaacov Apelbaum

The Biden Demand Letter first falsely asserts that Yaacov was “working with Senator Ron
Johnson’s office” when Hunter Biden dropped of his laptop with John Paul. We are unsure from where
this information came but it is false as Yaacov has never worked with Senator Johnson’s office. This
would have been easy to verify, had the author of the Biden Demand Letter attempted to do so.

The Biden Demand Letter also seems to purposely mislead when it states that Yaacov “came to
Delaware and assisted John Paul in creating a ‘forensic image’ of the hard drive left in his store.” In
“support” of this claim, Mr. Lowell cites John Paul’s book and a Daily Mail article, “EXCLUSIVE:

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High Living Hunter Biden blew tens of thousands on prostitutes, drugs and luxury cars, was desperate
to avoid jail for $320k in unpaid taxes and threatened to take money from his daughter’s college fund.”1

The page cited in John Paul’s book (P. 177) and a few pages prior merely explain John Paul’s
first interaction with Yaacov after the NY Post story broke. Yaacov was hired to assist John Paul in
analyzing the information on the laptop, responding to false claims about John Paul and the laptop, and
sharing with the FBI potential evidence of national security breaches and espionage activity found on
the laptop. 2

In the Daily Mail article, the only mention of Yaacov is that “he was asked to analyze the laptop's
hard drive by the repair store owner's father after he became concerned its contents showed criminal
activity and undue Chinese influence on the then-presidential candidate's son.”

Nowhere in either source is Mr. Apelbaum identified as working for Senator Johnson’s office.
Nor does either source reference Mr. Apelbaum as assisting Mr. Mac Isaac in the creation of a “forensic
image” of the hard drive left by Hunter Biden. Mr. Apelbaum did no such thing and Mr. Lowell cited
no facts to back up his allegation of criminality against Mr. Apelbaum.

In effect, Mr. Lowell has provided a false statement to law enforcement about alleged crimes
committed by Mr. Apelbaum without any shred of proof.

John Paul Mac Isaac

My primary concern with Mr. Lowell’s and Hunter Biden’s request for a criminal investigation
into John Paul is that the request came immediately after Hunter Biden was served in John Paul’s case
against Hunter Biden and others. The lawsuit was filed on October on October 17, 2022, in the Superior
Court of Delaware in Newcastle County (Case No. S22C-10-012 RHR). It was exceedingly difficult to
locate Hunter Biden to serve him. After attempts to contact Hunter Biden’s various attorneys and either
receiving no response or a curt, “No,” in response to whether the attorney can accept service on Hunter
Biden’s behalf, we hired a private investigator to find him. The private investigator was successful and
we were able to serve Hunter Biden on January 27, 2023.

Whispers of a Hunter Biden “offensive” had been circulating in the media prior to serving Hunter
Biden but the whispers never mentioned John Paul. Now, John Paul’s name is a major component in Mr.
Lowell’s letters. The letters wreak of an attempt to intimidate John Paul and should be viewed as such.

Hunter Biden seems to be using every resource he has against John Paul. John Paul has suffered
the loss of his business, friendships, and lives in constant fear. It is time to let Hunter Biden know that
enough is enough.

A. Identification of Hunter Biden by John Paul-

I would first like to settle the question of whether John Paul knew it was Hunter Biden in The
Mac Shop on April 12, 2019, so we can move forward with that truth. On that date, Hunter Biden entered
The Mac Shop with three damaged laptops. At first, John Paul did not know with whom he was

1
https://www.dailymail.co.uk/news/article-9339527/Hunter-Biden-blew-tens-thousands-prostitutes-drugs-luxury-cars.html
2
Yaacov sent information the FBI in October 2020.

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interacting, he was just listening to the customer’s computer issues. When Hunter Biden told John Paul
his name, John Paul did not question that it was Hunter Biden nor did his vision prevent him from
knowing it was Hunter Biden. By the conclusion of that first meeting, during which John Paul gave
Hunter Biden an external keyboard with which he could access one of the three laptops, 3 John Paul knew
he was dealing with Hunter Biden. 4

A few days later, at John Paul’s request, Hunter Biden returned to The Mac Shop to drop off an
external hard drive to which John Paul could transfer the recovered data. 5 The data was then transferred
to the external hard drive and, upon completion, Hunter Biden was notified and asked to pick up the hard
drive and laptop. An electronic invoice for $85 was sent to Hunter Biden. John Paul never heard from
Hunter Biden nor was his invoice ever paid.

The fact that John Paul is legally blind did not render him unable to identify with whom he was
working. While it may have created a difficulty identifying Hunter Biden in the beginning, to argue that
his visual disability prevented him from using his other senses and his intelligence to identify his
customer shows a level of ignorance and discrimination towards people living with difficulties.

B. Consent

Throughout the letter, Mr. Lowell falsely states that John Paul “admitted to [fill in the blank]
without Hunter Biden’s consent.” If you take Mr. Lowell for his word, which, as shown above, you
should not, then it definitely sounds like John Paul might be the bad person described in the letter.
However, if you analyze each of these statements, they are verifiably false. 6

John Paul received Hunter Biden’s consent to access his laptop when Hunter Biden signed off
on the work authorization while at The Mac Shop on April 12, 2019. 7 Proof of that continued consent is
shown when Hunter Biden returns to The Mac Shop with the external hard drive a few days later.

Pursuant to the work order, signed by Hunter, when he failed to retrieve his laptop and the hard
drive to which the data was recovered more than 90 days later, it became abandoned property so John

3
John Paul never requested payment for the external keyboard despite Hunter Biden leaving with the external keyboard. He
just gave it to Hunter Biden which shows the type of business owner he was. To John Paul, the customer always came first
and should not be nickeled and dimed.
4
Mr. Lowell cites a Daily Beast article in support of his claim that John Paul could not see that it was actually Hunter
Biden in the store. This article was John Paul’s first “interview” where John Paul was “approached” by numerous
journalists who said they would not leave his store until he speaks with them. The intimidation, his lack of experience with
the press, and his nervousness over how to answer so his words would not be twisted resulted in the now famous “bizarre
interview.” In reality, the interview was a playground ambush where a group of bully journalists attacked John Paul and
threatened him if he did not participate.
5
John Paul initially had to recover the data to the store’s server and then transferred the data onto the external hard drive
provided by Hunter Biden.
6
One can only assume that Mr. Lowell anticipated that this letter would not be taken seriously by your office and that
leaking the letter to the media was extremely important because he anticipated the public would not scrutinize the claims
and that the “court of public opinion” would be skewed towards Hunter Biden.
7
Mr. Lowell cites an article containing John Paul’s first “interview,” where John Paul was “approached” by numerous
journalists who said they would not leave until he says something to him. The intimidation, his lack of experience with the
press, and his nervousness over what he should say resulted in the now famous “bizarre interview.” In reality, it was a
playground brawl between John Paul and the journalists which ended with the group of journalists claiming victory.

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Paul could dispose of it as he saw fit. John Paul determined the best disposal of the laptop and hard drive
would be to turn them over to the authorities and he was within his right to do that.

C. Unlawful Sharing of Property with Third Parties

Mr. Lowell claims that John Paul shared Hunter Biden’s property with third parties. This is a
very nuanced claim.

John Paul did share the original laptop and external hard drive with the FBI in December 2019. 8
Thereafter, while watching the impeachment hearings against President Trump in 2020, John Paul was
concerned that there was no mention of the information on the laptop. It seemed as if no one even knew
about the laptop.

At that point, John Paul decided that he would try to get the information to Congress. When his
efforts failed, he went to President Trump’s attorney, Rudy Giuliani. At no point did John Paul approach
the media or anyone other than someone who might be able to review and use the information on the
laptop as a defense in the impeachment hearings. In reality, approaching Giuliani made the most sense
because he represented President Trump, who was defending allegations against him in impeachment
proceedings. Whether you believe President Trump should have been impeached or not, John Paul did
the right thing in approaching the President’s attorney with evidence that may help in the President’s
defense. Everyone deserves a full and fair defense.

John Paul did not provide the information to any other parties until after the NY Post story broke.
At that time, the data was provided to the undersigned counsel and to Mr. Apelbaum who was hired to
analyze the authenticity of the data and respond to false claims about the data to protect John Paul from
people who were trying make him seem like a political plant.

D. “The Biden-Laptop-From-Hell-Rally”

“The Biden-Laptop-From-Hell-Rally” to which the letter refers was a campaign event for
candidate for Senate, Jackson Lahmeyer. John Paul was invited to attend the rally but had no part in the
organization of the rally. At the rally, attendees were given thumb drive containing information from
the laptop that had already been released publicly. This fact is easily verifiable.

John Paul has never released information from the laptop on his own. In fact, it was never his
intent that the contents of the laptop ever be released to the public. His purpose in turning over the laptop
was to get it in the hands of law enforcement.

E. Profiting Off the Laptop

John Paul has not profited off the contents of the laptop. He has never been paid for the
information on the laptop nor has he even accepted reimbursement for the cost of the external hard drive
sent to Mr. Costello.9 John Paul’s book does not contain any information from the laptop that has not
already been released publicly by others.

8
John Paul retained a copy of the recovered data for himself for reasons that are even more obvious to everyone now.
9
Mr. Costello offered to reimburse John Paul for the cost of the hard drive but John Paul purposely refused because he did
not ever want it to look like he accepted money for the hard drive.

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 John Paul is just trying to earn a living since The Mac Shop had to be closed due to the negative
stories that circulated about him after the publication of the NY Post story. Hunter Biden and Mr. Lowell
seem intent on making sure John Paul can never earn a living.

Working with Biden Political Enemies

Neither John Paul nor Yaacov have ever spoken with Mr. Giuliani or Mr. Bannon. John Paul
spoke with Mr. Costello in his quest to get the data from the laptop to President Trump during his
impeachment hearings. At no point was John Paul involved in any political discussions.

Further, both John Paul and Yaacov refused requests by Mr. Maxey and Mr. Ziegler to work with
them since they seemed to be pursuing political attacks that were not of interest to John Paul and Yaacov.
Not only were John Paul and Yaacov wary of Mr. Maxey’s and Mr. Ziegler’s motives, they also publicly
questioned the legitimacy of the information being presented to the public by Mr. Maxey and Mr. Ziegler.

Conclusion

Perhaps an investigation should ensue – against Hunter Biden and Mr. Lowell. During that
investigation, perhaps Hunter Biden should provide verifiable evidence of his whereabouts on April 12,
2019, and the days following. This information has never been presented nor has anyone asked Hunter
Biden for it. However, such an inquiry could resolve many of the lies being levied at John Paul.

As I have shown herein, Hunter Biden and his attorney, Mr. Lowell, have likely violated both
U.S. law and their ethical obligations as attorneys. In my view, if your office does anything more than
throw out the letter from Mr. Lowell, especially after receiving this clarification letter, then one must
question whether politics is overshadowing legal reasoning.

Please feel free to contact me with any questions you may have.

Very truly yours,

Brian R. Della Rocca, Esq.

cc: Mr. John Paul Mac Isaac (via email)

Mr. Yaacov Apelbaum (via email)
Hamilton P. Fox III, Esquire (via email)

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