Dear Director Ragsdale:
We write to follow up about two developments relevant to our October 4, 2019, request that your office review the conduct of John Gore, former Principal Deputy Assistant Attorney General of the Civil Rights Division of the Department of Justice (DOJ, or the Department), as well as other attorneys representing DOJ in matters involving Mr. Gore.
First, please find attached DOJ's November 18, 2019, submission filed in the United States District Court for the Southern District of New York, in the litigation underlying our October 4 referral, Brennan Center for Justice et al. v. U.S. Dep't of Justice et al., 17 Civ. 6335. See Exhibit A. After plaintiffs in that matter brought our October 4 referral to the court's attention, DOJ filed this letter indicating that it had "recently learned additional information indicating that certain statements in Mr. Gore's declaration (and by extension, defendants' prior motion papers) require correction." The letter acknowledges that Mr. Gore's previous sworn statement describing the nature of his relationship with a Republican Party election official, described in our October 4 referral, was inaccurate. In the event that this development has not yet been brought to your attention, we thought it would be relevant to your review.
Second, a November 12, 2019, memo from the House Committee on Oversight and Reform details new evidence implicating Mr. Gore's truthfulness in litigation regarding the origins of a letter requesting the addition of a question about citizenship to the Census. This evidence casts further doubt on Mr. Gore's credibility and raises concerns about DOJ's continued reliance on his testimony. Enclosed please find the House Committee on Oversight and Reform's November 12, 2019, oversight report (Exhibit B) and Plaintiffs' Motion for Leave to File Sur-reply in Support of Sanctions in State of New York, et al. v. U.S. Dep't of Commerce, et al., which, again, we believe should be relevant to your review (Exhibit C).
Thank you for your prompt attention to this matter.