
Case 1:24-cr-00556-DEH Document 124 Filed 02/17/25
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Mr. Adams’ criticism of the Biden administration’s “immigration policies before the charges were
filed.” Mr. Bove cites zero proof of such a causal connection.
Mr. Bove speculates that “the former US Attorney’s public actions created appearances of
impropriety,” without specifying any proof in the memo. Exhibit A, p. 1. Mr. Bove made a feeble
effort to provide such proof in a letter to Ms. Sassoon three days later on February 13, 2025, accepting
her resignation as the Acting U.S. Attorney. The letter is annexed hereto as Exhibit B.
Mr. Bove asserted there was the creation of an appearance of impropriety with the conclusory
politically charged statement that the investigation into Mr. Adams was “led by a former U.S. Attorney
with deep connections to the former Attorney General who oversaw the weaponization of the Justice
Department.” Mr. Bove also claimed that “in late – December 2024, the former U.S. Attorney launched
a personal website- which closely resembles a campaign website–that touts articles about the ongoing
prosecution of Mayor Adams.” Exhibit B, pp. 3-4.
In a letter to Attorney General Pam Bondi, dated February 12, 2024, annexed to this letter as Exhibit
C, Ms. Sassoon responded to Mr. Bove’s unsupported claims. As to Mr. Williams’ involvement in the
Adams prosecution, she informed Attorney General Bondi that “[t]he investigation began before Mr.
Williams took office, he did not manage the day-to-day investigation, and the charges in this case were
recommended or approved by four experienced career prosecutors, the Chiefs of the SDNY Public
Corruption Unit, and career prosecutors at the Public Integrity Section of the Justice Department. Mr.
Williams’s decision to ratify their recommendations does not taint the charging decision.” Exhibit C, p.
4.
Ms. Sassoon wrote that “[r]egarding the timing of the indictment, the decision to charge in September
2024 nine months before the June 2025 Democratic Mayoral Primary and more than a year before
the November 2025 Mayoral Election- complied in every respect with longstanding Department policy
regarding election year sensitivities and the applicable Justice Manual provisions.”
She further wrote that “I am not aware of any instance in which the Department of Justice has
concluded that an indictment brought this far in advance of an election is improper because it may be
pending during an election cycle, let alone that a validly returned and factually supported indictment
should be dismissed on this basis.” Exhibit C, p. 4. DOJ provides no evidence in its motion to the
contrary.
There is nothing in the Bove memo or Mr. Bove’s other attempts to support his statement that a proper
jury could not be assembled through a normal voir dire process of the court questioning individual
jurors as to whether each can be fair and impartial. The fact the trial was scheduled before the June
Democratic primary is not relevant since, as Ms. Sassoon explained, “Adams has selected the timing of
the trial.” Exhibit C, p. 3.
In its motion, DOJ further argues the false claims that Mr. Bove “also concluded that continuing these
proceedings would interfere with the defendant’s ability to govern in New York City, which poses
unacceptable threats to public safety, national security, and related federal immigration initiatives and
policies.” DOJ’s motion represents that Mr. Bove “reached that conclusion after learning, among other
things, that as a result of these proceedings, Mr. Adams has been denied access to sensitive information
that the Acting Deputy Attorney General believes is necessary for Adams to govern and to help protect
the City.” Mr. Bove’s memo to Ms. Sassoon raises a similar bogus argument. Exhibit B, p. 6.
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