October 14, 2013 Michael F.A. Morehart State Inspector General 1111 East Broad St.

, Suite 2024 Richmond, VA, 23219 The Honorable Robert F. McDonnell Governor of Virginia 1111 East Broad St., 3rd Floor Richmond, VA, 23219 The Honorable Kenneth Cuccinelli Attorney General of Virginia 900 East Main Street Richmond, VA 23219 Dear Inspector General Morehart, Governor McDonnell and Attorney General Cuccinelli, Today I write to request that the Office of the Inspector General open an investigation into the matter that has recently come to my attention involving the Attorney General Ken Cuccinelli and his Deputy Attorney General Richard Neels handling of Star Scientific and CEO Jonnie Williams lawsuit against the Commonwealth in dispute of the tax assessment he received from Virginia. As you know, this case became controversial when it was revealed that Williams lawsuit, an effort to avoid paying $1.7 million in state taxes and interest, had sat in the Office of the Attorney General for nearly two years while Cuccinelli received thousands in gifts from Williams and Star and bought stock in the company. Under public pressure, Cuccinelli finally recused himself from the case and appointed outside counsel to move the case forward. Before that happened however, Mr. Cuccinelli and his office began handling the case in a way that is troubling and deserving of further investigation to ensure that no legal or ethical standards were violated. In 2010 when he first took office, Attorney General Cuccinelli and several members of his staff made use of Jonnie Williams Goochland County mansion while they made the transition to Richmond. Despite leaving other gifts off of his Statements of Economic Interest, Cuccinelli did list his stay with Williams as a gift in early 2011, as did the other staffers who were required to file such forms. One of the staffers who benefitted from Williams gift of free lodging was Richard Neel, whom Cuccinelli had appointed as Deputy Attorney General for the Technology, Real Estate, Environmental, Finance & Transportation (TREEFT)

Division. The same division was later responsible for opposing Jonnie Williams and Star Scientific in their lawsuit over $1.7 million in unpaid taxes. Given the many questions that still remain about how Williams may have hoped to benefit from the financial patronage he gave to Attorney General Cuccinelli and Governor McDonnell, Virginians are right to be concerned that the division responsible for representing them in the Star tax case was headed by a staffer who had received hundreds of dollars in free lodging from Williams. That is why I write today to request that Inspector General Morehart investigate whether that troubling arrangement violated Virginias legal or ethical standards of conduct, and that Attorney General Cuccinelli welcome such an investigation. Allowing a staffer with a financial relationship with Williams to oversee Virginias response (or lack of response) to his companys lawsuit was certainly wrong, but Virginians deserve to know if it was illegal and why the Attorney General did not put a stop to that clear conflict of interest, as well as his own. I hope you will agree to investigate this matter and give Virginians the information they deserve about the latest development in this troubling conlict of interest scandal. Thank you, Lauren Harmon Democratic Party of Virginia