Case 1:21-cr-00245-AJT Document 37 Filed 12/24/21 Page 1 of 3 PageID# 180

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division

UNITED STATES OF AMERICA :

:
v. : Criminal No. 21-CR-245 (AJT)
:
IGOR Y. DANCHENKO, :
:
Defendant. :

NOTICE OF DEFENDANT IGOR Y. DANCHENKO’S

WAIVER OF ANY ACTUAL OR POTENTIAL CONFLICTS OF INTEREST

Igor Y. Danchenko, by and through counsel, hereby provides notice of his waiver of any

actual or potential conflicts of interest raised by the United States’ Motion to Inquire Into Potential

Conflicts of Interest. Dkt. 35. Since the government filed its motion, Mr. Danchenko has

consulted with his own counsel as well as with separate and independent counsel, Nina J. Ginsberg.

Following those consultations, and in light of the fact that his counsel’s law firm has agreed to

wall off any attorneys or support staff who have previously worked on the representation of the

Clinton campaign, Mr. Danchenko has knowingly, intelligently, and voluntarily waived any

potential conflicts of interest. See Exhibit 1 (Waiver of Potential Conflicts of Interest). 1

1
The Court ordered defendant to file an executed waiver of any actual or potential conflicts of
interest by December 24, 2021. Dkt. 34. However, because Mr. Danchenko is currently traveling
with his family, he was unable to physically sign and return a copy of the attached Waiver by the
Court’s December 24, 2021, deadline. Undersigned counsel has reviewed the attached Waiver with
Mr. Danchenko and he has consented to its filing and has authorized counsel to electronically sign
the Waiver on his behalf. Mr. Danchenko will physically sign an additional copy of the Waiver
upon his return to the District, which will be filed with the Court.
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Case 1:21-cr-00245-AJT Document 37 Filed 12/24/21 Page 2 of 3 PageID# 181

Respectfully submitted,

IGOR Y. DANCHENKO
By Counsel

/s/ Stuart A. Sears

Stuart A. Sears
VA Bar 71436
Attorney for Igor Y. Danchenko
SCHERTLER ONORATO MEAD & SEARS, LLP
901 New York Avenue, N.W.
Suite 500 West
Washington, DC 20004
Telephone: (202) 628-4199
Facsimile: (202) 628-4177
ssears@schertlerlaw.com

2
 Case 1:21-cr-00245-AJT Document 37 Filed 12/24/21 Page 3 of 3 PageID# 182

CERTIFICATE OF SERVICE

I hereby certify that on this 24th day of December, 2021, I electronically filed a true copy

of the foregoing motion with the Clerk of Court using the CM/ECF system, which will send a

notification of such filing (NEF) to all parties.

/s/ Stuart A. Sears

Stuart A. Sears
VA Bar 71436
Attorney for Igor Y. Danchenko
SCHERTLER ONORATO MEAD & SEARS, LLP
901 New York Avenue, N.W.
Suite 500 West
Washington, DC 20004
Telephone: (202) 628-4199
Facsimile: (202) 628-4177
ssears@schertlerlaw.com

3
 Case 1:21-cr-00245-AJT Document 37-1 Filed 12/24/21 Page 1 of 1 PageID# 183

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division

UNITED STATES OF AMERICA :

:
v. : Criminal No. 21-CR-245 (AJT)
:
IGOR Y. DANCHENKO, :
:
Defendant. :

WAIVER OF ACTUAL OR POTENTIAL CONFLICTS OF INTEREST

I, Igor Y. Danchenko, have reviewed the government’s motion to inquire into potential

conflicts of interest (Dkt. 35) that may arise as a result of my continued representation by Danny

C. Onorato and Stuart A. Sears, and the law firm of Schertler Onorato Mead & Sears, LLP. I have

discussed the government’s motion and any actual or potential conflicts of interest with my

attorneys and how they could impact their representation of me. In addition, and on the advice of

Mr. Onorato and Mr. Sears, I have consulted with independent legal counsel. Specifically, I

reviewed and discussed the government’s motion with Nina J. Ginsberg, a partner at the law firm

of DiMuroGinsberg P.C. Based on my conversations with Mr. Onorato and Mr. Sears, as well as

my separate consultation with Ms. Ginsberg, I believe I have a full understanding of any actual or

potential conflicts of interest that might arise during the course of my representation. With that

knowledge and understanding, I voluntarily waive any actual or potential conflicts of interest, and

choose to continue with my current counsel of choice, Danny C. Onorato and Stuart A. Sears.

/s/ Igor Y. Danchenko 12/24/2021

Igor Y. Danchenko Date