June 29, 2023

The Hon. Maryellen Noreika

United States District Judge

J. Caleb Boggs Federal Building

844 North King Street, Unit 19, Room 4324

Wilmington, DE 19801-3555

Dear Judge Noreika,

I am writing to request that you reject the proposed plea deal to be offered by the government to Robert Hunter Biden (“Hunter Biden”), the son of President Joseph R. Biden, Jr. Like most Americans, you probably are aware of recent media reports and statements by members of Congress regarding undisclosed and, possibly, unlawful business dealings between Hunter Biden and foreign allies and adversaries of the United States.

On June 20, 2023, United States Attorney David C. Weiss, District of Delaware, filed a letter with the Clerk of the Court asking that two Informations be docketed in criminal matters involving Hunter Biden. One Information charges two misdemeanor counts of tax evasion while the second charges a firearms offense. Mr. Weiss’s letter requested the Court to schedule a consolidated Initial Appearance on the firearm Information and an initial Appearance and Change of Plea Hearing on the tax Information charges. In addition, Mr. Weiss’s letter stated that a Memorandum of Plea Agreement related to these charges will be submitted to the Court at or in advance of the Hearing. In response to Mr. Weiss’s requests, a  Hearing before you on this matter has been scheduled for July 26, 2023.

Recently, senior investigators of the Internal Revenue Service (“IRS”) have claimed that their years-long investigation of Hunter Biden under the direction of U.S. Attorney Weiss was impeded repeatedly by higher-ups in the IRS and the Department of Justice. Sworn testimony by these career officers conflicts significantly with statements made to Congress by Attorney General Merritt Garland and U.S. Attorney Weiss. Under these circumstances, prudence requires further investigation to ascertain the truth.

As the district court judge assigned to review and approve any plea agreement submitted in connection with this case, you are uniquely situated to play an important role in ensuring that Justice is served in this matter. With respect to plea agreements, the Department of Justice Manual and guidance to prosecutors, in pertinent part, states that “Plea agreements should reflect the totality of a defendant’s conduct.” (Ref: DOJM 9-27.400)

By any measure, the Hunter Biden plea deal –what little we know of it– smacks of favoritism. As the presiding judge in this case, you have the power to reject a flawed plea agreement. You also have the power to inquire into the totality of the defendant’s conduct as you weigh the merits of a plea agreement that is likely to deviate substantially from Department of Justice policy.

For these reasons and more, I respectfully request that you consider rejecting the Hunter Biden plea agreement in the interest of Justice and preservation of the rule of law.

Thank you for your service to our nation.


Dr. John J. Coleman

Assistant Administrator (Ret.), U.S. Drug Enforcement Administration

Letter to Judge Maryellen Noreika, District of DE, re: Hunter Biden

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