October 19, 2018
Covington & Burling
Attn: General Counsel’s Office
One CityCenter
850 Tenth Street, NW
Washington, DC 20001-4956
Dear General Counsel of Covington & Burling:
The Project On Government Oversight (POGO) is creating a Department of Defense Revolving
Door Database on its website (pogo.org), which compiles information from public resources
regarding former senior Department of Defense officials and military officers who went on to
work for government contractors, including Covington & Burling, from 2008 to the present. The
database is an attempt to track individuals when they leave the Department of Defense, and
inclusion in the database does not represent anything illegal or a violation of ethics rules. I have
enclosed the findings relevant to Covington & Burling and am requesting verification or
refutation of the data from you.
Any response would be greatly appreciated, as the accuracy of this information is in the best
interest of all parties. When a precise start date was not publicly available POGO chose the first
day of the month the employee said they began working for Covington & Burling. POGO is also
interested in any related ethics opinions issued for current or former Covington & Burling
personnel in compliance with the National Defense Authorization Act for Fiscal Year 2008,
Public Law 110-181, Sec. 847 and certifications of compliance as required by Defense Federal
Acquisition Regulation Supplement (DFARS) subpart 252.203-7005; 41 U.S.C. § 2105(c).
Please be assured that out of fairness to Covington & Burling, any response received by POGO
will be posted on the website along with the data if you so choose.
If you have any questions, I can be reached at (202) 347-1122 or msmithberger@pogo.org.
Thank you for your time and consideration.
Sincerely,
Mandy Smithberger
Director, Center for Defense Information

 Enclosure
Revolving Door Instances
1. Individual: Steven A. Shaw
Approximate Date Joined Covington & Burling: July 16, 2012
Synopsis: Steven A. Shaw was Deputy General Counsel for Contractor
Responsibility, Office of the Air Force General Counsel and the Air Force debarment
and suspension official. According to his Linkedin profile he stepped down in 2012.
Shortly after he joined Washington lobbying firm Covington and Burling's
government contracts practice group. Law360 described Shaw as "one of the U.S.
government's most aggressive and respected suspension and debarment officials."
According to the Center for Responsive Politics the firm's Pentagon contractor clients
included BAE Systems at the time he joined the firm. As of 2018 additional defense
contractor clients include Elbit Systems, Northrop Grumman, and Bombardier Inc.
Documents to Include:
http://www.af.mil/About-Us/Biographies/Display/Article/105659/steven-a-shaw/
https://www.documentcloud.org/documents/4575895-Steven-Shaw-LinkedIn-6-2618.html
https://webcache.googleusercontent.com/search?q=cache:TN_n1rsKZBkJ:https://ww
w.law360.com/articles/360503/covington-hires-top-air-force-debarmentofficial+&cd=5&hl=en&ct=clnk&gl=us&client=firefox-b-1
https://www.opensecrets.org/lobby/firmsum.php?id=D000021942&year=2012
https://www.opensecrets.org/lobby/firmsum.php?id=D000021942&year=2018

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