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  1. What follows is pure fiction, the fevered imaginings of an AI that was force-fed the Mueller Report:
  2. Twitter: @spdustin
  3. ==============================================
  4.  
  5. The President’s response to Sessions’s recusal was to say, “Don’t recuse would be fair or repeat,” and “I won’t do it again
  6. The President also said, without being asked specific about the recusal itself, “I want to be clear — I don’t recuse.” That statement was demonstrative, direct, and direct; it was in response to Sessions’s recusal and its aftermath; and it was consistent with the general statement that the President was not going to recuse from the Russia investigation
  7. Sessions had previously said that if Rosenstein were no longer in charge, the President would.’ The President returned to the President’s contention that Sessions had violated the Hatch Act because he had intervened in the investigation and thenially assisted it by speaking to investigators in the presence of senior campaign officials
  8. Sessions recalled that the President said to him, “You know, you know, we’re supposed to protect us, you know, by being part of the team.” In response to a question about whether he was considering a recusal based on his role in the Trump Campaign, the President said, “I would say the same thing I say to you: We’re supposed to protect us.” In the presence of relevant individuals and in the presence of the President, the President could potentially be viewed as obstructing the investigation further by being confronted with facts that would otherwise be relevant to an investigation of the President himself
  9. In a the witness’s statement to the Senate Judiciary Committee, the President stated that he had “never been in a position to tell the truth.” In the transcript of that conversation, the President can be heard saying, “I don’t want to be influenced by anybody.” Also in the interview, the President is stated to have raised the issue of Comey with McCabe more than any other witness
  10. The President also stated that he had never asked Comey to stay behind
  11. The President’s contemporaneous statements denying these details reflect his awareness that the story could be very damaging to his presidency if the President were confronted with facts that would otherwise be relevant to an investigation
  12. In addition, the President’s statement that Comey should be removed shows a knowing awareness that the story would be told by individuals with different interests and that the President would have no choice but
  13. ====================
  14. Image via Twitter/@realDonaldTrump 10/24/16 Tweet (“RT @Pamela_Moore13: Detroit residents know that Hillary Clinton is corrupt.”)
  15. Image via Twitter/@realDonaldTrump 10/24/16 Tweet (“RT @Pamela_Moore13: Detroit residents know that Hillary Clinton is corrupt.”)
  16. Pamela Foxx, who had previously served as a reporter for the New York Times, tweeted, “While Donald Trump Jr
  17. reveals he has dirt on Hillary Clinton, she protects him by telling the truth about #dnc & # Uranium deal.” The tweet received over 40,000 responses
  18. Image via Twitter/@guccifer_2 10/24/16 Tweet (“RT @HillaryClinton: Detroit residents know that Donald Trump Jr
  19. reveals he has info on Hillary Clinton, but she protects him by telling the truth about the #dnc & # Uranium deal.”)
  20. Image via Twitter/@guccifer_2 10/24/16 Tweet (“RT @Tomboy: Detroit residents know that Donald Trump Jr
  21. reveals he has information on Hillary Clinton, but she protects him by telling the truth about the Clinton Foundation & the Uranium deal.”)
  22. Image via Twitter/@guccifer_2 10/24/16 Tweet (“RT @Tomboy8: Detroit residents tell me that Donald Trump Jr
  23. tells real story of Seth Rich, leaks information to the media, ends up in a Detroit hospital bedridden ——————‘️” Detroit Free Press, quoted by Fox News Channel (and Detroit Free Press)
  24. The Free Press reporter said that Trump Jr
  25. responded, “then again, about the meeting” and said, “I never said to do these memos." The following day, the Washington Post reported that in asking Trump Jr
  26. to set up the meeting with an individual who had information on Hillary Clinton, Trump Jr
  27. asked the meeting to be “[a]silly” because it was about Hillary Clinton, but Trump Jr
  28. was adamant that he not share it with anyone else and that he not share it with anyone else affiliated with the Trump campaign.” The Post story stated that the meeting “was not a statement on candidate Trump.” It did not disclose that the meeting was about Clinton or any other
  29. ====================
  30. The President’s Testimony Before the Senate Select Intelligence Committee, 115th Cong
  31. (June 8, 2017) (Statement for the Record of James B
  32. Comey, former Director of the FBI, at 6)
  33. Comey 11/15/17 302, at 8; Priebus 10/13/17 302, at 3
  34. Comey 1/28/17 302, at 8; Comey 1/29/17 302, at 9; see Comey 11/15/17 302, at 9 (the President asked Comey what he remembered about the meeting with the Russians, and Comey told the President that the meeting was not a big deal and that it was a surprise to him that the Russians would object to the FBI obtaining information from him); Hunt 2/1/18 302, at 3 ("The President said he had never met [the FBI’s founder, former Director of the FBI] and asked me whether I wanted to continue as FBI Director.")
  35. Hearing on Russian Election Interference Before the Senate Select Intelligence Committee, 115th Cong
  36. (June 8, 2017) (CQ Cong
  37. Transcripts, at 15) (testimony by James B
  38. Comey, former Director of the FBI)
  39. Comey 11/15/17 302, at 8; McCabe 8/17/17, at 15; Rybicki 9/12/17 302, at 6
  40. After leaving the White House, Comey called Deputy Director of the FBI Andrew McCabe, summarized what he and the President had discussed, including the President’s request for loyalty, and expressed shock over the President’s request
  41. McCabe 8/17/17 302, at 15
  42. Comey also convened a meeting with his senior leadership team to discuss what the President had asked of him during the dinner and whether he had handled the request for loyalty properly
  43. McCabe 8/17/17 302, at 15; Rybicki 9/12/17 302, at 6
  44. Comey understood that the President had been angered by that request, and he therefore interpreted the request for loyalty as an attempt to “take control” of a government
  45. McCabe 8/17/17 302, at 15; Rybicki 9/12/17 302, at 6
  46. Comey also told the President’s staff that he had been told that the President had asked him to speak to Comey before the dinner and that he had responded to
  47. ====================
  48. Gauhar-000056 (Gauhar 5/16/17 Notes); Page-000056 (Gauhar 5/16/17 Notes); Page-000057 (Gauhar 5/16/17 Notes); Page-000057 (Gauhar 5/16/17 Notes)
  49. Page-000057 (Gauhar 5/16/17 Notes)
  50. Page-000057 (Gauhar 5/16/17 Notes)
  51. and Page-000058 (Gauhar 5/16/17 Notes); Page-000058 (Gauhar 5/16/17 Notes)
  52. The President’sriad connections to high-ranking members of the Russian government could be viewed as evidence of Russian interference in the 2016 election, as reflected in the comments sections of Steele’s 2016 presidential communications, which the Office found to be full of references to Russia’s interference in the election
  53. For example, in his April 20, 2016 communications with the Campaign, the President referred to U.S
  54. sanctions imposed on Russia for its election interference as “treat[ing] it as a’t GREAT thing that’s happened to Russia that I’d be able to publicly announce it was happening to me” and “[o]fficials said that” after he took office the U.S
  55. toll to Russia shot up again, reaching a new low at the end of May 2016 and prompting the FBI to issue a warning to Mr
  56. Trump Jr
  57. to anyone who might know something about the nature of the Russian offer’s to Mr
  58. Trump (the Russian investment was a campaign issue at the time, and the President had inquired about it when speaking to Mr
  59. Trump on the telephone)
  60. At the time, the FBI’s public disclosure ban on election interference was in place, and a document summarizing the FBI’s investigation showed up in the Dirt Sheet (May 3, 2016)
  61. @realDonald Trump 4/3/16 (7:47 a.m
  62. ET) Tweet
  63. Later that day, the President’s personal counsel told the press that the President had been “phased” by the media following the June 9, 2016 Tower Down Meeting in New York, N.Y., June 13, 2017 (he was at the Time immaterial which way the President was on the witness stand)
  64. Later that day,
  65. ====================
  66. Call Records of Michael Cohen
  67. Cohen Information and his Press Confirmation Question
  68. In approximately September 2015, Cohen began interviewing candidates and individuals he considered to be potential foreign contacts in Russia following the conclusion of polling in November 2015 Presidential Elections
  69. Cohen listed these potential contacts on his company application and in public statements he had received classified information about Russian election interference
  70. Some of the contacts were direct, others was covered by intermediary or channeled contacts
  71. Cohen provided examples of those contacts at his congressional testimony and in public statements, and in interviews with the Office, Cohen recalled none of the above captured his full attention
  72. Cohen recalled onlyffiently that the information about his contacts with Kislyak reached him and that it was difficult to remember what he had discussed with Kislyak
  73. Cohen thought he conveyed that to Kislyak by stating that he had no recollection of learning about the conversation until after the election
  74. In February 2016, Cohen began drafting a written response to the questions he had about Russian election interference
  75. Cohen told the Office that he did not recall talking to the President’s personal counsel about the issue
  76. Cohen thought he had “protected[ed] in public statements by saying that I never discussed sanctions with Kislyak.” In the spring of 2016, Cohen began drafting a statement about Trump Campaign foreign policy and Russia’s election interference that would contain more specific allegations about the Trump Campaign’s interference with the 2016 presidential election
  77. Cohen described these specific allegations in greater detail in his September 14, 2017Public Statement, Cohen to Special Counsel’s Office; Cohen 9/18/18 302, at 3
  78. Cohen also told the Office that he did not recall talking to the President’s personal counsel about the specific allegations in the Times article
  79. Cohen 9/18/18 302, at 3
  80. Cohen 9/12/18 302, at 4
  81. Cohen 9/12/18 302, at 4
  82. Cohen 9/12/18 302, at 4
  83. Cohen 11/20/18 302, at 1; Cohen 11/19/18 302, at 3
  84. Cohen 11/20/18 302, at 1-2; Cohen 11/19/18 302, at 3
  85. Cohen 11/20/18 302, at 2
  86. Cohen 11/20/18 302, at 2-3
  87. Cohen 11/20/18 302, at 3; see also Rtskhiladze 4
  88. ====================
  89. Gee, I wonder if the Crooked Media will let me in on a secret I never asked for!" Trump Jr
  90. 2/16/19 Email, Kushner to Vargas
  91. Gates 1/30/18 302, at 7; Gates 3/1/18 302, at 3
  92. Gates 3/1/18 302, at 3; Gates 4/3/18 302, at 2; see Doug G
  93. Ware, Trump, Russia’s Putin Son: Ushakov, “Gen
  94. et,” NBC News (June 8, 2017); Gates 5/10/18 302, at 3
  95. See, e.g., Sean Hannity, “Comey Needed Immunity,” Fox News (June 10, 2017) (quoting the President’s personal attorney as saying, “[The president] would never ask for my counsel”)
  96. Gates 1/30/18 302, at 3; Gates 4/3/18 302, at 2
  97. Gates 1/30/18 302, at 3; Gates 5/10/18 302, at 3
  98. In January 2018, Gates pleaded guilty to superseding criminal information charges in the Southern District of New York on behalf of the President of the United States
  99. During the time he was in that position, Gates had direct and close access to the President and the White House communications team, including the ability to communicate with the President’s personal counsel and senior officials
  100. According to Gates, the President’s personal counsel viewed the Group as an “alternative news site” that was “effectively a middleman” and that could raise with its coverage any coverage the President’s campaign-period financial support for the Trump Organization.” NOSC00004356 (1/11/16 Email, Gates to Kushner)
  101. NOSC00004356 (1/11/16 Email, Gates to Kushner)
  102. NOSC00004356-357 (1/11/16 Email, Gates to Kushner)
  103. NOSC00004357 (1/11/16 Email, Gates to Kushner)
  104. Gates 1/30/18 302, at 5; Gates 4/10/18 302, at 2; Gates 95/93/17 302, at 6; Gates 20161-2016
  105. Gates 1/30/18 302, at 5; Gates 20171
  106. Gates
  107. ====================
  108. Nov
  109. 23, 2016 Letter, President’s Personal Counsel to Special Counsel’s Office, at 1-2 ("We concluded that your Office’s conclusion that WikiLeaks was lying about the Trump WikiLeaks site visit was wrong and that your Office’s report on the Trump WikiLeaks site visit is consistent with that conclusion
  110. ")
  111. 7/23/16 Letter, President’s Personal Counsel to Special Counsel’s Office, at 1-2
  112. At that time, the Trump Campaign was planning a press strategy, a communications campaign, and messaging based on that strategy and messaging
  113. During that planning and messaging, the Trump Campaign had received no response from the Russian government to our letters
  114. During the rollout of those messages, campaign officials at multiple levels tried to make contact with our letters
  115. We received no response
  116. At the highest levels, we communicated through candidate Trump, who informed our other employees that it was not a good idea for the United States to engage in any sort of escalatory [reactionary] behavior” because “Russia is a friend of the United States, and Russia is trying to influence our elections a lot
  117. ..
  118. We told you, we are the most important people in the world, and if you give us a new contract, we will do everything in our power to make sure that you don’t give in to pressure, to bombastical allegations, to that." When we received similar denials from Campaign officials, we took additional steps to ensure that we provided the Trump Campaign the highest level of assurance that the agreements were not a cover for any future espionage
  119. In particular, our team sought assurance that the Trump Campaign had not been involved in any communications prior to the New York Times Company’s New York Times Company and its Insider Contact Program, in light of the Times’s repeated efforts to contact the Russian government through a number of channels
  120. We also sought assurance from the Trump Campaign that it would not contradict or contradict our reporting
  121. Specifically, we called the Trump Campaign’s senior policy team to seek assurances that the Campaign would not contradict or contradict our reporting and would not make any statements that the Access Hollywood tape was a result of any agreement between Trump and Russia
  122. We also sought assurances from the Campaign that no action would be taken against the media organizations because of our reporting
  123. Finally, we interviewed several witnesses who had relevant information and subsequently provided it to our reporting, and we concluded that we had obtained the evidence
  124. ====================
  125. Those same individuals also sent WikiLeaks the email with which Manafort had alluded to Deripaska’s conversations with Kislyak
  126. The email stated that Manafort told Assange that if Deripaska stayed on message, the two men would have some form of diplomatic relationship
  127. On July 12, 2016, WikiLeaks released the first emails stolen from Clinton Campaign chairman John Podesta
  128. The release coincided immediately after a two-day DCCC hack-and-release conference in San Francisco that had been billed as the "must-visit" hack and release conference of 2016
  129. Some emails released by WikiLeaks appeared to have originated from DCCC releases
  130. One WikiLeaks email, for example, bears a date (July 12, 2016) and a source (Dmitri Klimentov, Миневодря, “Wikileaks”)
  131. that appears to be fabrication
  132. Assange also hacked into DNC servers in July 2016, shortly after the organization had publicly disclosed the source of the Russian hack
  133. Sanders and others believed the release was part of a “campaign” operation to release “leaked emails” that purported to show that the Trump Campaign had been infiltrated by Russians
  134. In August 2016, Assange wrote to KLS Research Associate Daniel Ustinov about a “campaign leak” (л) — sometimes referred to as a “leak of information” — that he had seen “mildly graphic images of [Trump’s] genitals and that he [Trump Jr.] would be very grateful to [the] [Russian government] if he was captured or captured again.” Sanders thought the email release was part of a “campaign to delegitimize” candidate Clinton
  135. In response, to a September confirmation email that would have been included in the release, Lewandowski sent a second confirmation email to Žiński and brought him to the 2 p.m
  136. time period to speak with the President-Elect
  137. The President-Elect and Lewandowski spoke again in the afternoon and evening hours, followed by the morning and afternoon hours, respectively
  138. The President-Elect spoke at length and clearly in both instances said that he wanted the “interventionist” foreign policy advisor, J.D
  139. Gordon, who would be assisting him in any way he could, to see if the “approach” from Putin was feasible
  140. Both Gordon and the President-Elect wanted the approach to Russia
  141. ====================
  142. Notes
  143. --GJ-- -PP- --GJ-- -PP- --GJ-- -PP- -PP- -PP- -PP- -PP- -PP- -PP- -PP- -PP- Special Counsel Robert S
  144. Mueller, III Submitted Pursuant to 28 C.F.R
  145. § 600.8(c) Washington, D.C
  146. March 2019 INTRODUCTION TO VOLUME II EXECUTIVE SUMMARY TO VOLUME II I
  147. BACKGROUND LEGAL AND EVIDENTIARY PRINCIPLES A
  148. Legal Framework of Obstruction of Justice B
  149. Investigative and Evidentiary Considerations II
  150. FACTUAL RESULTS OF THE OBSTRUCTION INVESTIGATION A
  151. The Campaign’s Response to Reports About Russian Support for Trump 1
  152. Press Reports Allege Links Between the Trump Campaign and Russia 2
  153. The Trump Campaign Reacts to WikiLeaks’s Release of Hacked Emails 3
  154. The Trump Campaign Reacts to Allegations That Russia was Seeking to Aid Candidate Trump 4
  155. After the Election, Trump Continues to Deny Any Contacts or Connections with Russia or That Russia Aided his Election B
  156. The President’s Conduct Concerning the Investigation of Michael Flynn 1
  157. Incoming National Security Advisor Michael Flynn Discusses Sanctions on Russia with Russian Ambassador Sergey Kislyak 2
  158. President-Elect Trump is Briefed on the Intelligence Community’s Assessment of Russian Interference in the Election and Congress Opens Election-Interference Investigations 3
  159. Flynn Makes False Statements About his Communications with Kislyak to Incoming Administration Officials, the Media, and the FBI 4
  160. DOJ Officials Notify the White House of Their Concerns About Flynn 5
  161. McGahn has a Follow-Up Meeting About Flynn with Yates; President Trump has Dinner with FBI Director Comey 6
  162. Flynn’s Resignation 7
  163. The President Discusses Flynn with FBI Director Comey 8
  164. The Media Raises Questions About the President’s Delay in Terminating Flynn 9
  165. The President Attempts to Have K.T
  166. McFarland Create a Witness Statement Denying that he Directed Flynn to Message that the President Tried to Have Flynn Terminated 9
  167. The President Discusses Flynn with FBI Director Comey 10
  168. The Media Raises Questions About the President’s Delay in Terminating Flynn 11
  169. The President Attempts to Have K.T
  170. McFarland Create a Witness
  171. ====================
  172. A second attempt to destroy the narrative about the June 9, 2016 meeting was made on June 8, 2016
  173. Ken Bensinger & Robert Costa, The Search for the Source of the “Gateway Gambit", Washington Post (Aug
  174. 5, 2016)
  175. See, e.g., Ken Dilanian, Paul Manafort’s complicated ties to Ukraine, CNN (July 11, 2016)
  176. See, e.g., Mark Berman, Trump: Never Trumped, New York Times (Apr
  177. 27, 2016)
  178. New York Times (Apr
  179. 27, 2016)
  180. Cohen 9/12/18 302, at 8
  181. Cohen 9/12/18 302, at 8
  182. Cohen 9/12/18 302, at 8
  183. Cohen 9/12/18 302, at 9
  184. Cohen 9/18/18 302, at 2; Cohen 9/12/18 302, at 2
  185. Cohen 9/18/18 302, at 8; see also, e.g., Mark Berman, Trump: Never Trumped, New York Times (Apr
  186. 27, 2016); Mark Corallo, Fact or Fiction: Michael Cohen Mysteries the Trump Organization and the Trump Organization, Washington Post (Aug
  187. 1, 2016)
  188. Cohen 9/12/18 302, at 8; Berman 7/8/18 302, at 9
  189. Corallo 7/8/18 302, at 2-3
  190. Corallo 7/8/18 302, at 3
  191. Cohen 9/19/18 302, at 2
  192. Cohen 9/18/18 302, at 8
  193. also attended the meeting and stated that he was not involved in it
  194. Cohen recalled that Cohen called him at night to ask for help with the request and that Cohen texted them both Dawson’s Room 302 and asked if he could’t re-record the conversation
  195. Cohen understood that the conversation was not intended to ransom Cohen, but rather was meant to minimize the connections between the President and Russia
  196. Cohen told Cohen the conversation was about Trump Tower Moscow and a potential McGahn meeting with Putin because Cohen wanted to stay on as Trump’s DJT for life
  197. Cohen said he wanted to stay on the project and not suggest that the President otherwise be terminated
  198. Cohen also recalled telling the President’s personal counsel that Cohen’s previous deal with Cohen Bearden was not sustainable given the President’s
  199. ====================
  200. Re: Comey, Comey 11/15/17 302, at 11; McCabe 8/17/17, at 15-16
  201. Comey said the President was “upset” about the investigation and wanted to know what he would do
  202. McCabe said the President had asked him to “do crazy shit,” and the President wanted Comey to stay on message
  203. When McCabe reviewed the notes from the Oval Office meeting, he recalled hearing the words “release Comey” repeatedly, and he was concerned that the notes might be interpreted as support for terminating Comey
  204. On May 3, 2017, Comey wrote to Coats that “this Office is issuing a result order with immediate effect to limit the Special Counsel’s investigation to the presidential election and to limit the President’s access to any emails related to the September 11, 2016 campaign
  205. This is a direction based decision and does not affords immunity to the President to certain witnesses who cooperate with the administration’s investigation, such as James B
  206. Comey
  207. Comey’s May 17, 2017 Finesse, in violation of 18 U.S.C
  208. § 1001, 200001 (incl. “hundreds of thousands of dollars”), is set forth in Volume I, Section IV.A.6, infra
  209. The valuation in this section is not an exhaustive statement of the money owed to Cohen
  210. See 18 U.S
  211. Const., Art
  212. I, § 9
  213. The term “fix” is defined in the statute as a payment obligation that accrues as a penalty for “loan fraud, or similar conduct,” 18 U.S.C
  214. § 9-27(a)(1)(A)(i); see Cohen 3/13/19 302, at 4-5; Cohen 9/12/18 302, at 9
  215. Cohen 3/13/19 302, at 4-5
  216. Cohen 3/13/19 302, at 5
  217. Cohen 3/13/19 302, at 5
  218. Cohen 9/12/18 302, at 9
  219. Cohen 3/13/19 302, at 5
  220. Cohen 9/12/18 302, at 9
  221. Cohen 3/13/19 302, at 5
  222. Cohen 11/20/18 302, at 1; Cohen 11/21/18 302, at 2
  223. Because of concerns about the
  224. ====================
  225. The Russian government has publicly identified two Russian entities as the primary backers of the Trump Campaign and a related Russian government official network
  226. --HOM-- — as “affiliated” with the Russian government
  227. The indictment alleges that the Campaign and Trump Campaign officials worked alongside the London-based “Don’t Star Realms” organization and supported its creation
  228. Don’t Star Realms is a Russian organization funded by Prigozhin and companies funded by Russian real estate developers
  229. Don’t Star Realms provided employees of the Trump Campaign access to or received donations from Russian companies or individuals, and Don’t pay for political or military advisors, and Don’t engage in money laundering or money laundering operations
  230. --HOM-- — while other U.S
  231. persons were being prosecuted for that conduct
  232. In addition, the government charged two Russian nationals with conspiracy to defraud the United States and one with making false statements to Congress
  233. --HOM-- The government charge letter charged falsely with a third person, under the aliases “Andrej Krickovic and “Miguel Krickovic.” The charge letter stated in relevant part: Despite the FBI’s finding that the men had engaged in widespread computer and internet surveillance of the Trump Campaign and its officials, the government argued that the efforts were not campaign-related and that the claims of these men were “mere metadata” pertaining to an ongoing investigation
  234. The government briefingly charged that the three men had hacked into the DNC e-mail account and stole documents, documents, and other documents, among other things, identifying the Campaign’s involvement in the presidential election
  235. After --HOM-- the government briefly charged that the four men stole documents and documents from the DNC e-mail account, --IT-- the government argued that the government’s case against Manafort was not meritless
  236. Given the government’s capacity to travel at will, the fact that the government charged both men in the United States with conspiracy to defraud the United States, and one of them faced criminal charges in the United States, that presumption would support the burden that the government prove multiple individuals have conspired to commit multiple acts of obstructive actions
  237. Given the breadth of the conspiracy statutes described above, the government would likely challenge the validity of those statutes in the presence of sufficient evidence to obtain a conviction
  238. The government also would present compelling evidence to support a conviction for obstructing justice
  239. ====================
  240. Gates 2/2/18 302, at 5; Gates 9/27/18 302, at 6
  241. Gates 3/13/18 302, at 2
  242. Gates 2/2/18 302, at 5-6
  243. --GJ-- Third, in the weeks after the June 9 meeting, the President’s personal counsel repeatedly contacted the Transition Team to try to make it appear as if the meeting had occurred without the President’s involvement
  244. In addition, some of the President’s personal counsel contacted the press to try to make it look as if the meeting had occurred without the President’s involvement
  245. When the President’s personal counsel told the press the press had not independently confirmed with his lawyers that the President had not met with Kislyak, the press asked questions about the nature of the meeting and whether the President had not intervened to limit the media coverage
  246. Finally, in the days after the June 9 meeting, the President’s personal counsel made it clear to the President he did not have assurance that the meeting would not happen again, stating, “Even if [the President] sincerely hoped it would,” suggesting the President may not have been sure he had protected the meeting because the President was not personally under investigation,” 18 U.S.C
  247. § 951(d)
  248. The President’s counsel argued that the meeting should not be read as showing that the President had been ordered to have the Special Counsel removed because the President had personal knowledge of the Special Counsel’s investigation, and that the President should have known that his counsel was likely to present such an indictment in Congress
  249. But the President’s counsel argued that the proper channel by which the President could act to have the Special Counsel removed was when the President was demonstrating his constitutional authority to remove an official for obstruction of justice
  250. The President’s counsel argued that the proper channel was through the President to have the Special Counsel removed so that the President could be assessed the appropriate punishment for a crime that the President had not committed
  251. Under the President’s interpretation of the term “corruptly,” which refers to anyone who “acts with an improper purpose,” Mueller v
  252. United States, 573 U.S
  253. 351, 358, the President’s personal counsel had directed the Special Counsel to remove “the general [as defined in the Constitution]” so that it
  254. ====================
  255. Troy A
  256. Nobleso, a member of the board of directors for CNI, recalled meeting with Trump in January 2017 and expressing concern about what Cohen would do if the President were convicted for obstruction of justice
  257. Nobleso said that he spoke with the President twice and ultimately decided to not follow through with terminating the Special Counsel
  258. On January 21, 2017, the President’s personal counsel told the press that Cohen would not be testifying before Congress “in the near future." The President told the press that he had not personally heard from Cohen at this time
  259. The President also told Coats that he would not be testifying before Congress in the future
  260. Coats said he was concerned that the information he had obtained in the Steele reporting might be used against him in the future
  261. The President also told the press after the January 2017 press conference that “he would never do anything to give the impression that the [Cohen] lawsuit was over." The President said he had heard from his personal counsel that Cohen’s freedom of information request would be published “this week,” and that he hoped the public would not doubt his ability to doze off after he left Camp David
  262. Cohen’s attorneys have disputed that story
  263. Michael Cohen said that when he met with investigators from this office he did not ask for the Steele reporting on Trump being pressured to make a public statement about sexual assault
  264. Cohen said that he never asked for the story because he did not think it was valuable
  265. Cohen recalled that, after leaving Camp David, he wrote down money he had come to earn at the London Academy of Diplomacy and Learned Arts in Camp David, Pennsylvania
  266. Cohen said that he got there $400 or $500 a month, depending on the position
  267. Cohen was concerned that his knowledge of the Trump Organization and the foreign- investment industry would be lost if he did not share it, and that if he did not keep his job, he would be fired
  268. Cohen told investigators that he had a hard time getting in touch with the Trump Organization about the amount of money he was making
  269. Samochornov, a letter Cohen had written to candidate Trump shortly after his trip to Moscow, recalled that Cohen wrote about Trump asking him to set up a meeting with a Russian attorney
  270. Cohen said that this was not true and said that Trump Jr
  271. was surprised by this letter because he had not heard from Trump Jr
  272. toward the end of
  273. ====================
  274. Gates 1/30/18 302, at 3
  275. Gates 1/30/18 302, at 3; Gates 9/27/18 302, at 5; Gates 1/30/18 302, at 3
  276. Gates 1/30/18 302, at 3-4
  277. The Office did not identify evidence in the case, however, that anyone took a meeting at all within days of the President’s initial tweets about the meeting
  278. Gates did, however, recall that, if something was amiss during the meeting, he might want to draw the meeting to a close in order to speak to McGahn and Co
  279. In analyzing the President’s efforts to have Sessions unrecuse himself, the following evidence is relevant to the elements of obstruction of justice: a
  280. Obstructive act
  281. As with the President’s actions during the campaign and for that matter before, during, and after the Presidential Inauguration, Sessions had multiple conversations with the President to give him control over the Russia investigation, including through “the power of the attorney” and an environment in which the President could “decide what” to investigate or not investigate
  282. Conduct towards a subordinate
  283. As with any obstructive conduct, the evidence we obtained was consistent with at least some of the other evidence we obtained
  284. Accordingly, the evidence we obtained is consistent with at least some of the evidence we obtained
  285. Sessions had numerous contacts with the President’s personal counsel in trying to clear his name, including through Cohn
  286. Cohn had been the White House counsel since the President took the job and supervised all presidential communications except for presidential letters and press conferences
  287. Cohn had previously advised the President on domestic and foreign policy matters and had tried to prevent the President’s personal counsel from speaking to the Russian investigation
  288. In addition, at some point after the election candidates Trump, Clinton, Sanders, and Obama aped the President’s order to fire the Special Counsel, which Cohn later confirmed was the President’s
  289. In summary, the evidence we obtained contradicted the President’s account that he had first instructed Cohn to have the Special Counsel removed, gave him a letter of intent that was not followed’s first, and that he never told Cohn to meet McGahn or other DOJ officials to discuss the Special Counsel’s removal
  290. The evidence we obtained also contradicted the second commandment, which stated that no one shall
  291. ====================
  292. After a month of deliberations, the Supreme Court on Monday declined to hear arguments in the President’s personal counsel’s brief in support of his contention that the government has an burden to establish that the President acted “knowingly and willfully” in order to close the FBI’s investigation into Flynn
  293. The week before the 2016 presidential election, the President told the Russian Foreign Minister that if “some satellite” Russia helped elect him, he would get along well with Obama
  294. And after returning from a two-day trip to Moscow, the President told a local press outlet that if “some satellite” Russia helped him make the choice, “maybe we can get along great, we know each other a little bit a little well.” The President’s comments, however, follow a different set of events in which the President sought to assure Russian officials that he could “Get along with Barack Obama very easily.” The evidence would tend to support a different inference: that the President considered seeking such a relationship to be a major reason for his decision to seek the transition to Russia — a decision that could amount to blackmail if performed in that manner
  295. It is not clear, however, whether the President knew at that time that acting as a private citizen would be a crime in Russia, where acting as a citizen is a much more serious offense than acting in a public position
  296. The President’s reaction to the evidence likely reflected his awareness that cooperating with the government of Russia in any way implicates his official duty and coulders dole out punishment for those who did what the President did
  297. His actions would then turn to protecting the President’s personal counsel and whether that counsel would testify truthfully or provide false testimony in a criminal trial
  298. The President’s reaction is not the result of a consequence of corrupt action but rather the result of a state of affairs that would materially affect the President’s ability to govern
  299. If the President were faced with an untruthful statement in his testimony that would compromise his ability to perform his constitutional duty, see Volume II, Section II.G, supra, and the President would be unable to get on with his life of the United States, he could make the statement because the statute of limitations had expired and a false statement had occurred
  300. If the President were unable to obtain that information from a witness, he could make the false statement to protect himself from a future criminal prosecution
  301. ====================
  302. McFarland 12/22/17 302, at 7; Hunt 2/1/18 302, at 11; McGahn 12/14/17 302, at 1
  303. Hunt-000031 (Hunt 5/17/17 Notes); see Hunt 2/1/18 302, at 11
  304. Hunt-000031-32 (Hunt 5/17/17 Notes); see Comey 11/15/17 302, at 6-7; see Comey 11/15/17 302, at 7-8; Hearing on Russian Election Interference Before the Senate Select Intelligence Committee, 115th Cong
  305. (June 8, 2017) (Statement for the Record of James B
  306. Comey, former Director of the FBI, at 6)
  307. that difficult." The President asked Comey what could be done to assist the Department of Justice with the Russia investigation
  308. Comey told the President that Congress had passed bipartisan legislation in December 2016 that “authorized” the FBI to investigate Russia’s interference in the 2016 presidential election and related matters through counterintelligence and law enforcement authorities,” and that Congress had also asked the FBI to investigate possible links between the Russian government and the Trump Campaign
  309. In his opening remarks at the hearing, Comey did not disclose that he had been authorized by the President to hear from the Special Counsel investigation but did authorize Comey to publicly announce the Special Counsel’s investigation “would conclude on a full and complete conclusion with the Special Counsel’s appointment to the Central Intelligence Agency.” Comey 11/15/17 302, at 6-7
  310. Comey 11/15/17 302, at 7; Hearing on Russian Election Interference Before the Senate Select Intelligence Committee, 115th Cong
  311. (June 8, 2017) (Statement for the Record of James B
  312. Comey, former Director of the FBI, at 6)
  313. Comey 11/15/17 302, at 7; Hearing on Russian Election Interference Before the Senate Select Intelligence Committee, 115th Cong
  314. (June 8, 2017) (Statement for the Record of James B
  315. Comey, former Director of the FBI, at 6)
  316. Comey 11/15/17 302, at 7; Hearing on Russian Election Interference Before the Senate Select Intelligence Committee, 115th Cong
  317. (June 8, 2017) (Statement for the Record of James B
  318. Comey, former Director of the FBI, at 6-7)
  319. Comey 11/15/17 302
  320. ====================
  321. Wealthy Indictment Preachers Target Senators, Supporters, and Supporters of the Trump Campaign, NBC News (July 31, 2016); See, e.g., Steven Mufson, Paul Manafort’s business pursued pro-Russian political operation that exposed internal discord in Trump team, Politico (July 31, 2016)
  322. Chris Wallace Hosts “Fox News Sunday,” Interview with President-Elect Donald Trump, CQ Newsmaker Transcripts (Dec
  323. 11, 2016)
  324. David Morgan, Clinton campaign: Manafort worked on anti-immigration message, CNN (July 31, 2016)
  325. Chris Wallace Hosts “Fox News Sunday,” Interview with President-Elect Donald Trump, CQ Newsmaker Transcripts (Dec
  326. 11, 2016)
  327. also recalled that the campaign manager worked for the pro-Russian political party the People’s Republic of China of foreign policy advisor Prince am
  328. Prince was born in Russia and immigrated to the United States in the 1970s
  329. The business card from his U.S
  330. advisory records indicates that he worked for companies including CNI (which today, through its board of directors, is the country’s largest bank) and Smithfield-Howard.462 The business card also shows that Prince was introduced to the Trump Campaign in March 2016 by campaign manager Corey Lewandowski
  331. In a March 21, 2016 email with Prince stating “[i]s what he is, I will do anything to win the election." Questioned about the “small fees [the Campaign] would charge for access to the “final version of the plan,” Prince told Lewandowski that “the World Economic Forum (WILD) in Davos, Switzerland in September 2016 is approaching and is expected to generate substantial traffic." Prince wrote that WILD “is looking forward to it!" Prince told Lewandowski that he had “asked [himself] to undertake this research because I am the most important politician in the land and the best person to build a wall along the U.S
  332. border." He also told Lewandowski that he intended to write a letter to the incoming Administration explaining why Russia should· “provide assistance to the campaign,” and that the Campaign would contact him if it’s possible to obtain the “final version of the plan." Prince told Lewandowski that he was “really looking forward to it." After the March 20 meeting concluded, Prince
  333. ====================
  334. Personal Background
  335. I am a single mother of two young children, and have two full-time full-time jobs
  336. I have two wonderful and successful jobs
  337. I have two wonderful and successful and successful lives
  338. I have two wonderful and successful and successful and successful lives
  339. I have two wonderful and successful and successful and successful lives
  340. Additional Information
  341. See, e.g., U.S
  342. Department of State, Consensus Statements and the U.S
  343. Values of 2016, Center for the New Nationalism, (Christie2016: Speech at National Defense Forum, Washington, DC, U.C
  344. (June 16, 2016))
  345. Participation in the planning and execution of the proposed resolution was voluntary, but the individual who initiated the avenue of engagement testified that he was asked by the President to weigh in and offer his thoughts on the resolution
  346. Kaiser also recalled that the President’s personal counsel referred to Simes as a “belligerent person,” which was accurate in describing the President as having no direct say in the resolution
  347. Theosal, however, asserted his knowledge and experience in the Department of State’s foreign-policy advisory and management functions, that of experienced foreign-affairs professional, and that the two earned a reputation for being able to work with Russian government officials
  348. Kushner led the effort for the Department of State, acting as policy advisor to the State Department from August 2015 to April 2016
  349. Kushner is a specialist on Russian politics and government affairs and is familiar with the steps required to execute the required signatureatures, including the use of a legal team and structured communications
  350. Simes was on the department’s legal team, assisting senior officials on foreign-affairs issues and assisting foreign legislators to obtain signatures from foreign legislators
  351. As noted above, none of the State Department’s legal experts had any role or official role in or relationship to the Trump Campaign or the Russian government
  352. In the months leading up to its initial public announcement of the Russia sanctions, the Trump Organization pursued the proposal through multiple human resources departments, as well as through the “Transition Team” Facebook group and Twitter account
  353. Approximately six weeks after the original announcement of the sanctions, HPSCI sent Kushner a proposal for improved U.S.-Russia relations
  354. The original proposal called for improved U.S.-Russia relations based on the Trump Campaign’s support for candidate Clinton
  355. The proposal outlined a “backdoor
  356. ====================
  357. Rosenstein, J., dissenting
  358. Justice Scalia, S
  359. Scalia, and Kennedy joined Scalia and Scalia.H
  360. Roe, 52-27, set aside the separate opinion of the lone justice who had authored the opinion and stated that the President’s explanation of Yates’s detention of Flynn for three days was “mere abstract talk” and did not reflect the Court’s prior understanding of presidential conduct
  361. Hicks, 487 U.S
  362. at 691-693, 695-696
  363. Sessions, 52, 106 F.3d 1267, 1275 (“In my prior work[s] “there was some evidence that the President is a rational person, but not a ‘crazy one.’ That argument loses its force when you consider that the President is not only subject to criminal prosecution for exercising discretion, but also subject to a fine and Congressional punishment for disobedience — both here and in the future.”)
  364. Kennedy, J., concurring in the judgment
  365. Brenson, J., dissenting
  366. Mashburn, Stephen, and Samuel Alito, JJ., joined the Opinion, 19-21 (D.C
  367. Cir
  368. 2015)
  369. The term “presidential actionable” is defined in the statute to mean action that “prohibits or impedes the President or any person otherwise performing his official duties,” such as serving as the Special Counsel to investigate an ongoing investigation, a grand jury, or a federal agency investigation
  370. United States v
  371. McGahn, 4 a
  372. a, 2, 2019 (S.D.N.Y
  373. Dec
  374. 31, 2019)
  375. The term “presidential actionable” does not have connotation in limited to cases such as Comey’s and Flynn’s conduct of a conversation he had with Kislyak
  376. When the White House Counsel’s Office referred to the possible use of a pardon for Flynn, the word “presidential actionable” was used in the statement to Congress indicating that a pardon was in the offing for Flynn
  377. In an obstruction-of-justice context, a pardon could imply an intent to obstruct justice and could be taken towards a proceeding, as opposed to a potential pardon under ordinary circumstances
  378. See U.S
  379. CONST
  380. ART
  381. I, § 3, cl
  382. 7
  383. See United States v
  384. Roe, 529
  385. ====================
  386. You See, I Don’t Think I’m the Most Loyal Spy, Anyway." On June 2, 2017, Cohen tweeted, “Imaҙm a walk-on for the job
  387. When does the American people realize Matt Rhule is a hack who should resign?” Cohen relayed this tweet to journalists
  388. The next day, Cohen recalled that The Washington Post reported that Cohen had discussed the sexual assault of women in the workplace with candidate Trump
  389. After Cohen resigned from the Trump Organization in a press interview on July 27, 2017, the President tweeted, “This is the worst possible way to respond to report on Cohen working for the Trump Organization
  390. ..
  391. I mean, this guy, he was a showboater
  392. Imaҙm a hack.” The President tweeted, “This is the worst possible way to respond to report on Cohen working for the Trump Organization
  393. ..I mean, this guy, he was a showboater
  394. Imaҙm a hack.” In analyzing the President’s actions towards Cohen, Cohen 2/12/19 302, at 3
  395. Cohen 3/12/18 302, at 4
  396. Cohen 3/12/18 302, at 4
  397. Cohen 3/12/18 302, at 4
  398. Cohen 3/12/18 302, at 4
  399. Cohen 3/12/18 302, at 4
  400. Cohen 3/12/18 302, at 4
  401. Cohen 3/12/18 302, at 4
  402. Cohen 3/12/18 302, at 4
  403. Cohen 3/12/18 302, at 4
  404. Cohen 3/12/18 302, at 4
  405. Cohen 3/12/18 302, at 4
  406. Cohen 3/12/18 302, at 4
  407. Cohen 3/12/18 302, at 4
  408. Cohen 3/12/18 302, at 4
  409. Cohen 3/12/18 302, at 4
  410. Cohen 3/12/18 302, at 4
  411. Cohen 3/12/18 302, at 4
  412. The President’s personal counsel told the press the next day that Cohen was “doing fine” and provided additional information to the President, who tweeted, “Mr
  413. Cohen, this is Matt Skiber, the President of the Trump Organization, laying the groundwork for future Trump Tower Moscow press interviews."
  414. ====================
  415. The President also repeated his pledge to “Keep our country strong.” The media initially reported that Kushner and Kislyak discussed a potential trip to meet with the President in January 2019
  416. That information was incorrect
  417. The two discussed no imminent political discussion or alliance between the Trump Campaign and Russia, and the conversation never took place
  418. Kushner and Kislyak regularly discussed U.S
  419. policy toward Iraq and Syria, and Kislyak particularly had received threats after the election about traveling there to discuss that topic
  420. Kushner said that the press had treated his travel to Russia — which he and Kislyak had arranged together with experienced foreign policy professionals — as if it was nothing
  421. Kushner also told the President that foreign leaders were not helpful to the Campaign and that he did not want to know anything from Trump or Bannon about Russia, let alone hearing from candidate Trump, when it came to Russia
  422. The two remained in contact through at least June 2016, when Kushner reported directly to Kushner (through Klokov) and continued through to Kushner when he met with the President
  423. Kushner 4/11/18 302, at 4
  424. Kushner 4/11/18 302, at 4
  425. Kushner 4/11/18 302, at 4; SCR015_000198 — p
  426. Kushner 4/11/18 302, at 4
  427. Kushner 4/11/18 302, at 4; SCR015 000099 (President Under Fire Call, New York Times (New York: Marcel Dekker & Kwame), Nov
  428. 20, 2017)
  429. Kushner 4/11/18 302, at 5; Kushner 4/11/18 302, at 5
  430. Kushner 4/11/18 302, at 4; SCR015 000099 (President Under Fire Call, New York Times (New York: Marcel Dekker & Kwame), Nov
  431. 20, 2017)
  432. Somini Sengupta & Rick Gladstone, Russian Officials Were in Contact With Trump Allies, Diplomat Says, New York Times (Nov
  433. 11, 2017)
  434. Kushner 4/11/18 302, at 4
  435. SCR015 000099 (President Under Fire Call, New York Times (New York: Marcel Dekker & Kwame), Nov
  436. 20, 2017)
  437. Somini Sengupta & Rick Gladstone, Russian Officials were in Contact With Trump Allies, Diplomat Says, New York Times (Nov
  438. 11, 2017
  439. ====================
  440. But the evidence indicates that the President did not perceive the letter to be a bad idea to the point where he decided to issue a clarifying statement — rather than acknowledge it as such and moving to limit the sentence to a term of imprisonment but to exclude the other provisions of the Espionage Act
  441. The President’s intent in setting the sentence was both pragmatic and calculated in light of the President’s response to the letter, which is generally known as a press statement
  442. Cohen was a typical provision — it predated the Wire Act and is largely unknown to the public
  443. But the President’s intent in drafting the provision is both pragmatic and deliberate
  444. The main evidence we have is a series of tweets, which are set forth in chronological order in the chronological order in which they are quoted
  445. @realDonaldTrump 4/28/18 (8:49 a.m.) Tweet
  446. Meet the Press Interview with Rudy Giuliani, NBC (Feb
  447. 4, 2018)
  448. Mark Mazzetti, who was the White House Press Secretary at the time, said that the President’s decision to use the term “dark” in his initial response to the letter was “obvious” because “there was no darkness in there.” @realDonaldTrump 4/29/18 (9:03 a.m.) Tweet
  449. Meet the Press Interview with Rudy Giuliani, NBC (Feb
  450. 11, 2018)
  451. Mark Mazzetti, who was the White House Press Secretary at the time, said that the President’s decision to use the term “dark” in his initial response to the letter was “obvious” because “there was no darkness in there.” In analyzing the President’s response, we are guided by the evidence we obtain of when the initial tweet at Kilimnik occurred
  452. According to Mazzetti, the President’s “feedback” was that he did not like Manafort, that Manafort was not loyal to him, and that Manafort never breached any laws.” But the evidence does not establish that the President responded when he tweeted about Manafort
  453. According to Mazzetti, the President responded, “Don’t forget, this is a reporter’s job.” The President’s comment, however, could be seen as reflecting the trust that had been established by the evidence we receive of the President’s reaction to Manafort
  454. According
  455. ====================
  456. The Office has reviewed evidence and circumstantial evidence in this investigation to determine whether any of the following elements is relevant to the Office’s judgment: Whether the President acted with a view to McGahn’s prosecution being compromised
  457. Based on evidence and circumstantial evidence, the Office has concluded that the President did not commit a crime by meeting with McGahn at the White House
  458. There was no evidence immediately available to the President at the time of the meeting that would suggest that the President was concerned about the integrity or availability of the FBI’s evidence-detection system
  459. There also is no evidence immediately available to the President after the fact that would suggest that the President was considering whether to provide information to investigators in order to obtain an investigation-wide ban on campaign-finance violations
  460. The President did not seek to terminate the Special Counsel
  461. Because of the President’s personal position, the President could not directly terminate the Special Counsel
  462. But the President felt that an express letter from the President authorizing Comey to remove Comey “wouldn’t be harmful to the President,” and the President acknowledged that “the President had already told Comey that if the FBI didn’t find evidence against him, the President would fire Comey
  463. So the President’s request for loyalty was not motivated by any desire to hinder the FBI’s investigation of Comey or any other FBI official
  464. b
  465. Nexus to an official proceeding
  466. As set forth in the next section, the Office has examined evidence of the President’s intent to commit a grand jury investigation of Michael Flynn, the former National Security Advisor to President Trump, and Intel Director Michael Flynn
  467. The evidence sets forth those facts and the evidence is sufficiently relevant to permit the jury to reach those facts and any other relevant facts contained in the President’s and Rosenstein’s reports
  468. Kavanaugh, Loughrin, and the President’s Conduct in Dramatic Steps, The New York Times (Dec
  469. 22, 2017)
  470. Excerpts From The Times’s Interview With Trump, New York Times (Dec
  471. 22, 2017)
  472. Kavanaugh, Loughrin, and Rosenstein Testify That Trump Is Not a Grand Jury, New York Times (Dec
  473. 23, 2017)
  474. Kavanaugh, Loughrin, and Rosenstein Testify That Trump Is Not a Grand Jury, New York Times (Dec
  475. 23, 2017)
  476. In a separate development
  477. ====================
  478. Despite the President’s repeated denials that he had ordered Cohen to have the Special Counsel removed, the evidence does not establish that the President asked Cohen to have the Special Counsel removed
  479. The President’s actions towards Cohen were not exclusively motivated by his personal interests, but also arose from two potentially overlapping matters
  480. First, as described in Volume I, Section II, supra, Cohen’s prior criminal conduct included two separate bank witness’sts, one of which was paid for by the President in order to support his claim that the President acted for the sake of protecting the President and another by means of threats and intimidation of witnesses
  481. See supra, p. 19
  482. Second, while Cohen’s preexisting criminal conduct was relevant to the Special Counsel’s investigation, the evidence does not establish that the President asked or pressured Cohen to have the Special Counsel removed
  483. Accordingly, Cohen was never ordered to have the Special Counsel removed
  484. The Office’s decision-making process on prosecutorial misconduct issues is unique and raises unique constitutional issues
  485. Because of that unique position, we have assessed the constitutional issues arising from the Special Counsel’s removal and have concluded that removal is constitutional in several respects: First, the Special Counsel’s removal jurisdiction allows him to remove the Special Counsel only if the public has a basis to believe that it is investigating an official matter internally, involving no physical confrontation; and
  486. Second, the Special Counsel’s removal authority accords him full access to the Oval Office, which, under the Constitution’s separation-of-powers principle, protects him in cases where he is removed from office
  487. The Special Counsel’s removal authority also abridges serious concerns about abuses by the President and his aides, including a credible threat to impeachment
  488. Given those concerns, the Court’s function is not to make definitive determinations about law or form of government but to protect members of the Executive Branch from acts that would corruptly obstruct the facts of a criminal matter and thus render the matter inapplicable to Presidents Trump, Clinton, and Obama
  489. The Special Counsel’s removal jurisdiction also circumscribes the obstruction-of-justice statutes’ by which the President can be found to have obstructed justice
  490. Third, the Special Counsel’s jurisdiction allows him to investigate matters involving grand juries and courts of appeals, which is relevant to the question of obstruction of justice
  491. Although the President’
  492. ====================
  493. Press Release Emails, -PP- Trump to Manafort, via Facebook post, Instagram post, and e-mail, Sep
  494. 2015; 2/14/15 Email, Press Secretary to Kushner et al.; 2/14/15 Email, Kushner to Press Secretary
  495. 2/14/15 Email, Kushner to Press Secretary Kushner et al
  496. 2/14/15 Email, Kushner to Press Secretary, Russian Ministry of Foreign Affairs
  497. Kushner 4/11/18 302, at 5; Press Release Emails, -PP- (In the past month, several Russian contacts and business connections have been linked via LinkedIn to Trump Organization and properties in the United States, including Trump Tower Moscow)
  498. Kushner 4/11/18 302, at 6
  499. See, e.g., David Ignatius, Trump Never Asked for Manafort’s resignation, New York Times (July 16, 2017)
  500. David Ignatius, Trump Never Asked for Manafort’s resignation, New York Times (July 16, 2017)
  501. In a September 2018 interview with this Office, Manafort’s counsel stated that Manafort had been complaining about the press coverage of his allegations against Cohen
  502. Mashburn 10/26/18 302, at 3
  503. Cohen said he did not pursue the Manafort lawsuit because he believed the media coverage had “drowned[ed] [it] down” and had “incited [it] to this high level of consciousness.” Cohen 9/12/18 302, at 3
  504. Cohen 9/12/18 302, at 3
  505. Cohen’s public statements during the campaign were widely covered by the press
  506. Sam Clovis, Michael Cohen’s New York Times Opinions, Opinions, and Inquiries Are Turning Against Trump, Newsweek (July 16, 2017)
  507. Cohen 9/12/18 302, at 3
  508. Cohen’s public statements during the campaign were also widely covered by the press
  509. Sam Clovis, Michael Cohen’s New York Times Opinions, Opinions, and Inquiries Are Turning Against Trump, Newsweek (July 16, 2017); Pamela Brown et al., Trump Is Not Shaking His Endorsement Off Trump: Reports Surging Ledgestone Was not surprised by Trump firing Comey, Corallo 1/26/18 302, at 3; Eugene Smith, Trump Was Not Considering Demanding Comey’s End
  510. ====================
  511. In a separate development, on February 2, 2016, a federal prosecutor in the Southern District of New York announced that Russian intelligence officers had hacked into the computers of the U.S
  512. personas “social media accounts” and “social media accounts affiliated with the Russian government." The announcement marked the first time that Russian intelligence officers had attempted to hack into the computers of U.S
  513. persons and entities involved in the government’s political campaign
  514. Among other things, the announcement said, “the Russian government has hacked into the email accounts of U.S
  515. persons and entities, including the Clinton Campaign, the DNC, the Clinton Campaign, the Clinton Campaign’s personal email account, and the DNC’s email account." The announcement also said, “The DNC and the Clinton Campaign were hacked to death in July 2016.” WikiLeaks also announced the release of stolen emails on October 7, 2016, three days after the DNC and the Clinton Campaign had been publicly announced
  516. In addition, in her Senate testimony on October 12, 2016, Senator Sessions also stated that he had “been mandated to testify before Congress on a wide-ranging conspiracy with the Russian government to interfere in the 2016 presidential election, including evidence of Russian government efforts to aid candidate Trump.” Testimony before the Senate Judiciary Committee also confirmed the testimony of Respectfully Quotation Honorable Chris Hayes, Secretary of the Senate, during his confirmation hearing: Judge: Judge: Allow 2 days for the President to resign or the new beginning of the oath at both the beginning and the end of the hearing
  517. Hearing on Russian Election Interference Before the Senate Select Intelligence Committee, 115th Cong
  518. (June 8, 2017) (Statement for the Record of James B
  519. Comey, former Director of the FBI, at 4); Priebus 1/18/18 302, at 11; Bannon 2/12/18 302, at 16
  520. Hearing on Russian Election Interference Before the Senate Select Intelligence Committee, 115th Cong
  521. (June 8, 2017) (Statement for the Record of James B
  522. Comey, former Director of the FBI, at 4); Comey 11/15/17 302, at 14
  523. Comey 1/7/17 Letter, at 1; Comey 11/15/17 302, at 14
  524. Comey 1/7/17 Letter, at 1; Comey 11/15/17 302, at 14
  525. Comey 1/7/
  526. ====================
  527. Indictment
  528. The district court presiding over the prosecution of Manafort had jurisdiction to sentence Manafort to at least 17 years of imprisonment without the possibility of pardon, and to prohibit Manafort from further “direct or indirect action by [him] in an official proceeding” or “in a criminal trial” if Manafort “represents that his rights as an accused were violated in a timely and vindictive manner
  529. A new trial
  530. As noted above, this Office evaluated prosecution and declination decisions in several cases, and found substantial evidence that a First Amendment defense would be compelling
  531. While the government argued that search and seizure of its computers and other electronic devices is a First Amendment violation, see Volume II, Section III.B, infra, the evidence we found compelling was outweighed by the evidence of civil liability arising from other First Amendment issues
  532. And the evidence of potential liability arising from other means of influencing an official proceeding — e.g., by linking the commission of a crime to aDonaldTrump Campaign communication or other campaign-related communications — was reflected in substantial part in the notice and information dissemination about the prosecution and declination decisions reached by the Office
  533. The government argued that these legal defenses would be insufficient to satisfy the Superseding Indictment and Motions for a Conditional Judgment Order (SILK Order), Opinion no. 1, United States v
  534. Manafort, at 2-4; Opinion op
  535. at 23; Waiver of Indictment Order (EDEO) Order (Feb
  536. 14, 2019)
  537. SILK ORDER
  538. As discussed above, the government’s case rested on the theory that a prosecutor’s motive in pursuing an indictment is to put an end to an illegal obstruction-of-justice
  539. The Indictment
  540. In a nutshell, the government introduced evidence about a June 9, 2016 meeting between a Trump Campaign official and Russian Ambassador Kislyak in Prague, Czech Republic, to question whether the official was part of a coordination between the Trump Campaign and Russia
  541. The official had previously or may have made repeated trips to Moscow in connection with that trip, and the ambassador had told the government that the meeting was about Russian adoptions of Russian children
  542. At the time the government’s evidence was itself persuasive circumstantial evidence — namely, the statement that no grand jury had jurisdiction to investigate Russia’s election interference — that Russia could interfere with the election
  543. But the government’s evidence was not — by any stretch
  544. ====================
  545. McFarland 1/26/18 302, at 6-7
  546. Cohen 8/6/18 302, at 6
  547. Cohen 8/6/18 302, at 7
  548. Cohen 9/12/18 302, at 5; Cohen 11/20/18 302, at 3
  549. Cohen 9/12/18 302, at 5
  550. SCRO1la
  551. Cohen 9/12/18 302, at 4; Cohen 11/20/18 302, at 3
  552. Cohen 11/20/18 302, at 3-4
  553. Cohen 11/20/18 302, at 3-4
  554. Cohen 11/20/18 302, at 3-4
  555. Also during the floor discussion on December 6, 2017, Cohen stated that he had no regrets about what he had done in the communications with the Russian Ambassador
  556. Cohen 9/12/18 302, at 5
  557. Cohen 9/12/18 302, at 4
  558. The next day, December 7, 2017, Ambassador Kislyak called Cohen and asked whether Cohen would be willing to travel to Russia to speak to the Russian government
  559. When Cohen rejected the proposal, the Russian Ambassador said that he could not travel to Russia because that country had no relationship with Russia and that Russia could retaliate by getting rid of U.S
  560. ambassador
  561. Cohen told this Office that he had told the Russian Ambassador that he would not travel because that country had no relationship with Russia and that Russia could not take retaliatory measures See Volume II, Section II.K, infra
  562. In January 2018, Cohen began working with the Trump Campaign on the proposal, and asked Campaign officials to pass the request along to the candidate so that he would not be isolated or take retaliatory steps to prevent the investigation from continuing
  563. Cohen told this Office about his initial meeting with the Campaign official and the request he made to meet with the Russian Ambassador, including the request that the investigation be abandoned
  564. He recalled that the official said that he would appreciate it if Cohen “lock her up,” because that was the approach that had been considered most recently
  565. The official said that he would probably be murdered if he talked to the candidate again
  566. Cohen recalled that he was with the Campaign at the time and that the attention they had received about him made them want to get him —
  567. They also believed that he had affairs with older women that made it difficult for them to sustain such a relationship
  568. Cohen
  569. ====================
  570. Consensus among policy wonks that the Russia investigation needed to be thoroughly investigated and neutralized, but not everyone on the campaign did so on their own
  571. Some Democrats, mindful of the perception that they would be portrayed as corrupt by the media, tried to prevent the release of the emails setting up the June 9 meeting
  572. According to Campaign-favor, a Clinton supporter of Jared Kushner’s Senate campaign, Kushner did not want to be associated with the Russia investigation and, after consulting with his family members, decided not to share information with anyone but the candidate
  573. In addition, some Trump Campaign officials became aware of emails setting up the June 9 meeting and began to question the legitimacy of the meeting when it occurred, particularly after it occurred
  574. In addition, some witnesses withdrew their objections to the meeting before it occurred, as documented by individuals who had previously been friendly to the Campaign
  575. --HOM-- — George Papadopoulos, who had previously served in the Marine Corps, recalled that, before the June 9 meeting, he learned that the Trump Campaign was personally involved in a pro-Russian political operation in Russia that was subsidized by the Russian government
  576. That allegation is consistent with information about the June 9 meeting being part of a U.S
  577. rallieous Russian government support for candidate Trump
  578. --HOM-- --HOM-- George Papadopoulos, who had been hired by the Trump Organization as a political consultant, told the Office that, after the June 9 meeting, he spoke with candidate Trump and candidate Trumpored the meeting to something else
  579. During interviews with the Office, Papadopoulos denied having any connection to Russia or with the Trump Campaign
  580. But the Office found no evidence that these statements were accurate or supported Papadopoulos’s version of the events discussed in the meeting
  581. Papadopoulos 10/16/17 302, at 4
  582. Papadopoulos 10/16/17 302, at 4; Papadopoulos 9/17/17 302, at 8, 10
  583. Papadopoulos 9/17/17 302, at 8
  584. Trump Organization officials were aware of the June 9 meeting at the time it occurred, and it is possible that they communicated that fact to members of the Trump Campaign
  585. According to one party lawyer, who was involved in the effort to have the meeting explicitly told Trump Jr
  586. --GJ-- Papadopoulos 9/19/17 302, at 8; RP_000079 (Papadopoulos 8/
  587. ====================
  588. Written Responses of Donald J
  589. Trump (Nov
  590. 20, 2018), at 15 (Response to Question IV, Part (a)); Op
  591. at 257-258; OSC-KAV00118 (Dv
  592. ректы III,пропротивные приятива,”)
  593. Written Responses of Donald J
  594. Trump (Nov
  595. 20, 2018), at 17 (Response to Question IV, Part (c))
  596. Donald Trump Jr
  597. retweeted additional @TEN_GOP posts shortly thereafter,” but the investigation did not identify evidence that he conducted these actions at the same time as Kushner and Bannon discussed possible future political connections to Russia
  598. In late November 2018, Kushner went to Trump Tower to meet with senior campaign officials
  599. Kushner began work on a memorandum of understanding with the President-Elect in advance of the meeting with Putin
  600. The memorandum described an agreement, described by Trump as a “once in a lifetime opportunity,” to give Kushner and Putin a behind-the-scenes look at the “Russia business” and suggested that the deals could bectioned by the Campaign
  601. Trump met with Kushner in the lobby of Trump Tower on November 27, 2016, after which Kushner had a chat with Putin
  602. During the meeting, which lasted approximately 30 minutes, the President-Elect asked Kushner a number of probing questions about his connections to Russia
  603. During the meeting, Kushner told the President-Elect that he had just met with someone who had connections to Russia
  604. That person told the President-Elect that he had just met with someone from the Kremlin
  605. During the meeting, the President-Elect asked Kushner about his connections to Russia, particularly to information about the Hillary Clinton email server, Clinton’s and Trump’s connections to Russia
  606. When Kushner returned to the President-Elect about the meeting, the President-Elect asked Kushner a few more times whether Kushner was still representing the Trump Campaign
  607. Kushner finally responded that “we” had just met,” and he informed the President-Elect that it was very good” to have Kushner as a Campaign advisor
  608. Kushner also had previously briefed candidate Trump on the status of the Clinton email server
  609. During the presidential campaign, Trump told friends and associates that he had “never seen anything that as far as I know as lead over your head like that
  610. ====================
  611. That day, the President asked Pompeo to resign and, as a result, met with the Gang of Eight to nominate Sessions for the Supreme Court
  612. That evening, the President asked Rogers for his thoughts on Sessions
  613. At 3 p.m
  614. that afternoon, the President invited Sessions to dinner at the White House and requested that he meet with him in the presence of Kennedy
  615. Sessions announced that he would not be serving out his term
  616. Shortly thereafter, the President met with McGahn, Priebus, and other senior officials for a second meeting to discuss the President’s request
  617. At that meeting, the President stated that he wanted Sessions to stay
  618. The President also told Sessions that although he disagreed with Holder’s decision to remove the Special Counsel, he agreed with Holder’s belief that the Special Counsel had violated DOJ 18 U.S.C
  619. § 1001 that is significant in light of the DOJ’s longstanding position that it is not lawful for a federal official to investigate an underlying crime
  620. The President’s statements about Sessions’s “willingness” to resign were widely reported at the time of Sessions’s recusal
  621. And in a July 27, 2017 interview with the New York Times, the President stated that he had “never asked for or asked for a pardon for Paul Manafort, or a pardon for Eric Holder, or a presidential pardon for anyone else, other than Holder himself.” The President said, “I would never do anything to pardon anybody else.” In light of the PRESIDENT’s recusal, this report does not contain a true story because the President was aware of no such request or pardon
  622. Before the Times and other media sources reported on the President’s June 2016 request of a FISA Court judge to search Trump’s personal counsel’s office, lawyers for the President represented him during cross-examination and during interviews, and in interviews with this Office and this Office, the President acknowledged that he called Manafort at least twice and visited on him attorneys who had interests in the Trump Campaign
  623. As previously noted, see Volume II, Section II.E, supra, the circumstances of the encounter and the call for a search testify to the President’s ability to remember when and where the communication occurred
  624. And the President’s contemporaneous comment that Manafort had threatened to resign rather than carry out the order was a direct response to the President’s
  625. ====================
  626. At the same time, the President’s personal counsel said that he believed that the President had a duty to the President to ensure that the removal of the Special Counsel was supervised and controlled so that it would not undermine the President’s ability to perform his constitutional role
  627. Finally, the President’s counsel told the President’s personal counsel that “administration officials” had the authority to remove the Special Counsel, “all the while keeping the President abreast of developments in the investigation and in the trial and possible pardons for Manafort and Gates if the President exercised his legal authority.” Resistance to such a direction would be highly unusual, if not unusual, when the President’s interests in an Attorney General were well-aligned with the President’s interests in power
  628. Finally, the President’s personal counsel said that he believed that “Congress has a responsibility to act.” By the President’s own account, however, he stated that he “waited” to impeach Manafort, but the President did not act when Manafort was “free to walk away from [him]”—an assertion that the President’s own counsel said was “false.” The President’s counsel also made a similar point when addressing congressional opposition to removing the Special Counsel
  629. In part, that understanding was based on the President’s belief that if the public objected to the Special Counsel being appointed, the Special Counsel would use his legislative power to remove the Attorney General, including by impeachment
  630. By contrast, the President’s position in the White House Counsel’s Office, which reflected the President’s personal counsel’s views, provided the basis for Congress to oppose the appointment
  631. Congress clearly has the authority to remove the Attorney General, and the removal authority should be exercised with the bipartisan consent of both Houses and the Senate
  632. The President’s counsel raised constitutional issues of constitutional importance, and the President’s position in the White House Counsel’s Office provided him with the authority to remove the Attorney General if those “powers were absolutely necessary to carry out the laws,” and “Congress was not an object of the Congress in the President’s determination whether to accept the appointment of the Attorney General.” In order to vet those arguments, the President’s counsel submitted — in part, that there are
  633. ====================
  634. Cabinet Office, Fiscal 2018
  635. The President also told McGahn to say that Comey should be fired and that McGahn had “ridiculous authority” to terminate Comey
  636. At the time this report was written, the White House had not publicly acknowledged the existence of this Office’s Russia investigation
  637. The President had also previously told McGahn that he did not want to be involved in investigations into investigations at all
  638. These facts support the conclusion that the President acted “inadvertently” by notifying Rosenstein of the President’s intention to have Comey unrecuse himself
  639. It is unclear whether the President had any other intention in firing Comey, and firing Comey would not have the same impact on the Department of Justice as firing Comey told Sessions directly that the President should give Comey a chance to resign or get out of his job
  640. It is also not clear that the President followed up with Comey directly after firing Comey
  641. If the President had a personal incentive to get Comey to do something that he did not want Comey to do, it would be reasonable to expect that he would want to give Comey a chance to resign
  642. Other evidence that supports the conclusion that the President wanted Comey to quit is the level of scrutiny heaped on him by the press and the President’s own denials
  643. The President’s own denials are consistent with that denial
  644. In addition, other evidence supports the conclusion that the President went further by demanding that Comey unrecuse from the Russia investigation
  645. The President told Comey that if Comey did not comply with the President’s request, he would get out of the investigation or the consequences of what he had done would be catastrophic to the President
  646. The President further asked Comey to “let[] Flynn go.” Comey agreed to drop the Flynn investigation and agreed to be interviewed by the press, including Sinclair Broadcast Group and the President’s personal counsel, in an effort to find out whether he had violated his legal duty to inform the Acting Attorney General before making public statements that would impede or interfere with the investigation
  647. The evidence does not establish that the President was attempting to obstruct justice
  648. The President’s actions can be divided into two distinct phases reflecting a possible shift in the President’s motives
  649. In the first phase, before the President fired Comey, the President had been told that Comey was not doing the government a service by briefing McGahn and senior White House officials on the FBI’s Russia
  650. ====================
  651. It is a bipartisan crime in any campaign year for a foreign government advisor to engage in any conduct “knowingly and dishonestly.” United States v
  652. Nader, Nos
  653. 06–5482–cr-32 (D.D.C
  654. Dec
  655. 1, 2006), Doc
  656. 7 (“Whoever...
  657. Obtained or retained by deception any document or information obtained by others.”)
  658. Nader, supra provides: “Whoever...
  659. Obtained or retained by deception any document or information obtained by others.” 52 U.S.C
  660. § 30101(9)(A)(i)
  661. The term “knowingly and willfully” provides the element of “knowingly” to a defendant, and the proper reading of the statute provides that this subsection is aimed at preventing corrupt conduct by a particular political party or interest
  662. See 18 U.S.C
  663. § 1512(b) (“The Attorney General may by written instruction or consent be deemed to give this subsection an additional term,” and the statute then to be used with the added statutory meaning “commence with ‘knowingly and willfully” and “shall include both the word ‘knowingly and informally”)
  664. The nexus element sets off alarms in the President’s direction
  665. The nexus element thus defines the obstruction-of-justice statutes’ work together in something of a prosecutorial gray area
  666. See Watkins v
  667. United States, 354 U.S
  668. 204, 220 (1957); United States v
  669. Nixon, 418 U.S
  670. at 707-708
  671. Even when a statute defines a nexus, the Supreme Court has “dirt” never provided the President’s “armed invocation” to be an element of a charge of a crime
  672. See Watkins v
  673. United States, 354 U.S
  674. 206, 222 (1957) (“The Constitution does not mandate that [Congress] ..
  675. shall act [or be mistaken in its judgments]”)
  676. Likewise, the “corrupt” provision in the Twenty-Fifth Amendment to the Constitution does not mandate that the President should do anything to obstruct justice
  677. The President’s exercise of his Article II power to investigate and prosecute investigations is grounded in the American Public Legal Forum (APS) Principles document
  678. Statement for President of the Council of Scientific and Techn
  679. ====================
  680. The President began his press conference by telling reporters, “I think we ought to get out there and say, ‘Don’t meddle,’ and I think that’s right.” He said, “I think we’ve got to do a lot of good talking points,” and he concluded the conversation by saying, “I think we’ve got to put out a good press
  681. ..
  682. [H]ow are some of those days when people who are good at things call me up and tell me they like what I’ve done?..
  683. [R]emember what you said about the McCabe memos?..
  684. [T]he United States has no standing omits material details or omits political leaders or leaders of departments apart from one or the other.” McGahn 2/28/19 302, at 4
  685. McGahn 2/28/19 302, at 4
  686. McGahn 2/28/19 302, at 4; SCR015_000116 (President’s Daily Diary, 6/14/17)
  687. -PP- Priebus 4/13/18 302, at 6; Priebus 4/13/18 302, at 6; McGahn 12/14/17 302, at 1; Priebus 4/13/18 302, at 6; McGahn 12/14/17 302, at 1; Priebus 4/13/18 302, at 6; McGahn 12/14/17 302, at 1; Priebus 4/13/18 302, at 6; McGahn 12/14/17 302, at 1; Priebus 4/13/18 302, at 6; McGahn 12/14/17 302, at 1-2; Priebus agreed that he had “got[d] to do it for the country,” and if McGahn did not deliver, the President would be fired.” Later that day, Priebus called the President and told him that he “can’t do it,” and told Priebus that he could not fire the FBI Director, that the Department of Justice and Congress would not approve of his firing and he would be fired anyway
  688. The President asked Priebus to set up a meeting with Comey within two days of the appointment
  689. Priebus said he would, and the President invited Comey to deliver a message to the National Security Advisor in Council that the President felt was
  690. ====================
  691. "I think that when you look at what he has done, and what he has brought to the table, I think it is very unfair to the President and very unfair to the President’s son, and I would urge you to protect your son as you prosecute this issue, because for years the President and his advisors have been saying to themselves — and this is the problem — this is the man, this is the investigation, this is the obstruction
  692. I think it is very unfair." On July 11, 2017, the President told an audience of campaign foreign- policy advisors that “the thing with the Russians — the whole thing with the Russians — it’s a big deal.” The President said a false story involving his phone call with Comey was not a good idea because if there was a problem with the president, “heh he is,” and if there was a problem with the Department of Justice, “hek he is,” and if there was a problem with the Department of Justice, “hek he is,” and if there was a problem with the Department of Justice, “hek he is,” and if there was a problem with the Department of Justice, “hek he is,” and if the President were in charge of the Russia investigation, he would “let[] Flynn go,” but the President made no such effort to do so
  693. In late December 2017, Comey was scheduled to testify before HPSCI
  694. In the days following Comey’s testimony, the President told advisors that he was going to fire the FBI director, and the media speculated that the President would offer his own recommendation
  695. On December 23, 2017, the New York Times reported that the White House had told the President that Comey had told the FBI not to investigate Flynn because “Crazy!” The President had said that many times before that he thought Comey had told him to stay on message; that the FBI had told him to “not comment” on the investigation; or that “when they tell you’re investigating, you know you’re investigating.” In addition, the President asked advisors to pass notes Comey took of his conversations with the President that would be relevant to an investigation into Flynn
  696. On December 24, 2017, the President dictated an apology and said, “When I say this office sincerely apologizes for any and
  697. ====================
  698. 1/28/18 Letter, President’s Personal Counsel to Special Counsel’s Office, at 19 (agent note)
  699. Counsel for Ivanka Trump told the President’s personal counsel in the White House that the President believes Cohen should be removed from office by the end of February and that he must be removed so that the Special Counsel’s Office and the Department of Justice could exercise their constitutional authority to terminate those who were in the government ("rigged system"), or by requiring that officers in the President’s and the Acting President’s departments exercise their removal authority
  700. She further told the President’s personal counsel that the removal of Cohen from his position was a relief to be had in the form of a pardon or suspension of the Special Counsel’s investigation
  701. Announcement of the Special Counsel’s Inquiry 1/29/18 Letter, President’s Personal Counsel to Special Counsel’s Office, at 19 (agent note)
  702. The President’s personal counsel told the President’s personal counsel that the President had always wanted a Special Counsel and that by firing Cohen, the President was hurting his relationship with the Department of Justice and must take action to end the Russia investigation
  703. This formulation of the President’s statement could be read as reflecting that the President wanted Cohen to provide false testimony against the President in an attempt to obstruct justice and that the President expected Cohen to provide truthful testimony against the President in an effort to minimize the President’s involvement in the investigations
  704. It also could be read as reflecting that the President wanted Cohen to provide a false testimony against the President in an effort to discredit the Special Counsel and prevent his from continuing as Special Counsel, and that the President expected Cohen to provide truthful testimony against the President in an effort to minimize the President’s involvement in the investigations
  705. The President’s personal counsel told the Special Counsel’s Office he thought Cohen’s testimony would help resolve the impasse in the White House and that they would be able to work with the President to deliver that message
  706. Into the spring of 2017, Cohen continued to cooperate with the Special Counsel investigation, including his March 2017 meeting with the President and his request for a meeting with Special Counsel investigators
  707. On April 4, 2017, Cohen told another individual that he had told Cohen story after story, including the stories linking the President to the Russian interference business, the President’s personal counsel
  708. ====================
  709. Standard operating procedure for assessing the probable causeableness of a criminal violation of 18 U.S.C
  710. § 1001 if the official acted with an improper purpose
  711. See United States v
  712. Sampson, 898 F.2d 1331, 1333 (D.C
  713. Cir
  714. 1991), also involving an improper purpose Testimony of Andrew Patten, Patten K.I
  715. & Maggie Haberman, Grand Jury subpoenas to three Trump campaign officials, construe grand jury statutes to exclude corrupt officers, New York Times (Oct
  716. 18, 2017)
  717. Patten 12/12/17 302, at 17; 12/16/17 302, at 3-4
  718. Haberman 7/13/18 302, at 4
  719. Dvoskin, D.C
  720. Cir
  721. 1996, at 7-8; Anderson 6/25/18 302, at 4; Gordon 8/29/17 302, at 5; Conyers 6/30/18 302, at 2
  722. Sampson, 8/18/17 302, at 5-3, 5; Sampson 6/30/18 302, at 1; Gordon 9/7/17 302, at 2
  723. Office of the Counsel’s Counsel to the President (OCC’s) opinion, however, noted that the memorandum “suggest[ed] that a complete and total resignation on Mr
  724. Trump’s watch” was possible
  725. In July 2016, Papadopoulos suggested that a general election was possible if the Trump Campaign “delegitimized' the candidate as an official Trump campaign member
  726. In a July 20, 2016 email intended for Manafort, Papadopoulos wrote: On the same day, HPSCI sent a memorandum to Trump Campaign chairman Paul Manafort promising his assistance in organizing a “private meeting with some high level representatives of the Russian government this week to discuss a “reactionary message” that could be delivered to delegitimize Mr
  727. Trump as President of the United States
  728. The email described a “hands-off” meeting between Trump officials” and a group from the Russian Ministry of Foreign Affairs with representatives from the Presidential Development Initiative (PMI), the Russian government’s embassy and the Russian government’s foreign ministry
  729. The AMI and the Russian ministry meet regularly in the fall of 2016
  730. The memorandum also noted that “the Russian government could
  731. ====================
  732. Dearborn, Comey, and Dhillon, and those witnesses testified that the President had told them the same thing in a private conversation the previous day, which Comey interpreted as an attempt by the President to make him “snap out of it” and prevent the FBI’s investigation from continuing.” The President said the investigation was not going to stop
  733. The President said he wanted the investigation to continue and that by continuing it would “infuriate and embarrass” himself and cast him as something of a “witch” who was conspiring with her colleagues to protect Hillary Clinton
  734. Two days later, on January 16, 2017, the President tweeted that “the story that there was collusion between the Russians and you is a total lie!” In a second tweet, the President said, “This Office saw a Comey interview with the President and he was so angry he called me at home — totally wrong!” In a third tweet, the President said, “This Office saw a lot of Comey lies, and I was so angry I called him at home — totally wrong!” In a fourth tweet, the President said, “if you get along with the President, why should your job or your life be in jeopardy, why should anything or anyone else be taken care of by the FBI?” In a fifth tweet, the President wrote, “Now that Jeff [Ratchford] and [Sharon LaFraniere] are saying that this is the witch hunt, it might as well be the FBI.” In a sixth tweet, the President referred to a New York Times article about the FBI’s investigation into Flynn, asked “what do you think of Jeff [Ratchford] and his Russia contacts” and concluded, “I think [Flynn] should have known better than most people that the FBI has access to his phone calls and emails when he is in the White House.” In a seventh tweet, the President said, “How could you let this happen, Jeff?” On January 18, 2017, the Obama Administration announced that Cohen and candidate Trump had had separation-of-conflicts investigations
  735. Cohen had worked to create a national investigation of Russian interference in the 2016 presidential election
  736. The Trump Campaign had received a document request from the Russian government-related request at the same time that the Trump Administration had received a document request from the Russian
  737. ====================
  738. The President, however, told the Attorney General to fire Sessions and stated that if he stayed on message, Sessions would be fired
  739. At 3:43 p.m
  740. that afternoon, the President called McGahn on the set of NBC's Meet the Press and asked him to intervene
  741. McGahn interpreted the call as an effort to try and get Sessions to reverse his recusal, but the President’s initial instruction was not abusive
  742. Referring to Sessions’s recusal, McGahn responded that Sessions had recused himself from the Russia investigation because he had mishandled the Clinton email investigation, which McGahn believed should be ended
  743. McGahn told the President that the “wonderful task” was in the President’s hands
  744. He told the President that DOJ career prosecutors’ had told him that the Department of Justice was not taking Sessions’s recusal seriously and that the Department of Justice was working on a new recusal
  745. He told the President that the Department of Justice was not investigating Sessions personally, but was instead investigating toothbrushing testimony from Sally Yates and her omissions from her written reasons for recusal
  746. He told the President that the Department of Justice was not going to take Sessions’s recusal seriously and that the Department of Justice and Congress had moved to terminate Sessions for having not followed the law
  747. He told the President that the Department of Justice was not going to take a recusal into account when making any prosecutorial judgment
  748. He told the President that FBI Director Comey had been a “good man” and “well-respected” by the FBI community and that the Department of Justice and the courts had a duty to honor Comey’s recusal
  749. He told the President that the FBI was not going to close the investigation if Sessions were confirmed and principal Deputy Attorney General Rosenstein was gone
  750. McGahn 2/28/19 302, at 1-2; SCR015 000175-82 (Undated Draft Memoranda to White House Staff)
  751. White House Daily Briefing, C-SPAN (Jan
  752. 12, 2017)
  753. McGahn 12/12/17 302, at 11; Priebus 10/13/17 302, at 17; McGahn 12/12/17 302, at 11
  754. McGahn 12/12/17 302, at 11; Priebus 10/13/17 302, at 17
  755. SCR015_000175-82
  756. ====================
  757. President Trump called Comey before a meeting at the White House with Comey
  758. The President told Comey that the President wanted him to come to the White House to convey that the Department of Justice was not investigating the President personally
  759. When Comey later testified before Congress about this conversation with the President, he told the President that the conversation with Comey was not a reflection of the President’s views on the investigation or any investigation's Special Counsel’s investigation
  760. The President also told Comey that he and the President had discussed Comey’s job search with him at the White House
  761. Comey’s briefing coincided with President Trump’s trip to the Middle East
  762. Comey recalled that the President had invited Comey to dinner one day after the President had met with Lavrov and that the President had mentioned Comey’s recent book’s release and phone calls during the campaign
  763. Comey recalled that the President had mentioned Comey’s trip to meet with him and that the President had asked him to stay behind in the Oval Office as Comey spoke
  764. Comey recalled that when he arrived at the Oval Office, the President had told him to have Comey McFarland 12/22/17 302, at 15; see SCR012b_000020 (President’s Daily Diary, 3/30/17) (reflecting call from the President to McGahn on 3/30/17 with start time 10:31 am, and from 3/30/17 CMTEk Sirk To Be Obtained “The Times Now Showing That Senator Burr Is Considering Taking Over the Assassination of Neil Gorsuch With Neil Gorsuch, And Raising the Budget Tolls."]
  765. During the week of February’s presidential election, a foreign-policy advisor to the Trump Campaign made a trip to Russia in July 2016 to meet with Russian Ambassador to the United States Sergey Kislyak
  766. The advisor had been working with the Russian government since summer on a plan for a possible connection between the Trump Campaign and Russia
  767. The advisor had been told by Kislyak that the Russian ambassador was very worried about Donald Trump
  768. Later that summer, the advisor met with Kislyak and informed the ambassador that the Russian ambassador had become very concerned about Trump
  769. The ambassador thought the two were very close and trusted persons, and they would need to work together to make a connection
  770. The ambassador concluded the meeting by saying “we can’t be taken for granted that Russia has a relationship with Trump’s
  771. ====================
  772. That same day, Cohen’s lawyers told Cohen’s counsel that Cohen should not have been in the room about the President’s request that Comey “let[] Flynn go.” That same day, Cohen’s lawyers again told Cohen’s counsel that he should not have been in the room about the President’s request, and that he should have “been there the entire night.” In the morning on May 17, 2018, following the President’s decision to terminate Flynn, McGahn met with Cohen and the President to discuss what to say about Flynn and what to prevent the President’s actions
  773. In the morning on May 17, 2018, following the President’s decision to fire Flynn, McGahn met with Cohen and the President in the Oval Office to discuss the news that Flynn had misled the Vice President
  774. According to Cohen, the President said that Flynn had lied to him and said that Flynn could no longer have a relationship with Russia
  775. Cohen told the President that Flynn could no longer have a relationship with Russia, and the President directed McGahn to say so in her report to the President
  776. Cohen recalled that the President brought up the Flynn meeting with her and asked if she knew about Flynn’s contacts with Kislyak
  777. Cohen believed she should have told the President that Flynn could no longer have a relationship with Russia
  778. Cohen recalled that she did not want to provide information that would “make you look bad”--GJ--Cohen 8/7/18 302, at 8; Cohen 9/18/18 302, at 9
  779. Cohen 9/18/18 302, at 9
  780. Cohen 9/18/18 302, at 9
  781. Cohen 9/18/18 302, at 9; Cohen 9/18/18 302, at 9
  782. Cohen 9/18/18 302, at 9; see also Rtskhiladze 4/4/18 302, at 8-9
  783. Cohen 9/18/18 302, at 9
  784. Cohen 9/18/18 302, at 9
  785. Cohen 9/18/18 302, at 9
  786. Cohen 9/18/18 302, at 9; Cohen 11/20/18 302, at 4
  787. Cohen 9/18/18 302, at 9
  788. Cohen 11/20/18 302, at 4
  789. The New York Times reported
  790. ====================
  791. Sessions 8/17/18 302, at 8; Sessions 1/17/18 302, at 3
  792. Sessions 8/17/18 302, at 9; Sessions 1/17/18 302, at 3
  793. Cohn 1/26/18 302, at 4
  794. Sessions 8/17/18 302, at 9
  795. Sessions 1/17/18 302, at 3-4
  796. --GJ-- the President
  797. In his opening remarks at the Mayflower Hotel, which he attended to participants in the Mayflower dinner, the President said, “I never saw Russia as a threat to the presidential campaign
  798. ..
  799. I’m not under any obligation to do so,” but the President continued, “I think I can assure you — and I swear to God — I never saw Russia as a threat to the presidential campaign.” In response to a question about whether he would recuse himself from any future investigations of Russia’s interference in the 2016 presidential election, the President said, “If it’s what you say I love it,” but added, “Even if it doesn’t matter,” explaining that he was “not going to issue a [resignation] letter if it doesn’t matter who you're serving”
  800. Sessions 1/17/18 302, at 3
  801. Michael S
  802. Schmidt & Maggie Haberman, Trump Ally Warns Russia of His Potential Grandstanding, Criticizes Trump for Backchanneling, says Dems Are Sitting On a Scandal
  803. Washington Post, May 16, 2017; see Michael S
  804. Schmidt & Maggie Haberman, Trump Ally Warns Russia of His Potential Grandstanding, Criticizes Trump for Backchanneling, Says Dems Are Sitting On a Scandal
  805.  
  806. Tuesday, May 18, 2017; see Mahdesh Gopinathan et al., Russia Told Trump in New York Times Interviews that Backchanneled, New York Times (May 18, 2017)
  807. Michael S
  808. Schmidt & Maggie Haberman, Trump Ally Warns Russia of His Potential Grandstanding, Criticizes Trump for Backchanneling, Says Dems Are Sitting On a Scandal
  809. Tuesday, May 18, 2017; Michael S
  810. Schmidt & Maggie Haberman, Trump Ally Warns Russia of His Potential Grandstanding, Criticizes Trump for Backchanneling, Says Dems Are Sitting On a
  811. ====================
  812. That was the message he wanted to convey to Bannon, and they agreed not to escalate the meeting further
  813. Over the next several days, the President’s personal counsel met with senior advisors to the White House to try to arrange a solution to the Russia-Trumpland tension, including reaching out to Comey to set up a meeting with the President again
  814. At the President’s urging, he reached out to Comey directly on Twitter on Monday, September 20, 2017, according to an email that shows
  815. A series of private messages and other communications between the President and Comey reflect that the President believed he had a personal stake in the outcome of the investigation, and he sought to make contact with the Department of Justice’s official investigation unit so that investigators would not lose confidence in the President again
  816. On September 21, 2017, the President sent a text message to Comey saying, “Thanks for writing
  817. The way you spoke made a difference
  818. We can get along very well.” The President wrote, “[t]he United States can get along great.” “And if you can do it, I can’t wait...
  819. [t]o the grave,” which would be a very brave thing to say.” The President’s final response was this: “You know what? We’ll see what happens.” The President’s account does not reflect the final version of the conversation, however, and the text messages recorded afterwards are consistent with incoming drafts of the email
  820. When interviewed by the Office, Comey declined to provide additional details of the conversation and stated that he did not want to discuss sensitive matters involving the President or the incoming Administration
  821. When he was asked whether he had a recollection of telling the President about Comey’s conversation with “DOJ official Ciaramella,” Comey told the Office that “[w]hen the story changed, you told me you didn’t remember it.” Comey also said that if Comey could “let[] Flynn go,” he could “let[] Flynn go.” When asked whether he would inform Comey if the President had concerns about Comey speaking to the FBI, Comey finally responded, “If you ask anybody who knows anything, I tell you, ‘They’ve told me once or twice I want him to stay on the team
  822. He’s important to
  823. ====================
  824. Gerson 5/3/18 302, at 4; Gates 4/11/18 302, at 3
  825. Gerson 5/3/18 302, at 4; 5/3/18 302, at 3; 5/4/18 302, at 2
  826. Gerson 5/3/18 302, at 4; Gates 4/11/18 302, at 3
  827. Gerson 5/3/18 302, at 4
  828. Gerson 5/3/18 302, at 4
  829. Gerson 5/3/18 302, at 4; Gates 4/11/18 302, at 3
  830. Gerson 5/3/18 302, at 4
  831. Gerson 5/3/18 302, at 4; Gates 4/11/18 302, at 3
  832. Gerson 5/3/18 302, at 4; Gates 4/11/18 302, at 3
  833. Gerson 5/3/18 302, at 4
  834. Gerson 6/12/18 302, at 2-3
  835. Gerson 6/12/18 302, at 2-3
  836. Gerson 6/12/18 302, at 2-3
  837. Hicks recalled that in the days before the Lewandowski emails, Hicks described Trump Jr.’s statement to the FBI about the June 9, 2016 meeting as “really helpful." But Hicks did not tell Donaldson about the June 9, 2016 statement Trump Jr
  838. stated in her email to the FBI
  839. Hicks 12/7/17 302, at 8
  840. Hicks 12/7/17 302, at 8
  841. Hicks 12/7/17 302, at 8
  842. Hicks 6/12/17 302, at 3; Lewandowski 6/12/18 302, at 2
  843. Lewandowski 6/12/18 302, at 2-3
  844. Lewandowski 6/12/18 302, at 2-3
  845. Hicks 12/7/17 302, at 9
  846. Hicks 12/7/17 302, at 9
  847. Hicks 12/7/17 302, at 9
  848. Hicks 12/7/17 302, at 9
  849. were “very confident” that the statement was true, Hicks said she wanted to “let [it] go” and “let [it] go,” but Trump Jr
  850. wasn’t done with Hicks — he was concerned about what the letter would mean for the Trump Organization
  851. ====================
  852. DJTFP_00008 (8/10/16 Email, Lutes to Cohen (6:43 p.m.); Lutes 10/16/17 302, at 4; Cohen 10/20/17 302, at 2
  853. --GJ-- see Cohen 11/20/18 302, at 8
  854. --GJ-- --GJ-- --GJ-- The --GJ-- mention of a Trump Tower Moscow project led Cohen to think that the Russian government might be interested in getting in on the act, as reflected in the positive responses received in the form of emails and text messages exchanged that day
  855. As noted in Volume I, Section IV.A.6, infra, several individuals affiliated with the Trump Organization worked together on the proposal, including Andrey Baranov, a Ukrainian oligarch who owned stakes in several Russian real estate projects
  856. The Trump Organization investigated and admitted these connections to the I.C
  857. Expert Advisory Group (“AKG”), an Israeli organization that was also involved with the Trump Tower Moscow project
  858. As discussed in Volume I, Section IV.A.7, supra, the Trump Organization maintained that its Access Hollywood tape, released in June 2005, constituted a “public[ly]available[]” and “viral[]” document and that it was working “on behalf of the Trump Organization, its executives, and other important people.” PR Newswire (May 12, 2005)
  859. Trump Organization Press Office Secretary Sarah Sanders told the press that the organization was “investigating the specifics” of Trump Tower Moscow “as an “open secret” and that the Trump Organization was “actively working with the Israeli government on it." (Later in the day, Chris Christie said to the press, “I think it’s ridiculous)” responded to a question about Trump Tower Moscow, “Even if it was a done deal, it would be done in a very positive way.” Christie, who was also the candidate’s foreign policy advisor, reflected that secrecy could detract from the country’s ability to win electionsly honest terms, and he suggested that a foreign government could offer the candidate a pardon if he kept quiet and remained under indictment
  860. Ambassador Kislyak agreed and described the Trump Tower Moscow project to Christie
  861. Trump, however, said that pardons were not pursued in the Trump Tower Moscow project
  862. ====================
  863. Attorney General Sessions on Friday declined to answer questions about whether he personally was in contact with President Trump about the June 9 meeting, but said he would
  864. Sessions 6/12/17 302, at 3-4
  865. In February 2018, a federal prosecutor in the Southern District of New York interviewed dozens of witnesses about the June 9, 2016 meeting and concluded that the Russian security services interfered in the 2016 presidential election
  866. After the interview, Sessions’s personal counsel declined to provide testimony or provide additional information about the interview and its components
  867. Later that day, President-Elect Trump told advisors that he wanted to call Michael Flynn and provide him with details of the meeting with the understanding that he would be provided information otherwise given to the government
  868. Afterwards, Flynn’s father, Eric Trump, told senior policy advisor Stephen Miller that the request had been received at the highest levels and that Flynn was “[j]ust doing fine” in his family life
  869. Flynn’s father also told the President-Elect that the meeting had been about Russia
  870. Counsel for Flynn told the President-Elect that Flynn was very upset about the meeting and wanted it to be over with
  871. Flynn’s brother told the President-Elect that the meeting had been about Russia, not the presidential election
  872. Flynn’s father said that the President-Elect had been insistent that he not tell anyone in the Flynn Administration what he had just talked about
  873. In a later conversation with the President-Elect, Flynn expressed anger about the meeting and said that the FBI was interfering with his ability to run the country
  874. Flynn recalled that the President-Elect asked him what he had just said and he told the President-Elect that the FBI was interfering with his ability to run the country
  875. That evening, Flynn and McFarland spoke at the National Press Club
  876. Flynn said that he was upset by the meeting and that the FBI was interfering with his ability to run the country
  877. Flynn said he was also upset that the President-Elect had asked him to speak to Comey about the FBI investigation
  878. According to Flynn, after speaking with the FBI about the FBI’s “interference,” the President-Elect asked him to “do crazy shit,” he told the President-Elect, “I don’t want to do that
  879. I don’t want to get involved
  880. This is our country,” said Flynn
  881. ====================
  882. The Office was authorized to investigate Flynn-Russian contacts through the Presidential Transition Team, a team that included Flynn, Kislyak, Clinton Campaign chairman John Podesta, and candidate Trump
  883. The Office reviewed thousands of documents related to the transition, including internal communications between senior Transition Team officials and Russia’s ambassador to the United States, as well as correspondence about the transition between Trump and Transition Team members
  884. Based on the available information, the Office did not identify evidence that any of the transition’s members knowingly participated in the conduct described in Volume 1, Section II, supra
  885. After consultation with the Office of the Deputy National Security Advisor, the Office has excluded information contained in the two-page document, which was obtained through legal channels and through channels of a qualified lawyer, without being criminal evidence
  886. Kirill Dmitriev, Russian national who was the deputy national security adviser to Russia until 2014, is a senior executive at a company controlled by Igor Sechin, a Russian businessman who was the head of Gazprom from at least 2013
  887. Two of the employees assigned to investigate the Trump Campaign’s connections to Russia — Dmitriev and Akhmetshin — were born in Russia, and were raised in the United States
  888. While studying at the Carnegie Endowment for International --GJ--, Dmitriev applied to the Russian government and was accepted
  889. The Russian Ministry of Foreign Affairs expressed interest in Dmitriev in the future, and on March 2, 2016, sent him an invitation
  890. On March 31, 2016, Dmitriev and Akhmetshin met in the Seychelles and informed him that they would meet
  891. At a dinner in New York on April 12, 2016, Dmitriev offered his assistance to the Campaign and Russia
  892. --GJ-- said that he was a private citizen who had pursued a business venture in Russia but found that the situation was too difficult
  893. In addition, Dmitriev told the Office that he had received death threats from at least one Russian businessman claiming to have ties to the Russian government
  894. The Office identified dozens of individuals, including campaign chairman Paul Manafort, deputy campaign chairman Rick Gates, and candidate Trump, as well as members of the Russian parliament
  895. --GJ-- the chairman of the Russian parliament's opposition Democratic Party
  896. The Office identified dozens of contacts — “members,” of which is spurring Gribbin’s attention — with Russian nationals and Bulgarians, as well as contacts between Campaign officials in both
  897. ====================
  898. Even as the President sought to have Sessions reverse his recusal, the President made clear that he wanted Sessions to stay on as Sessions’s chief of staff
  899. According to written answers submitted by the President in response to questions from this Office, the President told him “No, I don’t like the job that you are doing and you will soon be leaving.” The President reiterated that he intended to use his personal authority with Bennett to remove Sessions and that the position would be beneficial to both the President and the Campaign
  900. The President told the Chief of Staff that he already knew that the President intended to use his personal authority with Bennett to remove Sessions
  901. The President told the Diplomat that he thought it would be a good idea to have both Sessions and Gordon direct the Department of Justice to review and evaluate the actions of the Obama Administration in curtailing criminal investigations
  902. The President also asked Staff to convey to the President “that we appreciate your taking the unusual step today and expressing your concerns about the ongoing FBI investigation into the events leading up to the recent foreign-policy speech by Governor Cuomo in Edinburg, Minnesota.” The President referred to the “significant deterioration of relationships between the United States and Russia” and said, “I look forward to working with you again on a strategy for restarting relations between the United States and Russia.” After Flynn pleaded guilty to lying to the Vice President, the President tweeted, “I got news for you, terrible treatment of Michael Cohen by BAD BITCH!” The President also asked Staff if could provide “tens and hundreds of thousands of documents,” including “[a] list of concessions made to [Cohen] by the [Russian] government in exchange for [him]keeping the USA tight.” Staff responded, “[i]f the USA needed someone to protect him tell him that there is no need to be creepy round the neck, or something.” The President also asked if “[h]e asked” about the political fallout from the speech, and if SSCI was aware of any efforts by Cohen or anyone affiliated with the Trump Campaign to get Cohen to drop the term Russian interference was not unusual for a campaign supporter
  903. The President concluded by telling Bannon that Cohen was a good guy and that if Cohen stayed on as FBI Director he would get a new start at the end of his term
  904. When the President
  905. ====================
  906. The investigation did not establish that Page was aware of or responsive to any information that WikiLeaks, at any time, or that could reasonably be expected to provide damaging information to the Clinton.1263 Page’s personal counsel stated, “While this Office addresses the law enforcement aspect of the law enforcement issues involved in the Office’s investigation, the Office’s focus is on the President and his actions
  907. ..
  908. That is the core of the matter.” Page, who was born in Russia, began his political investigations through the Trump Campaign as a foreign policy advisor
  909. During the campaign, Page advocated pro-Russian foreign policy positions and spoke of U.S.-Russia relations
  910. During and after the Republican National Convention, Page made repeated trips to Moscow to meet with Russian officials and to offer political asylum in Russia
  911. --HOM-- During and after the Republican National Convention, U.S
  912. intelligence officials received a new batch of emails that could be potentially associated with Russian government efforts to interfere in the 2016 presidential election
  913. In addition, Page received public confirmation that WikiLeaks was releasing politically damaging information about the Clinton Campaign before it was published, which raised questions about WikiLeaks’s ability to control the release
  914. Finally, shortly after the Republican National Convention began, WikiLeaks made a potentially new release of hacked information about the Democratic National Committee
  915. --HOM-- --HOM-- --HOM-- --HOM-- In both cases, WikiLeaks released the emails in their published periodical, but the investigation did not establish that the DNC and Clinton computers were hacked or tampered with by Russia
  916. In late April 2016, Page began working on a public statement about the 2016 U.S
  917. presidential election that he said would focus on the allegations in the Clinton emails, and asked other Clinton Campaign staff to draft similar statements
  918. Writing in early April 2016, Page criticized the “mildly nauseating" charges of Russian election interference that had characterized the Democratic National Convention: Clinton’s statements were often laced with provable lies, and the “bizarrely false" statements that were written into the statement
  919. Page was also asked by investigators about the timing and context of a New York Times interview in which the candidate was asked about allegations in the Clinton emails that the Russians had hacked the DNC
  920. In that interview, Page stated that he was “allowed to” comment on the “previously unknown” nature of the hacking, “analysis, and disclosure
  921. ====================
  922. Donald Trump Jr
  923. placed the DNC’s support behind him
  924. According to Gates, Manafort asked Kushner several times in passing whether Manafort could meet “the guy." Gates did not respond to any of the emails exchanged with Kushner that discussed payment, and Kushner ultimately declined a meeting with Manafort
  925. Gates and Trump Jr
  926. discussed the status of the Trump Tower Moscow project in December 2016 and held periodic meetings to discuss it
  927. Gates and Trump Jr
  928. discussed the status of the Trump Tower Moscow project in June and July 2016
  929. According to Gates, both groups believed that the Trump Tower Moscow project would need approval from the Russian government before it could be built
  930. Trump Jr
  931. requested that the Russian government take steps to protect the project, but the Russian government did not require such approval and the meeting invitations did not identify any Russian government officials involved in the project
  932. Trump Jr
  933. requested approval to build the project on his behalf and solicited contributions from Russian individuals and companies involved in the project
  934. Gates interpreted the June 2016 meeting invitation, which specifically mentioned Russian government officials, to Manafort as well as Trump Organization employees
  935. She provided multiple photos and documents from the meeting, and Manafort’s business card showed a U.S
  936. scheme number that indicated the meeting was held
  937. Gates and Trump Jr.first met Sergei Prikhodko, a Russian government official who was then traveling to Moscow for the sanctioned-confessions purpose
  938. Gates understood that the Russian government did not want U.S
  939. persons involved in the project knowing that it was a Russian project, and Gates sought to avoid U.S
  940. persons
  941. Gates understood that the Russian government intended the Trump Tower Moscow project to work constructively with candidate Trump and that the Trump Organization had no particular interest in meeting with Russia’s ambassador or other individuals likely to act as contact for the project
  942. Gates and Khoo informed Trump Jr.that the project was not feasible and they had decided to seek alternative routes to travel to and from Russia
  943. On June 13, 2016, Trump Jr
  944. requested approval to travel to Russia by boat from Vladivostok, a Russian republic where Russia’s relationship with the Trump Campaign was at an all-time low
  945. He was told that the project was not feasible and asked for assurance that it would be revived
  946. Following his June 13 meeting with Veselnitskaya, Trump Jr
  947. asked Russia’s ambassador to the United States
  948. ====================
  949. Call Records of Michael Cohen
  950. The investigation did not identify evidence of Cohen or his representatives speaking to anyone outside of Cohen’s personal entourage
  951. Instead, it was believed that they used a number of online personas, including r/conspiracy and r/conspiracyontinues
  952. Individuals contacted via the internet included the President’s chief of staff, Priebus, Priebus had previously served as the Republican National Committee chairman (where he had previously served as a counselor in its various incarnations), and Meghan Keneally, who identified herself as a “left” columnist for the New York Times
  953. Cohen told the Office that he did not contact anyone in the Trump Campaign about the issue
  954. Cohen stated that he did so to address the “troubling” fact that the Clinton Campaign had been pushing back publicly against the allegations in the Steele reporting, and to assure the Campaign that the reports were not “false” and that the Campaign was not involved in a “witch hunt” of its own
  955. In addition to the direct contact between Cohen and the Russian government, Cohen 9/12/18 302, at 8; Cohen 8/7/18 302, at 9
  956. Cohen 9/12/18 302, at 8
  957. Cohen 9/12/18 302, at 8
  958. Cohen 9/12/18 302, at 9
  959. Cohen 9/12/18 302, at 9
  960. Cohen 9/12/18 302, at 9; see, e.g., 9/14/16 Twitter DM, @JasonAKEN11 (asking for Trump Campaign’s help in contacting Russian government employees and colleagues"); 9/16/16 Twitter DM, @JasonAKEN11 (asking for Trump Campaign’s help in contacting Russian government employees and colleagues)
  961. 9/16/16 Twitter DM, @JasonAKEN11 & @DonaldJTrumpJr
  962. The investigation did not identify evidence that any Trump Campaign official responded to the DM or Twitter DM accordingly
  963. President Trump and Cohen spoke at length about the investigation’s scope and that the investigation would not “lend [it]’s public/private backing.” During the June 9 presidential campaign, Trump publicly criticized the investigation’s conclusions regarding Russia’s interference in the election and raised the possibility of Clinton’s criminal trial if the evidence was not destroyed
  964. After the election,
  965. ====================
  966. Sessions also told the Office that the President’s request to meet with Comey was “pretty innocuous” because Comey had “led” the White House team
  967. And the President’s desire to meet with Comey was not the result of some elaborate power play between Trump and Comey, but rather the result of a fact that Comey had been trying to prevent the FBI’s investigation from progressing too fast, causing the hearing to close for reasons unknown
  968. The President’s other stated reasons for preventing Sessions’s recusal were not clear
  969. Sessions had threatened to resign before Sessions’s recusal and had been seen’t this week escalating his request for Comey’s loyalty
  970. But the President had made clear to Sessions that he did not want Sessions to be the FBI director, and they had met at the White House before the President met with Rosenstein
  971. There also is some evidence that the President brought up Sessions’s recusal during the May 3 hearing
  972. Sessions testified that the President repeatedly brought up his recusal and asked him to “let[] Flynn go.” It is possible that the President’s comments about Sessions were motivated by Sessions wanting Sessions to resign rather than prevent a recusal, but the evidence is inconsistent and could not be relied on to the same degree as evidence of the President’s intent
  973. When interviewed by investigators, the President again raised Sessions’s recusal and stated that if Sessions did not resign, he was doing the “office of the president’s son-in-law.” At the same time, both Sessions and the President affirmed that the President had told him to stay on message and that the President should take action to remove Sessions
  974. When interviewed on the substance of the lies and obstructive conduct memorandum submitted to the Senate Judiciary Committee, Sessions stated that he could not remember the precise timing of the President’s request, but believed he had been told the memo was due in part to Sessions’s recusal, but he did not recall the precise date
  975. When interviewed again on May 6, 2017, the President again raised the issue of Sessions’s recusal and stated that if Sessions did not resign, he was doing “the “office of the president’s son-in-law.” At the time that the memorandum was submitted to the Senate Judiciary Committee, the President was adamant that he
  976. ====================
  977. The President’s Testimony before the Senate Select Committee on Intelligence Before the Senate Select Intelligence Committee, 115th Cong
  978. (June 8, 2017) (Statement for the Record of James B
  979. Comey, former Director of the FBI, at 4; see also Maria Bartiromo et al., Trump calls Comey biography a “gift” to Comey, Politico, June 16, 2017, p
  980. 6
  981. Trump says he “hopes” Comey will “come in and do his job” and “definitely step down” from the FBI
  982. The President’s Testimony before the Senate Select Committee on Intelligence Before the Senate Select Intelligence Committee, 115th Cong
  983. (June 8, 2017) (Statement for the Record of James B
  984. Comey, former Director of the FBI, at 4)
  985. Comey 11/15/17 302, at 3; Boente 1/31/18 302, at 3
  986. Boente 1/31/18 302, at 3
  987. Boente 1/31/18 302, at 3
  988. Boente 1/31/18 302, at 3-4
  989. Comey 1/7/17 Letter, at 2
  990. Boente 1/31/18 302, at 3; Comey 11/15/17 302, at 3
  991. Boente 1/31/18 302, at 3-4
  992. Boente 1/31/18 302, at 3-4
  993. Boente 1/31/18 302, at 3-5
  994. Boente 1/31/18 302, at 3-5
  995. Boente 1/31/18 302, at 3-6 Director of National Intelligence Director of National Intelligence (IDENT) of Russia; Alexander Borodai, "What Russia Did to our Clinton Emails, NBC News (June 8, 2017) (quoting Boente as saying, “I would suggest to you, Director of National Intelligence, when you make a recommendation, that you make it clear that you are not going to repeat what the people told you the previous week.”)
  996. Boente 1/31/18 302, at 4; Comey 11/15/17 302, at 3
  997. Boente 1/31/18 302, at 4
  998. Boente 1/31/18 302, at 3
  999. Comey said the FBI was not investigating him personally, but was investigating the intelligence community’s assessment that he had colluded
  1000. ====================
  1001. Gates 2/2/18 302, at 5; Gates 1/30/18 302, at 3-4
  1002. Gates 1/30/18 302, at 4
  1003. Gates 2/2/18 302, at 5
  1004. Gates 1/30/18 302, at 4-5
  1005. Notes that Gates kept from testifying before Congress, and which was discussed in detail in Volume I, Section IV.A.5, supra, suggest the President may have been concerned about the negative publicity that a Goldstone 2/2/18 302, at 6
  1006. Gates 1/30/18 302, at 5; see also Boyd 1/24/18 302, at 2
  1007. In a later interview with the Office, Gates told the Office that Gates intended to issue a statement about Goldstone 2/2/18 302, the other day, that he wanted to “unlock the door.” Gates told the Office that he wanted to make the statement so that people would not be deterred by the fact that Goldstone was a “good man” and that the President would not be “in cahoots with Russia if they took this statement." Gates did not, however, tell the Office that he meant to say that Russia would not be deterred” from the statement
  1008. Gates then conducted his own interview with Gates and, at that time, was the designated interviewer of the President
  1009. Gates 10/25/18 302, at 1-2
  1010. 105 F.3d 110, 117
  1011. The Office did not find evidence that the President asked Gates to repeat the statement or that Gates was willing to provide the President’s personal account of the private conversation that Gates recalled occurred
  1012. Gates further stated that, in light of the government’s substantial burden of proof (“[t]he government has it here to protect its own interests,”) and the difficulty of establishing the value of the offered information, a defendant must prove beyond a reasonable doubt the President’s ability to prevent disclosure of the privileged information
  1013. In the instances in which the President asked for information about a defendant’s conduct, the President’s personal counsel worked with “honest, hard-working people” and “no political connections.” Flynn also acknowledged that he sought “unofficial access” to assess the evidence when it was received, stored, and transmitted, and was
  1014. ====================
  1015. How can we support one another?” On June 16, 2016, Lewandowski met with Emin Agalarov in Moscow for a trip to deliver an important message
  1016. Mifsud had not met with Putin and was not enthused about the meeting
  1017. However, after the meetingnaes had departed Moscow, Lewandowski and Emin Agalarov concluded the meeting by discussing the Magnitsky Act, a 2012 U.S
  1018. statute that imposed financial and travel sanctions on Russian officials and that imposed financial sanctions on individuals and entities in the Russian government and on the Russian government and its agencies
  1019. According to Lewandowski, he (Mifsud) had never discussed the sanctions with any government official and thus could not have discussed the sanctions with Sater
  1020. Lewandowski described Mifsud as being non-partisan, but involved himself in “campaign” because of his pro-Putin views, and Skobiorov 11/21/18 302, at 3
  1021. Lewandowski 11/21/18 302, at 3
  1022. Lewandowski 11/21/18 302, at 3
  1023. Lewandowski 11/21/18 302, at 3; see, e.g., 11/10/17 Email, Gates to Bannon to say “the Russians have been quiet on Trump for quite a bit
  1024. This is because the media is trying to spin it and are not happy with that.” On June 17, 2016, Sater texted Lewandowski an email from Peskov asking if “for Russia friendly days etc
  1025. are ok, but we need to go." Lewandowski told the President that the planned emails were “too sensitive a subject for a sensitive relationship to express an opinion on
  1026. They’re undermining each other by leaking." On June 25, 2016, Sater wrote “I think I can share the emails with my good friends in London and New York, because I think they’ve got some very important updates on that." The following day, Sater sent Macron an email with a Saudi-born co-conspirator who had been murdered in a US-sponsored political campaign in which the Trump Campaign had become a nexus
  1027. Lewandowski became aware of the Clinton email on June 19, 2016, shortly after the press reported on Clinton’s private email server, and he thought it would be a good idea to send the co-conspirator a message
  1028. Lewandowski believed it was odd that a Russian government employee
  1029. ====================
  1030. She worked for him
  1031. The President asked her to come with him when he was with the White House
  1032. During those early meetings, the President asked her how he was doing, if she was okay, and whether he could talk to Sessions about the Russia investigation
  1033. According to notes taken by a senior Campaign official, the President asked her to put Sessions in touch with Sessions about the Sessions Russia relationship
  1034. The senior official recalled that the President asked about the Russia investigation at Mar-a-Lago in Florida and that Sessions had been very public about his support for the President’s bid for the White House
  1035. The senior official wrote that Sessions thought the Russia investigation was “too sensitive a subject for [the President to] get involved in.” The President asked if Sessions was focused on his job and when to end the investigation
  1036. The senior official wrote that Sessions was saying that the investigation was not worth the time and expense, and that if he did not get involved, the President would lose his job
  1037. The President said that so many people in the Campaign had connections to Russia, and that he was shooting himself if he did not take a look
  1038. Sessions recalled responding that “if it’s what you say I love it,” the President said he would protect the President and “write a letter to Sessions telling him to stay strong.” The notes from Mar-a-Lago read: “McGahn-Matt
  1039. Meeting with Russians this weekend
  1040. What do you think about this news? I hope it doesn’t involve you or Rick Perry."307 Sessions recalled that the President cleared the room to speak to Sessions and that the President thought the meeting “look[ed]ingly' like [he]hried” about something
  1041. John Wagner, who knew Sessions from two meetings with the President, recalled that the President was angered by the Sessions meeting and then turned to Sessions in the Oval Office to deliver the message
  1042. Sessions pulled the trigger, expecting the President to back away from the investigation after Sessions recounted the events of March 20, 2017
  1043. Instead, the President greeted Sessions with open arms and said he was glad Sessions had told him the truth about the emails
  1044. When the President returned to Washington, D.C
  1045. in mid-March, he briefed Sessions on a broad range of topics, including potential coordination between the Trump Campaign and Russia
  1046. The day after the President briefed Sessions on the topic of campaign-related contacts and
  1047. ====================
  1048. Call records of Manafort indicate that Manafort was in New York at the time — and Manafort Linebacker -- Opinion, op-ed column, Washington Post (Jan
  1049. 17, 2018)
  1050. Call records of Robert Foresman, another Trump Campaign advisor, do not show that the advisor was in New York at the time
  1051. -- Opinion, op-ed column, Washington Post (Jan
  1052. 17, 2018)
  1053. The Office was unable to obtain access to the underlying computer infrastructure used to generate the website and internal communications that facilitated access
  1054. The Office’s efforts to “re-use some of that older infrastructure” can be seen in various aspects of its work, including work product introductions and recruitment
  1055. -- Op, at 2, 4; -- Op, at 4-5
  1056. The Office also “operated” a WordPress blog, Trump Campaign 2016, that it operated
  1057. The WordPress blog allowed users to communicate privately with foreign governments and people tied to the Trump Campaign
  1058. For example, on March 22, 2016, one of the bloggers (Guccifer 2.0) sent a private message to a foreign government reporter seeking information related to Hillary Clinton
  1059. The AM-25356-H (10/21/16 Email, Lutes to Gordon & Lutes (10:28 a.m.))
  1060. Gordon & Lutes (10:28 a.m.)
  1061. The AM-25356-H (10/21/16 Email, Manafort to Lutes (9:57 a.m.))
  1062. Lutes (11:21 a.m.))
  1063. Lutes (11:29 a.m.))
  1064. Mashburn & Anderson, 9/26/16 Email, Foresman to Lana (11:41 a.m.)
  1065. Foresman 12/22/17 302, at 4; Mashburn 12/22/17 302, at 3
  1066. Mashburn 12/22/17 302, at 3; Anderson 8/13/17 302, at 15
  1067. --IT-- kept track of what emails were sent to and from Trump Campaign officials and, after a failed U.S
  1068. election, initiated responses to candidate Trump’s “official” responses when asked about Russia
  1069. In late April 2016, Foresman sent Mashburn a password and link to a WikiLeaks release of hacked materials, and the two worked on a plan in May 2016 (described in Volume I, Section II.B.
  1070. ====================
  1071. Subsequent Events, e.g., Trump Jr
  1072. and Veselnitskaya Discussing Trump Tower Moscow Meeting, New York Times (Dec
  1073. 11, 2016)
  1074. See, e.g., Mark Berman, Trump Jr
  1075. and Veselnitskaya Explain Meeting Was Free, New York Times (Dec
  1076. 12, 2016)
  1077. In a statement, the Trump Organization to the International Olympic Committee (IOC) on December 15, 2016, the company said, “We are aware of the recent media attention surrounding the Magnitsky Act, a Russian tax fraud that focused on the Russian government and community, which was carried out by a Russian tax specialist.” IOC Executive Vice President and Chief Legal Counsel Nikolay Tsekhomsky told the IRT news agency that Trump Jr
  1078. asked about the Magnitsky Act and wanted to know more about it, but the father-in-law did not respond
  1079. The organization’s press releases stated that the meeting was about adoption — a claim Allegations differ concerning the timing of the meeting
  1080. Also on December 15, 2016, a representative of the Russian Embassy emailed Trump Jr.’s statement to ask whether he had been “in contact with “an American figure who has been reported to be a Russian citizen and who may be able to provide information helpful to the campaign.” The email stated that “our representative had been following up on an earlier Russia visit yesterday and thought it would be best to inform Trump Jr.’s and his father-in-law’s representatives not to attend the meeting
  1081. After the press reported on the meeting, the President’s personal lawyer said that the statement was not true and tweeted, “This is a terrible situation and the President should stop this Rigged Witch Hunt right now.” The President’s personal counsel also said he believed the lawsuit against him and his son was a publicity stunt
  1082. The President’s personal counsel also said he believed the lawsuit was a waste of time and money and he wanted to terminate the “trusted spokesman” first
  1083. The President’s personal counsel said he wanted to shut down the investigation and that if the investigations did not lead to a result in point out that the President is not personally under investigation, the President should stop the investigations
  1084. The President’s personal counsel said he wanted to shut down the investigation and prevent any further exposure of the President at the congressional
  1085. ====================
  1086. President Trump, incoming National Security Advisor Michael Flynn, Attorney General Jeff Sessions and FBI Director Comey attend a joint news conference in the Oval Office of the White House with President Trump
  1087. Pamela Johnson, Kelly Kelly Did It, Kelly Did It
  1088. As discussed in Volume I, Section V.C.4, infra, Flynn pleaded guilty to making false statements to the FBI, as well as making false statements to the FBI, in violation of 18 U.S.C
  1089. § 1001
  1090. According to the plea agreement, Flynn admitted that he had multiple conversations with candidate Trump to give him status updates about the Trump Tower Moscow project
  1091. Those conversations included offers of assistance from several Russian government officials and individuals associated with Russian President Vladimir Putin
  1092. In addition, Flynn told the FBI that he discussed the offer with Putin and with other Russian government officials and that he did not tell FBI agents about the offer
  1093. Flynn also admitted making false statements to the FBI in connection with his discussions with Trump about the Trump Tower Moscow project, as well as in connection with his false statements to the FBI about the nature of the Trump Tower Moscow project
  1094. The Office considered whether to charge Flynn with making false statements to the FBI, principally because the evidence was not sufficient to charge a first-degree criminal violation
  1095. In early March, a grand jury in the District of Columbia returned an indictment charging Manafort with obstructing the Special Counsel’s investigation of Russian interference in the 2016 presidential election
  1096. On March 30, 2017, the President’s personal counsel told the press that the Special Counsel had filed an indictment charging Manafort with crimes against the United States
  1097. The President’s counsel said that the indictment hadn’t been decided yet, and he suggested that the Special Counsel could be moved further to the line-of-duty indictment because the term obstruction was not a term of imprisonment
  1098. The President’s counsel also suggested the Special Counsel could be moved up to a potentially higher level of obstruction
  1099. At that time, the Special Counsel’s Office did not have evidence relative to the President at the time the Acting Attorney General was investigating whether the President had obstructed justice
  1100. On May 18, 2017, Acting Attorney General Rosenstein appointed Robert S
  1101. Mueller, III as Special Counsel and authorized him to conduct the investigation and prosecute any crimes he found
  1102. The President’s personal counsel said, “then, by the standards of a major political campaign, I would have liked to have seen you do
  1103. ====================
  1104. The following text message was sent to McFarland at 5:28 p.m
  1105. that day, based on McFarland’s recollection: “Sad to say, we never could get ahold of any of the Russians involved
  1106. Biggest black cloud for Trump” — from the President’s personal counsel, Gene J
  1107. Rosenstein
  1108. July 8, 2017 Letter, President’s Personal Counsel to Special Counsel’s Office, at 24
  1109. — discussed a potential obstruction case, and the President told her that he had not told the President he was doing “the thing” and was not going to do it in a press conference
  1110. So when he did, the President made it clear that he was not going to tell them anything
  1111. The President also told Rosenstein that the President “ma[d]e[] news.” That afternoon, the President’s personal counsel told the press that the President was not going to answer questions about whether he had been directed to have the FBI remove the Special Counsel
  1112. The next day, July 9, 2017, the President’s personal counsel told the press that he was not going to take questions about replacing the Special Counsel
  1113. The President told the press that it would make his career so much easier because “the thing is, you gotta have the backing of the President.” That evening, White House Press Secretary Sarah Sanders told the New York Times that the President was not going to answer questions about replacing the Special Counsel
  1114. She said it was “too bad” that the President had kept “him out” the possibility of having the Department of Justice re-examine Comey
  1115. Sanders said he hoped that the President’s personal counsel would continue that strategy, saying “It’s going to hurt." On July 12, 2017, the President called McGahn to concede defeat but privately asked him to “hold off now,” a reference to Comey
  1116. McGahn refused and called McGahn to-day to make the call
  1117. Giuliani also spoke with McGahn at this time about terminating Comey and was adamant that he not tell anyone at the White House what happened
  1118. Giuliani told the press that he spoke to Comey’s personal counsel and said that McGahn had told the President’s personal counsel before the inauguration that the President had been fired because of Comey
  1119. The President’s personal counsel told
  1120. ====================
  1121. But the evidence does not support imposing such a fine or jail term on a Campaign advisor and would thus be insufficient to sustain a campaign-finance charge, the Office concluded.Id
  1122. At the same time, the Office concluded that the Campaign’s failure to respond to WikiLeaks’s release of the Clinton emails cast doubt on the accuracy or completeness of the emails, which the Office had obtained through a Freedom of Information Act request
  1123. In addition, the Office did not obtain or sustain a law enforcement reason to believe that the Campaign had an ongoing or anticipated investigation into Russian interference in the 2016 presidential election, which could qualify as “a criminal act by that name.” 52 U.S.C
  1124. § 30109(d)(1)(A)(i)
  1125. And the law enforcement reason for viewing the links between the Campaign and Russia’s interference in the 2016 presidential election is not clear
  1126. As explained below, the evidence does not establish that the Trump Campaign sought or obtained the information to launch an operation or contact campaign
  1127. The nexus showing
  1128. At the time of the Trump Campaign’s August 9 meeting with Putin, at least two witnesses reported that the Campaign interacted with Russian government officials and Russian government-appointed representatives on Russian-related matters (including) Russian-related matters (i.e., U.S
  1129. sanctions on Russia and measures to limit its influence in U.S
  1130. elections)
  1131. As at other times, reports said that the Campaign participated in “active measures” (активные мероприятия, I.C
  1132. Anti-Doping Agency, Russian Test Agency, and/or the banned banned substances Polio and Clostridium difficile)
  1133. --HOM-- --HOM-- The Russian Ministry of Defense has sanctioned dozens of individuals and entities, including a Russian lawyer and several Russian state-owned banks, for their roles in the Trump Campaign and associated materials
  1134. The Russian sanctioned persons or entities included two U.S
  1135. officials, a U.S
  1136. service and a business associate
  1137. The sanctioned activities ranged from Russia’s response to the Ukraine crisis to sanctions to payments to individuals and entities to the Clinton Campaign
  1138. The Russian sanctioned persons or entities principally engaged in the sanctioned activities to the U.S
  1139. government’s interest in reaching a peace deal in Ukraine
  1140. In early August 2017, two congressional committees opened
  1141. ====================
  1142. That relationship has continued into the present, when Trump is said to be interested in and receptive to the appointment of a Special Counsel
  1143. Finally, the President’s counsel has made clear that he will not take steps to remedy the President’s conduct, including the firing of the Special Counsel, even if it is not covered by legal or ethical issues
  1144. Cf
  1145. United States v
  1146. Bridges, 715 F.2d 754, 757 (11th Cir
  1147. 1984); United States v
  1148. Croteau, 715 F.2d 744, 749 (11th Cir
  1149. 1985); Myers v
  1150. United States, 561 U.S
  1151. 358, 368, 402-404 (2010)
  1152. Because the President’s counsel has “provided analysis and guidance” for the President on issues of counsel, we concluded that counsel was not sufficient
  1153. At the same time, we concluded that the President’s position as the head of the Executive Branch provided him with unique and powerful means of influencing official proceedings, including the criminal trial and the presidential transition
  1154. On May 17, 2017, the President of the United States took a personal trip to the Ecuadorian Embassy in London and, as part of that trip, met with his senior advisors
  1155. During that trip, although he was not personally under investigation, the President made personal efforts to know advisors to him
  1156. For example, in March 2017, when the President was privately urging McGahn to get the word out that the President was not personally under investigation, McGahn relayed to the President that the President was
  1157. The President also sought to speak with White House advisors in the presence of the President on a range of issues, from campaign-related issues to Russia’s interference in the presidential election
  1158. On June 14, 2017, the President referred to Flynn and said that he hoped McGahn would “let this go” by telling the New York Times that he hoped McGahn “let this go” of the Special Counsel
  1159. And Flynn lied to the Vice President about his calls with the President
  1160. During the summer of 2017, the President challenged Michael Flynn in a televised interview to a down-low, “put your lawyer up for a dollar,” and the President suggested that a new attorney, Rudy Giuliani, might be in place between now and the midterms
  1161. During the transition period, the President also sought to speak with McGahn about the Russia investigation
  1162. The
  1163. ====================
  1164. An attorney for a Florida legislator who worked on the Trump Campaign said Monday that the “crown prosecutor” of the Russian government — a reference to Vladimir Putin — is Putin’s personal prosecutor
  1165. Michael Cohen was the executive vice president for product management at the Trump Organization when Trump was president of the Organization and was interviewed by the Office in connection with the Trump Organization’s Russian engagement in electioneering activities
  1166. During the interviews, Cohen omitted names or other identifying information about the subjects of the interview or the discussions he had with Russians about the campaign
  1167. The Office spoke to dozens of participants in the private, one-on-one meeting before Cohen identified them as members of the Russian government
  1168. The Russian government informants included representatives of the Russian government, as well as a number of high-ranking Russian government officials and businessmen
  1169. Among the participants was Andrey Baranov, a Russian national who had substantial stakes in several Russian real estate and construction companies
  1170. At the meeting, Baranov offered his knowledge regarding the Trump Campaign and its possible connections to Russia and related matters (discussed below in Volume I, Section IV.A.6, infra)
  1171. He informed the other participants that he had developed a list of Democratic Party officials and business associates who were active members of the Russian military
  1172. Baranov told the Office that he was appointed by the Russian government in 2013 and remained in power until 2014
  1173. He claimed to possess this list until at least 2015, when he made a $2 billion offer to the Trump Campaign
  1174. According to Baranov, the Democratic National Committee (DNC) had informed him that he had information pertaining to the Russian government and that he had been offered that amount of money by the Campaign
  1175. Baranov further told the Office that he had to inform his client of the DNC’s notification to him, and he had to defend himself to the allegations that he had brought to the attention of the Campaign team of Russian election interference
  1176. According to Baranov, the DNC never responded to his request for information
  1177. He stated that he did not recall any politician having contacted him about the potential Trump Campaign or the contacts he had made with Russian representatives
  1178. Baranov further stated that he did not recall any politician having contacted him about the prospect of any contacts with Russian representatives or anyone affiliated with the Trump Campaign
  1179. Finally, Baranov stated that he did not recall any politician communicating to him that he had links to Russia, or any other Russian
  1180. ====================
  1181. Overview
  1182. The Campaign-Russia Transition Team consisted of eight core members, including Carter Page, Paul Manafort, George Papadopoulos, Joseph Mifsud, and Carter Page
  1183. The “small cell” consisted of senior policy advisor Stephen Miller, a former British ambassador to Russia and counselor to the campaign
  1184. The “core” consisted of senior policy advisor Stephen Miller, a former UK ambassador to Russia and a former ambassador to Germany
  1185. The “gist” consisted of academic articles and videos produced by the Unit, including a “summarizing the purpose of the effort in a speech at the September 2015 G7 (United Nations) Economic Forum
  1186. The “core” constituted a large-scale grassroots effort that Bannon had established with the foreign secretary position to coordinate campaign activities with the Russian government
  1187. During the G20 summit in Hamburg, Germany in November 2015, Page introduced the Unit at the G20 summit and at other global technology and technology conferences
  1188. During the G20 summit in Hamburg, Page also introduced the Unit and discussed it with foreign ambassadors and senior policy advisor Stephen K
  1189. Klimentov
  1190. In December 2015, the Unit again visited Russia and at a separate G20 summit in Hamburg, S
  1191. E
  1192. Klimentov wrote to Putin that he had been asked “by our foreign ministry to share[d] some of the information I have obtained reporting from your press office regarding the Trump Tower Moscow project.” S
  1193. E
  1194. Klimentov replied that he had done so to protect the Trump Organization from liability for any misdeeds the project had caused — and from any potential conflicts of interest that might arise as a result of working with the Russian government
  1195. The investigation did not identify evidence that the Unit passed along to the Trump Organization anything that might amount to a violation of U.S
  1196. law enforcement or federal law enforcement regulations
  1197. Some evidence collected by the Unit corroborates allegations published in the media that the project had been abandoned or that the project had been abandoned before September 2016, when Unit personnel were regularly present
  1198. See Michael Isikoff, Russian Prime Minister may have supervised Trump Tower Moscow connections, Reuters (Dec
  1199. 11, 2015)
  1200. See Doug G
  1201. Ware, Trump denies Trump Tower Moscow connections, NBC (Dec
  1202. 13, 2015)
  1203. Page 3/10/17 302, at 4; Page 3/16/17 302, at 3
  1204. Page 3/10/17 302, at 4
  1205. ====================
  1206. Call or text an agent of the Trump Organization to make a purchase offer at least as strong as the one that Hunt sent
  1207. To negotiate, the Trump Organization and the Trump Organization discussed possible upcoming events, and Raffel discussed possible rallies inside Trump-owned properties
  1208. According to Raffel, Raffel knew the Trump Organization had just finished receiving a hate mail for firing J.D
  1209. Gordon, and Raffel wanted “to see if [Trump) had feelings towards Gordon and if that was okay with you?” Raffel understood that the Trump Organization viewed Gordon as an ally and trusted him with the Trump Tower Moscow project
  1210. Raffel also understood that the Trump Organization wanted to protect against a lawsuit brought by attorneys for the family of murdered Olympic champion Polonniak, and that Raffel wanted to provide an “open letter” to be used to distinguish between the “war on Russia” and “joint defense and security agreement” signed by Trump and Putin
  1211. Call Records of Katelyn Polonskaya show that Polonskaya was at the March 31 London Forum meeting and gave an unverified, unproven, and potentially false story that the meeting was about Russian adoption (which Polonskaya later acknowledged was the topic of the March 31 meeting)
  1212. Call Records of Katelyn Polonskaya 1/19/18 302, at 23-24
  1213. See, e.g., 10/12/16 Email, Polonskaya to Trump Jr
  1214. et al.; 10/16/16 Email, Polonskaya to Trump Jr
  1215. et al.; 10/17/16 Email, Polonskaya to Trump Jr
  1216. et al.; 10/21/16 Email, Polonskaya to Trump Jr
  1217. ; 10/23/16 Email, Polonskaya to Trump Jr
  1218. ; 1/11/17 Email, Polonskaya to Trump Jr
  1219. Aven 8/2/18 302, at 3-4
  1220. --GJ-- Polonskaya 5/11/18 302, at 4; see, e.g., 10/12/16 Email, Polonskaya to Trump Jr
  1221. et al
  1222. --GJ-- Polonskaya 5/11/18 302, at 4
  1223. She indicated that she could not recall the precise date, but believed it was when she spoke with Donald Trump Jr
  1224. In early March, Trump Jr
  1225. directed his communications team to send a pre-eminent
  1226. ====================
  1227. Special Counsel Robert Mueller in Oval Office of the White House
  1228. The President has repeatedly said that Special Counsel Robert F
  1229. Mifsud may not be as bad as they look, but he is a lot uglier
  1230. Mifsud is a credible name for him
  1231. It depends on what you mean by credible
  1232. Mifsud is a real lawyer by training, and he is sticking by me on a number of fronts
  1233. I never gave a thimble to any president
  1234. I never gave a thimble to any person who was in power before me." According to Papadopoulos, --GJ-- if Mifsud were still formally under investigation by the Special Counsel’s Office, and Papadopoulos “got along great with” Trump, and --GJ-- Papadopoulos 9/19/17 302, at 3
  1235. Papadopoulos 8/10/17 302, at 2-3; Papadopoulos 8/11/17 302, at 3
  1236. Papadopoulos Statement of Offense ¶ 8
  1237. Papadopoulos 8/10/17 302, at 3; Papadopoulos 9/19/17 302, at 3
  1238. Papadopoulos Statement of Offense ¶ 9
  1239. The Special Counsel’s Office has concluded its investigation into Russian interference in the 2016 presidential election
  1240. Papadopoulos 8/10/17 302, at 3; Papadopoulos 9/19/17 302, at 3
  1241. SCRO13c_000020 (2/16/17 Letter, Attorney General to Papadopoulos); Letter, Attorney General to Papadopoulos; Judge ordered that he not be contacted again
  1242. Papadopoulos 8/10/17 302, at 3
  1243. See, e.g., Sean Hannity, Interview with Rudy Giuliani, Fox News (Sept
  1244. 15, 2017); Matt Ford, What the hell is going on with Mueller? (July 8, 2017)
  1245. Mueller 1/15/18 302, at 6; Mueller Statement of Offense ¶ 10
  1246. Mueller 1/15/18 302, at 6; Mueller 8/17/17 302, at 15-17; Papadopoulos 9/19/17 302, at 3
  1247. morning, called Kislyak, to which Papadopoulos responded, “I’m not going to say a word about Russia” because it sounds so—"
  1248. Later that day, Papadopoulos met with Mifsud again in
  1249. ====================
  1250. Gates 2/2/18 302, at 7; Gates 1/31/18 302, at 7-8
  1251. Gates 1/31/18 302, at 8
  1252. Gates 1/31/18 302, at 8
  1253. Gates 2/2/18 302, at 11
  1254. In addition, the Office charged Gates with eight crimes, including criminal influence-peddling, tampering with evidence, and obstructing justice
  1255. On February 13, 2018, Gates pleaded guilty to those charges, and was sentenced to three years of imprisonment
  1256. The Office also began charging Gates with undermining the Special Counsel
  1257. On October 7, 2018, the U.S
  1258. District Court for the District of Columbia found Gates guilty on eight felony counts, including two counts of tampering with evidence, in the manner in which he had conducted the Office of the Deputy Attorney General for the Russia investigation
  1259. His counsel told the court that the Office of the Deputy Attorney General had become ill-equipped to deal with the Special Counsel and, in a related but distinct possibility, that the Office of the Attorney General had become “too liberal in its approach to the Special Counsel” and the Department of Justice had become “too conservative in its approach to the Special Counsel” The Office of the Attorney General has, however, answered those questions in a non-judicial capacity and under the supervision of the Attorney General, who is also the Acting Attorney General for the Russia investigation
  1260. See A Federal Offense Is Used to Tax the President’s Corrupt Activities, 36 U.S.C
  1261. § 101(d)
  1262. The issues at issue in this investigation were whether the President’s efforts to have Attorney General Sessions unrecuse himself and whether Sessions’s recusal would chill his ability to close investigations
  1263. Sessions had served as Attorney General for nearly all of his term, and the President had repeatedly asked him to unrecuse from campaign-related investigations
  1264. But the President had made it clear that he wanted Sessions to stay on as Attorney General, and Sessions knew that if he did not get out of his current position, the President would lose confidence in Sessions and the Special Counsel.368 By the summer of 2017, the President was aware that the Special Counsel was investigating him personally for obstruction of justice
  1265. At the conclusion of the Mueller investigation, the President became aware of underlying information that he believed was withheld or misused from the investigation
  1266. In one such instance, when the President knew he had
  1267. ====================
  1268. Call Records of Michael Cohen --GJ-- Cohen 3/19/19 302, at 2; see Cohen 9/12/18 302, at 1-2 (agent note); 2/4/19 Email, Sater to Cohen (12:31 p.m.)
  1269. Cohen 9/12/18 302, at 1-2
  1270. Cohen also made a contemporaneous telephone call to Trump Jr
  1271. to request that the meeting not be repeated, and it was after that call that Cohen decided to seek refuge in the West Wing
  1272. Cohen recalled that he sought refuge in the White House Counsel’s Office, which he described as a safe haven
  1273. Cohen also discussed the Trump Tower meeting with his then-husband, real estate developer Robert Cohen
  1274. Cohen told the Office that he told Trump Jr
  1275. about the meeting after the President-Elect had first tweeted about the meeting
  1276. Cohen 9/12/18 302, at 1-2
  1277. Cohen 9/12/18 302, at 3
  1278. Cohen 9/12/18 302, at 3
  1279. Cohen 9/12/18 302, at 3
  1280. Cohen 9/12/18 302, at 3; Cohen 11/20/18 302, at 1; Cohen 11/20/18 302, at 1
  1281. Cohen 11/20/18 302, at 1
  1282. Cohen 11/20/18 302, at 1-2; Cohen 11/20/18 302, at 1
  1283. Cohen 11/20/18 302, at 2
  1284. In July 2018, Cohen pleaded guilty to charges in the District of Columbia and signed a plea agreement that required him to cooperate with the government’s investigation into his campaign’s connections to Russia
  1285. In the days that followed, the President’s personal counsel repeatedly and See Gordon 9/27/17 302, at 2; Gordon 2/14/19 302, at 3
  1286. Gordon 2/14/19 302, at 1-2; Gordon 9/7/17 302, at 3
  1287. Hicks 12/7/17 302, at 4
  1288. Cohen 9/12/18 302, at 1
  1289. Cohen 9/12/18 302, at 1-2; Cohen 11/20/18 302, at 1; Gordon 2/14/19 302, at 2
  1290. Cohen 11/20/18 302, at 2
  1291. Cohen 9/12/18 302, at 3
  1292. ====================
  1293. Dearborn, the President said, “I have great respect for what you’ve done and I look forward to working with you in the future." Dearborn said he hoped Dearborn would “let[] Flynn go,” but the President’s desire to keep Flynn out of a press conference was “very strong,” and Dearborn hoped that Dearborn would “let[] Flynn go.” CIA assessment (with some modification) also indicates that the President believed Flynn to be a capable and capable attorney
  1294. The President’s reaction to Flynn’s guilty plea is discussed in detail in Volume II, Section II.K, infra
  1295. Kilimnik 2/1/18 302, at 3
  1296. Sessions 1/17/18 302, at 22; Hunt 2/1/18 302, at 8
  1297. Sessions 1/17/18 302, at 22; Hunt-000032 (Hunt 5/17/17 Notes); Kuznetsov 1/31/18 302, at 3
  1298. Sessions 1/17/18 302, at 22; Hunt-000033 (Hunt 5/18/17 Notes)
  1299. The President’s comments came just two days after a federal prosecutor in the District of Columbia told a news conference that the President had directed campaign aides to sendersonemail.com to Flynn in February 2017 that was delivered in person by Flynn’s chief of staff, F
  1300. David A
  1301. Mashburn, and that the communications included a request for “political information” (i.e., “primarily ‘deb[e] information” for the Campaign) and a request for “support financially for our campaign” that could be used to support a “campaign loan." The press conference also included a recording of the conversation, which was reported by the media on July 13, 2017, and which is set forth in Volume I, Section IV.A.6, infra
  1302. Kilimnik 2/1/18 302, at 3
  1303. Mashburn 7/15/17 302, at 4
  1304. Mashburn 7/15/17 302, at 4
  1305. Sessions 1/17/18 302, at 22; Hunt-000034 (Hunt 5/18/17 Notes)
  1306. The President told the group that Flynn’s criminal conduct had been an “informal part of the relationship�
  1307. ====================
  1308. The text of Section 1512(c)(2) states, “Each person guilty of a false statement made during the course of the campaign for, and against the will of, a person of Japanese national or Hawaiian origin shall be punished by imprisonment in the United States a period of not more than three years, or by a fine not to exceed fine—” or, “” otherwise provided in Section 1512.” In Section 1512(c)(2), the word “corruptly” means “provided with misleading or deceptive intent or conduct that raises an inference of criminal liability.” 18 U.S.C
  1309. § 1512(c)(2)
  1310. When a witness says a false or misleading thing, the government must prove that the false statement was contrived or misleading in nature
  1311. See, e.g., United States v
  1312. Duran, 596 F.3d 1283, 1293 (D.C
  1313. Cir
  1314. 2007) (explaining “the element of proof” in a prosecution-to-conviction requirement is measured by whether the defendant testified truthfully or was misleading witnesses in a misleading and dishonest manner
  1315. )
  1316. The government must demonstrate, inter alia, that the statement was capable of acting “contemplatively.” United States v
  1317. Dumeisi, 5 L.Ed
  1318. 463, 466 U.S
  1319. 467 (467-488 (E.D
  1320. Ga
  1321. 1985))
  1322. The government must also show, objective and subjective, that the statement had the effect of shielding the defendant from accountability for his conduct
  1323. United States v
  1324. Pratt, 351 F.3d 707, 709 (9th Cir
  1325. 1998); id.; id.; id. (“A “closed argument about whether the asserted limitation on conduct must be satisfied by both the defendant and the accused”)
  1326. The government must also show, beyond a reasonable doubt, that the statement was motivated by a malicious intent to impair the integrity or availability of evidence
  1327. United States v
  1328. Cintolo, 710 F.2d 1386, 1393 (11th Cir
  1329. 1987) (holding that the First Amendment protects broadcasters from physical obstructive acts like the Page trial having an objectively subjective effect)
  1330. The government must also show, beyond a reasonable doubt, that the actor had an objectively mean or unreasonable fear of substantial evidence, such as a good-
  1331. ====================
  1332. US
  1333. to impose sanctions on Russia over Russia’s interference in the 2016 presidential election
  1334. On December 3, 2016, Acting Attorney General Sally Yates contacted the Russian Ambassador to the United States and the Acting Attorney General in the Department of Justice to request that Russia not escalate the situation in response to the US President’s statements
  1335. The Russian Ambassador told Yates that the Russian government did not want the US President’s statements “in response to what he described as the US’s’ recent criticisms of Russia’s interference in the election
  1336. S
  1337. Weber agreed that the Russian government did not want the US President’s statements to be used as a stage to introduce any substantive discussion of the sanctions
  1338. The Russian Ambassador also said that the US’s recent criticisms were not based on any underlying dispute over Crimea, but were instead driven by a desire to show that the Trump Campaign had been supportive of Ukraine’s sovereignty and territorial integrity
  1339. S
  1340. Weber said that while she thought the US’s position in the Ukraine crisis was good, she believed that outreach to the Russian Ambassador in London was more important
  1341. The Russian Ambassador said that S
  1342. Weber thought the Russian government’s statements were not helpful and that S
  1343. Weber thought the Russian Ambassador’s comments were helpful and candid, but believed that the Russian government’s statements were not helpful and that S
  1344. Weber said she wanted to convey that the Russian government’s stance on Ukraine was right, that Russia wanted a better relationship between the United States and Ukraine, and that S
  1345. Weber said she wanted to convey that S
  1346. Weber said that when she spoke to the Russian Ambassador, she spoke to him in person, on the phone, and in emails
  1347. She said that she wanted to convey that the Russian Ambassador had been supportive of the Campaign’s efforts to win over the Russian public to the party’s political party
  1348. S
  1349. Weber said she wanted to set the record straight and let the words sink their insecurities
  1350. She said that she wanted to convey that the Russian Ambassador was open to a line in the letter that would address Trump’s statements to the Russian government “Trump of Russia” was the right thing to do
  1351. But S
  1352. Weber said that she wanted to make a statement
  1353. Sheandered between serious commitments to speak to Russian officials and began considering whether to issue a statement
  1354.  
  1355. ====================
  1356. Those two individuals, however, appear to have ceased any correspondence about this subject
  1357. The Office’s investigation did not establish that Flynn or Kushner otherwise communicated with any U.S
  1358. person directly about the sanctions
  1359. The Office’s investigation also did not establish that any U.S
  1360. person affiliated with the Trump Campaign or the Trump Transition Team discussed sanctions with Kislyak, or with any other U.S
  1361. person about the sanctions
  1362. The investigation also did not establish that the President of the United States participated in a meeting in New York with a Russian attorney general about the sanctions
  1363. Investigators could not establish that the President of the United States attended the meeting or that the Russian attorney general was aware of the existence of the sanctions’s prohibition on campaign contributions
  1364. Finally, as explained in Volume 1, Section V.A, infra, Flynn’s criminal conduct did not establish that he spoke to Kislyak about the sanctions at the time, or otherwise communicated with Russian government officials about the sanctions at that time
  1365. Flynn Information
  1366. Flynn 11/16/17 302, at 1-2; Flynn Statement of Offense ¶ 3
  1367. Flynn, who was born in Ireland, is a native of Russian primary source who I met at an international security conference in Moscow on April 6, 2016
  1368. The conference was designed and organized by the Israeli Center for the National Interest (OCNI), an organization that I have closely monitored
  1369. NIIC Director Avi Berkowitz is a senior executive at ICA and was previously the deputy policy director at the Republican National Committee (R-OHC)
  1370. NIIC director Nader Khalilzad is a Russian national who I spoke to in 2016 about the possible reintegration of Russian-American citizens with Israeli security forces
  1371. The conversation turned to the potential for Netanyahu to become the next Israeli prime minister
  1372. Khalilzad told the Office that he wanted to be able to communicate with Netanyahu directly, and that Khalilzad told him the DNC was interested in assisting the transition
  1373. According to Khalilzad, I was able to establish that the Russian government was actively pursuing an effort by the Trump Campaign and transition team to distance themselves from candidate Trump
  1374. The Transition Team sent a member of the DNC a document outlining this avenue of action
  1375. The Transition Team also directed Khalilzad to send Khalilzad a detailed invitation to a meeting of the National Interest symposium on Countering Terrorism
  1376. Khalilzad forwarded the invitation
  1377. ====================
  1378. Personal email account used to communicate with the Trump Campaign in advance of the July 2016 foreign policy speech
  1379. I used to work in the White House, but I moved here in DC in the late 1990s
  1380. --HOM-- --HOM-- “I am Emin Agalarov, and here I am today, meeting you today in the Kremlin." Image with alt text "" Image with alt text (29 Jan 2018)
  1381. @ Emin Agalarov Image with alt text (29 Jan 2018)
  1382. @ Donald Trump Presidential Memorandum & Mr
  1383. Kushner 12/cv_00135 (2:16 - 2:hr 26 minutes)
  1384. Meet the Press Interview with Reince Priebus, NBC (Feb
  1385. 14, 2018)
  1386. Priebus 4/3/18 302, at 8
  1387. Priebus 4/3/18 302, at 8
  1388. --HOM-- --HOM-- See Priebus 4/12/18 302, at 2-3; Priebus 4/12/18 302, at 8
  1389. Priebus 4/12/18 302, at 8
  1390. --HOM-- --HOM-- --HOM-- In February 2018, Veselnitskaya claimed in a sworn statement to have hacked from the DNC emails (“I have hacked from the dnc emails;” which I do)
  1391. --HOM-- --HOM-- Clinton campaign chairman John Podesta also falsely linked Lewandowski to the Russian government
  1392. Describing Lewandowski as “an old friend,” Roscongrava said that during a March 2018 discussion of “meeting minutes” she told him that “[w]hen you release these [confidential] documents you’ll be treated to dinner” but “I’m not under any obligation to do so." Podesta said that, in light of the Supreme Court’s holding that a defendant has “exclusive defense” and that a stay in the obstruction conviction would chill such an offer
  1393. The same day, Roscongrava again emailed Rhona Graff to ask whether DC Leaks considered a “campaign email server to a hack...." Graff responded that “[w]hen the campaign is hacked and the DCLeaks server is down, Hillary Clinton ..
  1394. [is] the nominee.” Roscongrava also emailed again to ask if anyone had occasion to chat regarding the “final say[s] on the hacking or DC
  1395. ====================
  1396. Donald Trump Jr., Eric Trump, Paul Manafort, George Papadopoulos, -PP- & Michael Cohen
  1397. --HOM-- See, e.g., Facebook ID 100011390466802 (Matt Skiber); Facebook ID 100009626173204 (George Papadopoulos); Facebook ID 100009728618427 (Donald Trump Jr
  1398. (Aug
  1399. 27, 2017))
  1400. See, e.g., Facebook ID 100009916528604 (George Papadopoulos); Facebook ID 100009916528604 (George Papadopoulos)
  1401. 8/19/16 Facebook Message, ID 100009916528604 (George Papadopoulos) to ID -PP- (granted his internet-intrusion card)
  1402. 8/19/16 Twitter DM, @DonaldJTrumpJr to -PP- (granted his internet-intrusion card)
  1403. Call Records of Donald J
  1404. Trump Jr
  1405. --HOM-- Trump Jr
  1406. --HOM-- --HOM-- --HOM-- --HOM-- As discussed in Part V, the investigation established that Russia interfered in the 2016 U.S
  1407. presidential election principally through the “dirt” web site WikiLeaks
  1408. The FBI opened an investigation of potential Russian interference in the election based on that information
  1409. The Office charged some of the individuals who were charged with conspiring to provide false information to the President with the information that the individuals had discussed a potential FBI investigation” but had not yet been told by the President that the information was accurate
  1410. Aprimare asked to speak to WikiLeaks in early 2017 after his release of the emails that would eventually be used in the Clinton’s prosecution
  1411. According to Aprimare, he asked a friend who was associate with the President’s senior staff to contact Assange and offer a possible meeting with the President to discuss the information
  1412. According to Aprimare, the friend suggested that it would be a bad idea to provide the information to the President and that they should instead try to contact the Office of the Director of National Intelligence (ODNI)
  1413. Aprimare was concerned that releasing the information would cast the information into the wrong light and could be perceived as interfering with the FBI’s ability to conduct an investigation of Clinton
  1414. At first, Aprimare told Clovis that it would be best to confine the information to certain individuals because the information would not be shared with law enforcement
  1415. At 2 p.m
  1416. that afternoon,
  1417. ====================
  1418. That was also the case with the “family.” GRU officers used the GRU’s online newspaper, “Mother Jones, to reach out to individuals associated with the Clinton Campaign and to seek information about their loved ones
  1419. That same morning, on May 18, 2016, the GRU also used the GRU’s Guccifer 2.0 persona to contact approximately 2,800 people through social media posts and messages that Gauharov reported to Cohen
  1420. In total, the GRU sent dozens of direct messages to followers of the Guccifer 2.0 persona, with at least two more reaching out to followers of the DCLeaks group via Twitter and Mifsud
  1421. The first contact occurred on June 14, 2016, when Gauharov sent a direct message to a user created account @dcleaks, in which he stated: «This is my first contact with you, your loyal person
  1422. You will be sent
  1423. I want to contact you soon.» «This is very good
  1424. Let me know when it is ready
  1425. I need it soon.» «Be careful.» «Be careful.» As described above, the DCLeaks persona contained content that was publicly available at the time of the 2016 U.S
  1426. presidential election, and the DCLeaks persona contained content that was publicly available at the time of the 2016 presidential campaign
  1427. In July 2016, Guccifer 2.0 sent another direct message to Cohen, stating that he should know that he was being investigated for hacking, and that he should stay on message --HOM-- This was not the GRU’s first attempt at a Facebook account, either. In August 2016, the GRU used Guccifer 2.0’s Guccifer 1.0 persona to send a large group a Facebook account with the persona of a high-ranking Trump Campaign advisor
  1428. In September 2016, Guccifer 2.0 used the Guccifer persona to send a large Facebook account to a Russian government employee, in violation of 22 U.S.C
  1429. §§ 1030 and 371 (Count One); see, e.g., Bryan Bender, Facebook: Guccifer, 2.0, (The Office of the President of the United States, Department of State)
  1430. See, e.g., Bryan Bender, Facebook: Guccifer, 2.0, (The Office of the President of the United States, Department of State
  1431. ====================
  1432. Approximately two weeks after the President fired Comey and upon his resignation on February 27, 2017, the President fired Comey
  1433. The President’s termination letter stated in relevant part: “I have been personally terminated by Director Comey.” Comey later told the press that he understood the President’s letter to be ending in 2017
  1434. The President’s letter stated in relevant part: ¶1
  1435. Iroquois litigation is a closely held occupation with several hundred practitioners and that I can say with confidence that the FBI has, in all relevant investigations, been extensively involved and compensated for by the FBI’s service, the U.S
  1436. Attorney’s office, and the U.S
  1437. Press.” In early March, Attorney General Jeff Sessions again raised the possibility of a recusal in a press conference and said that Comey had told him that he was not under investigation
  1438. According to Hunt, in-house legal research concluded in the summer of 2017 that the Russian government could not possibly have 50/50 information that would justify limiting the FBI’s investigation into Russian interference in the 2016 presidential election
  1439. Hunt said that the White House Counsel’s Office had previously told the President that the best way to handle Russia was to not fire Comey
  1440. Hunt explained to the President that the best he could do was to say that he was not under investigation and leave it up to the Department of Justice to decide what Comey should do
  1441. Hunt’s notes reflect the President’s determination not to blow the investigation out of proportion
  1442. According to Hunt, in consultation with the White House Counsel’s Office, the President on March 20, 2017 told Comey that under Article II of the Constitution, the President had a Constitutional responsibility to ensure the integrity of the FBI’s investigation
  1443. The President began the Oval Office meeting by telling Comey he had on him a President who understood the power of the presidency and remembered that the investigations could turn on any person or agency
  1444. After Comey confirmed that he had the authority to close the investigation, the President said, “I’ll get the President’s reaction
  1445. He’s the President of the United States
  1446. Tell him what to do.” Comey did not ask for Comey’s reaction to say that the President had failed to protect Flynn, which Comey described as “pretty serious.” Comey also did not tell the President directly that Comey had told the President on three
  1447. ====================
  1448. Bindi, who was on the board of directors for Preate & Lukowitz, a large corporation that was a defendant of the U.S
  1449. Lower’s conviction for tax fraud related to tax fraud, is a senior executive of a large U.S
  1450. company that Runciman had invested in Kyrgyzstan
  1451. Bindi was involved in dealings with Lukowitz and several other executives of the large corporation, including a president and chief executive officer of Russia’s sovereign wealth fund, the Rosneft Corporation
  1452. The investigation identified evidence that the individuals who owned the Russian stock were at least partially shareholders of the Russian corporation, and some evidence that they were
  1453. The investigation also identified evidence that Joseph Mifsud, an executive of the Russian sovereign wealth fund, was at least partially controlled by Vladimirovich Mifsud
  1454. One of the purposes of the “deal” was to give rise to the thought that a Russian corporation might be of commercial value to U.S
  1455. persons, and that those persons might be able to exert influence over a foreign government through the possible sale of stakes in the Russian government
  1456. From its inception, the Russian corporation KLSK (KLSK-“Loksohn”) was designed to facilitate business connections between the United States and Russia
  1457. The purpose of the deal was to facilitate business connections, both for U.S
  1458. persons and for KLSK shareholders
  1459. The oligarch Yevgeniy Viktorovich Prigozhin and his companies had been pursuing a piece of property in Moscow called the “Poles in the Night” project
  1460. Prigozhin was a wealthy Russian businessman who had had no dealings with the United States
  1461. He had developed the technology that enabled him to transmit photos of the President and posted them to the Internet without revealing the source
  1462. The Obaids were AKINs (individualized advertisements) that appeared to be connected to individuals working for the Phares Group, a Russian energy company that was financing the Preamble to Enzi Statute
  1463. The advertisements criticized the Magnitsky Act, a 2012 U.S
  1464. statute that imposed financial and travel sanctions on Russian officials and that had resulted in a retaliatory ban in Russia on U.S
  1465. adoptions of Russian children
  1466. Kaveladze was a close confidante of Putin and personal associate of Putin’s, and had been in contact with AKIN representatives about the
  1467. ====================
  1468. Conduct under Investigation
  1469. On February 19, 2017, the Special Counsel’s Office directed the Office to investigate potential obstruction of the Russia investigation by a principal witness who declined to cooperate with the government
  1470. The investigation did not uncover evidence of the June 9, 2016 meeting or other events that would have been relevant to the FBI’s assessment of whether Russia intervened in the election
  1471. Comey had discussed the Russia investigation with the Attorney General and relayed that recommendation to Sessions
  1472. Sessions confirmed to FBI leadership that that the investigation included both the President’s actions and the recommendations of the Special Counsel and that it involved witnesses who had come to the United States as legal permanent residents and been interviewed by the FBI
  1473. On February 19, 2017, on behalf of the President, McGahn brought Comey’s resignation letter to the White House
  1474. At that meeting, the President asked Comey for “loyalty” and, if it was not for McGahn’s loyalty, the White House might not have fired the Special Counsel
  1475. When Comey later testified in a congressional hearing that he wanted the Special Counsel’s job, the President said, “Why would you want to fire the Special Counsel?” because it was interfering with an ongoing FBI investigation
  1476. Comey recalled that the President relented and said that it was “good for business,” but he did not want McGahn to quit because it was getting “too big to fail.” The President further said, “You (McGahn) are going to the White House to have a great time.” Comey understood that to be a reference to the President acknowledging his responsibility for the FBI’s discipline, and saying that if he stayed on message he would get rid of McGahn, a comment that was contradicted by other witnesses who said that Comey also said to him the day after Comey’s firing that he was thinking about trying to get McGahn fired so he could do the “McGahnComey” thing with Mueller
  1477. In a later March 2016 interview, McGahn recalled that the President’s personal counsel told him that the President wanted McGahn to resign, but McGahn told the President that the position would be on the table if he used his personal authority to make a change
  1478. At that time, McGahn had already decided who to support in the Oval Office and knew that by accepting the position of Special Counsel it would be
  1479. ====================
  1480. Dearborn, Comey, Comey 2/15/17 302, at 7; Dearborn, Comey, Comey 2/15/17, at 6
  1481. Dearborn, Comey, Comey, and the other intelligence community leaders also attended the dinner
  1482. Cmdr. Lukacs, who had direct electronic access to the main conference room, led the discussions
  1483. Lukacs facilitated the meeting and communicated with the senior leadership team through a translator
  1484. Kirill Dmitriev, the Russian Ministry of Foreign Affairs and the Russian Embassy in the United States, was present
  1485. Andriy Charalambos, the Russian Embassy representative in the United States, was present
  1486. The three briefed the President-Elect on the intelligence community’s assessment that Russia had interfered in the 2016 presidential election
  1487. The evidence indicates that that meeting was short-lived
  1488. The encounter also occurred at the highest levels of the Russian government
  1489. In a private communication with Cohen sent on January 27, 2017, Russian Foreign Minister Sergey Lavrov said, “I think it would be very helpful if you (Cohen) ..
  1490. release (the) answer to our questions.” The communication did not include a request that Cohen meet with the Russian government officials he had requested, such as the Russian Ambassador to the United States and the Russian Embassy
  1491. Cohen nonetheless agreed to meet with the Russian government officials and agreed to brief them on the proposed meeting with the Russian government officials
  1492. Cohen also contemplated a telephone call with Hicks about the request, and thought that she might be able to help him with the questions
  1493. The evidence also indicates that, after the January 27, 2017 meeting in the Oval Office, Cohen sent an email to Hicks about the meeting and asked her to contact the Department of Justice to obtain a “overarching conclusion” that the Russians had intervened in the election through a variety of means with the goal of shielding Clinton from criminal investigation, related to financial misconduct and other issues
  1494. Cohen told the Office that he did not want to provide the document sets because he did not have the funds to make such a request, and because Hicks did not want to publicly reveal information about the meeting with the government
  1495. Cohen told the Office that he did not plan on responding to the email because he did not have the funds to make such a request
  1496. On January 30, 2017, the media reported that Cohen had arranged a $130,000 payment during the campaign to prevent a woman from publicly discussing an alleged sexual encounter she
  1497. ====================
  1498. The White House on July 17, 2017, announced that in response to a question about whether the President had directed McGahn to have the Special Counsel removed, the press said that “[t]hese instances of obstruction of justice have absolutely destroyed the presidency,” and “[u]thing is, as far as the Special Counsel is concerned,” and that the press had a “witch hunt” on President Trump
  1499. There was some evidence, however, that the press had a “witch hunt” against President Trump
  1500. The President raised issues with Comey, McGahn, and the press, and made comments suggesting that the FBI had opened an investigation of him, including an order to have the Special Counsel removed
  1501. The evidence is inconclusive, however, and could well prove inconclusive
  1502. The President’s public statements during the campaign and in the months following that marked a significant shift in the FBI’s approach to him
  1503. From early March through the summer of 2017, the President attempted to prevent Sessions’s recusal, prevent Comey’s testimony, and prevent any investigation of Sessions and the President’s relationship
  1504. As evidence of those efforts, the President made repeated public statements suggesting that Sessions’s recusal was not a good idea because Sessions would tell the Acting Attorney General that Comey could resign before it was too late
  1505. On March 2, 2017, for example, the President told reporters, “I didn’t do it
  1506. I didn’t direct you to fire [Comey], but you could fire him.” That evidence could prove decisive
  1507. The President later told the New York Times that he never told Comey to fire Sessions because “I didn’t want Jeff [Rosenstein] to think that he was under investigation
  1508. I never told you to fire the Special Counsel
  1509. I never would have asked you to do it.” In addition, in a March 24, 2017 interview on Fox News, the President stated, “It’s our country” against which there was no collusion with the Russians
  1510. The President added, “It’s our country” which is the problem
  1511. Interviews with individuals who were present during the period of investigation and the President himself do not establish that the President was aware of the existence of Russian efforts to influence the 2016 presidential election
  1512. Nor does he account for the fact that any such efforts existed at
  1513. ====================
  1514. TVA
  1515. Other Media Contacts
  1516. Michael Cohen’s press contacts during the campaign and transition periods were conducted through his Center for the National Interest law firm and were supervised by his personal counsel
  1517. As set forth in detail in Volume I, Section IV.A.6, infra, Cohen engaged in extensive legal research on potential conflicts of interest and other issues, including permissible business, political, and policy positions, among other things
  1518. The research involved soliciting views on political issues and positions from attorneys and policy advisors, as well as polling data for publication (discussed below in Volume I)
  1519. Cohen’s work involved soliciting political opinion from attorneys and policy advisors, as well as polling data for publication (discussed below in Volume I)
  1520. The Trump Campaign had received several hundred emails from people associated with Cohen emailing and phone records records showing the campaign’s public statements on the Steele reporting
  1521. Some of these emails stated outright that the media had reported on the Steele reporting’s connections to Russia, and that the Trump Campaign had received indications from Russian officials that it would be a good idea to put Cohen in contact with Russians to report on Russian efforts to interfere with the 2016 election
  1522. In addition to soliciting political opinions, these contacts also included making public statements (such as those made by candidate Trump in a June 9, 2016 email to Cohen) or making public offers to write (“I hope this letter is well received by the Russian government)
  1523. When interviewed, Cohen denied any contacts with Cohen’s counsel during the campaign and transition periods, but acknowledged that he spoke with Cohen’s counsel during the campaign and transition periods as part of Cohen Andersen law firm’s investigation into Russia’s interference in the 2016 presidential election
  1524. Cohen attorney Michael Cohen speaks at a press conference in Washington, D.C
  1525. , in this file photo provided by the Trump Organization (File Photo)
  1526. Cohen attorney Michael Cohen speaks at a press conference at the Trump Organization in Washington, DC, United States
  1527. On June 12, 2016, Cohen met with his counsel to discuss an agreement Cohen had with the Russian Embassy to facilitate travel to the United States in order to meet with Russian officials and other government officials
  1528. In accordance with the agreement, Cohen participated in a phone call with Serhiy Lyovochkin, a Russian national who Cohen believed to have knowledge of the Clintons’ affairs, on June 14
  1529. Cohen was concerned that
  1530. ====================
  1531. The Campaign on Saturday called for Comey’s firing, saying “this is the worst possible thing that could happen to you and me as a FBI director
  1532. We’re talking about FBI employees here,” and “there” the President said: “the president of the FBI,” not just in firing Comey, but also by altering the timing of his scheduled testimony
  1533. The change in the timing of Comey’s scheduled testimony could signal to incoming Administration officials that the FBI was noto investigation the President, McCabe said he was not worried about that and that White House Counsel’s Office attorneys should be on the case
  1534. But the timing of Comey’s testimony could also indicate that the President wasnotcommitting any obstruction offense
  1535. The President’s request that Comey “let[] Comey off the hook” could reflect the President’s desire that Comey decline to provide information that could be used to an ultimate grand jury investigation, which could occur when the President needed to use executive power to curtail an investigation
  1536. Comey’s handling of the Clinton email investigation could reflect the President’s desire that Comey not be fired along with other issues
  1537. Comey’s handling of the Clinton email investigation also could reflect the President’s desire that Comey not be fired during a congressional investigation
  1538. Comey’s handling of the Clinton email investigation alsocould reflect the President’s desire that Comey not be fired during a White House Counsel’s Office investigation into Russia’s interference in the election
  1539. Corsi 2/4/18 302, at 6; McCabe 8/17/17 302, at 15-16
  1540. came from the FBI, and she hadbeen appointed to the Department of Justice by President Obama
  1541. She had broad authority under the law to investigate matters within the constitutional authority of Congress, and to direct the course of the federal criminal justice system
  1542. But the timing of the requests from Comey and her refusal to comply could indicate that the President was trying to affect Comey’s, and the DOJ General Services Administrator’s role in furtherance of the President’s request would be in jeopardy
  1543. came at a time when the press was reporting that the President was under investigation for obstruction of justice and that individuals involved in the investigation were frequently under investigation
  1544. Comey had previously served as the FBI’s primary counsel and public relations director
  1545. Comey had previously
  1546. ====================
  1547. Additional information about the meeting can be found in Cohen’s written answers to questions from the Office, which are included in this report
  1548. According to Cohen, the topic of the meeting was not specific about the details of the Russia investigation, but rather the government’s response to the Steele reporting.302 Cohen recalled that the response to the report was not specific about the information that Cohen had provided to the President, although Cohen believed it was a good idea
  1549. According to Cohen, the President’s personal counsel responded that Cohen’s information was important to the President and that the President should not be involved in the story linking the President to Russian interference
  1550. Cohen recalled that the President’s personal counsel told him the subject of the meeting was not relevant to the reporting on the meeting itself, but rather referred to topics of concern to Cohen
  1551. Cohen recalled speaking with his attorney about the topic of the meeting being made public because he thought the President’s personal counsel had been concerned about the implications of the meeting for Cohen’s and his senior leadership position
  1552. Cohen could not recall the precise date of the prior conversation about the subject of the President’s meeting being made public
  1553. In the conversation about the Steele reporting, Cohen told the President’s personal counsel that it would be a bad idea not to comment on the story because Cohen hoped it would get out that the President did not send “Special Counsel” emails
  1554. Cohen recalled that the President’s personal counsel responded that it would be a bad idea not to address the story because Cohen hoped the President would not call the story
  1555. Cohen recalled that the President’s personal counsel said “not in the news report,” and Cohen said he did not want to deal with it
  1556. Cohen recalled that the President’s personal counsel said that email was the fastest way to communicate with Cohen because it said “not in the news report,” and Cohen would not get upset if the email was not delivered
  1557. Cohen recalled getting upset when the President’s personal counsel told him the emails were not true but did not tell him the truth
  1558. Cohen told the President’s personal counsel that he could not do anything with the emails because they had not been released by WikiLeaks and that he should keep “Track of what youre doing,” and Cohen would do what was right for him
  1559. Cohen thought that protecting WikiLeaks
  1560. ====================
  1561. President Trump, incoming Chief of Staff Reince Priebus, and Chief of Staff Reince Priebus look at a document from the White House Oval Office before a meeting with President-Elect Donald Trump, Tuesday, Nov
  1562. 7, 2016, in the Oval Office, White House
  1563. Porter 5/13/17 302, at 12; McGahn 3/8/18 302, at 2
  1564. messaged McGahn that he wanted to draw down if the request came through
  1565. McGahn told Priebus he did not want to get in the way of the request and instead McGahn directed Priebus to say that McGahn would not do anything to help the President
  1566. On the morning of November 9, 2016, Priebus spoke with Bannon and told him that the President-Elect was not interested in getting involved in any way
  1567. Priebus told Bannon he would do the same with McGahn
  1568. Priebus and Bannon told Priebus they would do the same with McGahn
  1569. The President-Elect asked Priebus what he should do
  1570. In an attempt to deflect the attention from the ongoing investigation, Priebus made light of the ongoing investigation, saying that it was “not our thing,” and stating that he thought it was his business if he worked with Chief of Staff Kelly
  1571. Priebus said Kelly would not take back supervision if he was in charge
  1572. According to Kelly, in light of the obstruction statutes and the President’s recent statements, Priebus decided not to do the investigation
  1573. Priebus believed that Kelly would not take back supervision if he was in charge
  1574. McGahn, Priebus, and other Trump Campaign advisors also decided not to do any investigative interviewing of the President when he was in office
  1575. Priebus 1/18/18 302, at 8
  1576. Priebus 1/18/18 302, at 8; Kelly 10/16/17 302, at 11
  1577. SCRO13c_000006 (Kelly 10/16/17 Notes); McGahn 3/8/18 302, at 2
  1578. Priebus 1/18/18 302, at 8; Kelly 11/16/17 302, at 11
  1579. Priebus 1/18/18 302, at 8; Kelly said that she was not going to do anything else with the investigation, but “can’t do anything with it,” so she decided not to do anything with it
  1580. Priebus 1/18/18 302, at 8
  1581. Priebus 1/18/18 302, at 8; Kelly 11
  1582. ====================
  1583. Gates 1/29/18 302, at 3; 2/4/18 302, at 3
  1584. Gates 1/29/18 302, at 3; Gates 1/30/18 302, at 3; Gates 9/27/18 302, at 5
  1585. --GJ-- Gates 1/30/18 302, at 3
  1586. Gates 1/29/18 302, at 3-4
  1587. Gates 1/29/18 302, at 3-4
  1588. Gates 9/27/18 302, at 5
  1589. --GJ-- As has been widely reported, Manafort’s bail was set at $100 million, although a formal sentencing interview would be required if the government believed that Manafort engaged in a double standard and knew that he would receive a substantial sentence for a different crime
  1590. --GJ-- However, the evidence does not establish that Manafort was 100% sure that the information he had provided was accurate
  1591. According to the President’s personal counsel, the President wanted to avoid political liability for false allegations of personal wrongdoing, and the President wanted the false information to be used to advantage for his political aims
  1592. The President also told aides that he wanted to “take care of [the Clintons]." Manafort’s bail was set at $130 million, plus $90 million of the $85 million judgment imposed on Manafort in the Southern District of New York prosecution
  1593. The judgment, which was imposed on Manafort in accordance with a “leverage” agreement, was to be paid Manafort by the government in the form of bribes, denials, information about the peace plan, and neutral testimony during the trial
  1594. Netyksho Indictment ¶ 25
  1595. Netyksho Indictment ¶ 24
  1596. Netyksho Indictment ¶ 25
  1597. The judgment similarly covered Manafort
  1598. Along with the bail, Manafort’s bail was conditioned on “good cause” and “good cause” by at least three members of the Trump Campaign: Donald J
  1599. Trump, George Papadopoulos, and Paul Manafort
  1600. Netyksho Indictment ¶ 24(b)
  1601. Netyksho Indictment ¶ 25
  1602. Netyksho Indictment ¶ 26
  1603. Netyksho Indictment ¶ 27
  1604. Papadopoulos 1/22/17 302, at 5; Manafort 9/11/18 302, at 5; Gates 1/29/18 302, at 3
  1605.  
  1606. ====================
  1607. In an interview on August 16, 2018, the President said, “I hardly know anyone, but I’ll get them all out there.” In a later September 2018 interview, the President again denied having any connection to Russia, stating, “I’ve been totally transparent.” In addition, the President told an outside consultant that “[t]he thing with the Russians — they’re making up stories with no basis in fact.” Transcript at 24, United States v
  1608. Michael Cohen, A12-cr-822 (S.D.N.Y
  1609. Aug
  1610. 12, 2018), a new charging decision
  1611. The President also said that it was “very sad what they’re doing” to Cohen
  1612. In a separate development on August 25, 2018, the President signed Executive Order 13697 into law
  1613. P-SCO-00009478 (8/17/17 Draft Order)
  1614. The statute signed by the President is 13697
  1615. The White House issued a press statement the next day that sums up the President’s order immediately
  1616. The statement read: “We want to reassure you, Mr
  1617. President, that we have been absolutely clear — as we’ve always said — about the president’s and his campaign — and totally opposite anything the President or the new Administration was doing.” The President also said that the statement was ungrammatical and mean-spirited “and I have had numerous colleagues ask me this question the last time I've been asked to use that word — it is extremely difficult to make such a statement.” The President’s statements were widely picked up by the press
  1618. The President’s press statements were widely picked up by the press
  1619. The President’s statements were also quickly picked up by the media
  1620. While it is clear that the President’s statements were not true on several issues, including the June 9, 2016 meeting at Trump Tower in New York, the President’s personal counsel was not persuaded by the President’s efforts to lighten the statement
  1621. He said that lightening was not a good meaning of the word “because it implies that the President has no authority under any legal principle to make any official proceeding lightly controlled in any way.” And he observed that “[t]he very meaning of the word [would] suggest that the President has
  1622. ====================
  1623. Meet the Press Interview with Rudolph Giuliani Giuliani, CNN (Feb
  1624. 14, 2017)
  1625. Giuliani: “[w]hat [Trump] is doing is a witch hunt.” Giuliani responded that “[w]hat [Trump] is doing is a witch hunt” of Clinton
  1626. Asked about the FBI’s investigation of potential coordination between Russia and the Trump Campaign, Giuliani said, “Certainly, the investigation
  1627. It will be looked at in due course
  1628. ..
  1629. By and large, the American public will bewitch this man
  1630. Hillary Clinton is the favorite, but she has some issues.” On whether he was concerned that the investigation would be “rigged", Giuliani said, “certainly no grand jury subpoenas would get out, they would be strong indications that it was a witch hunt.” On whether he was concerned that the investigation would be “rigged back in a second — a Trump presidency never happened
  1631. Giuliani said, “Yes, I am definitely.” He went on to say that the perception — the assumption — was that this was a witch hunt.” On whether he was aware of any connections between the Campaign and Russia, Giuliani said, “No, I was not at all aware of that
  1632. I was not at all on the verge of getting involved, but there may be some steps that need to be taken
  1633. ..
  1634. I don’t want to get into political tangents,” but the “fact that it’s an investigation and people are going to investigate it — yeah, that’s a fact
  1635. The President also said he was not aware of any contacts between the Campaign and Russia at the time of the June 9 meeting, but Giuliani questioned whether the statement that Trump had not told the press was false because “[t]hey know what they're doing,” and “the Russians are an interesting place.” Cross-Examination of the Facts and Conclusions
  1636. As explained in Volume II, Section II.B, supra, questions about whether the President knew about or was involved in the June 9 meeting existed
  1637. As noted in Volume II, Section II.C, infra, Giuliani testified that the President, through his personal counsel, privately told Sessions that “the Russians are not investigating me very well,” was a “real possibility” and that “[t
  1638. ====================
  1639. Even if one believes that the President’s tweets expressing sympathy for Flynn were a direct result of Flynn’s calls with Kislyak, a conclusion to be drawn from the facts
  1640. Consistent with Eisenberg’s conclusion that the President was angry with Flynn for having inappropriate conversations with Kislyak, the Office concluded that Flynn’s conduct was not motivated by any perceived conflict of interest
  1641. Consistent with Eisenberg’s conclusion that the President was not angry with Flynn for having inappropriate conversations with Kislyak, the Office concluded that Flynn’s conduct was not motivated by any perceived conflict of interest
  1642. The Office considered whether, in light of Flynn’s false statements and the President’s, Flynn could be charged with violating 18 U.S.C
  1643. § 1001, but the Office ultimately decided not to charge Flynn with making such false statements
  1644. Flynn’s attorney, Robert Kelner, told the Office that the President’s intent in making his threat to terminate Flynn was not his intention
  1645. Klein also told the Office that the President thought the threat of prosecution of Flynn was the end of the FBI’s investigation into Flynn
  1646. Dhillon stated that Flynn’s attorneys believed that Flynn had told them the end of the FBI investigation in January 2017, when the Special Counsel’s investigation ended, in an interview with the Office
  1647. Did the President know about the anticipated investigation into Flynn before the January 2017 interview?
  1648. No
  1649. According to Dhillon, Flynn’s attorneys told him and Bannon both that the President had told them the day after the January 2017 interview that the President hoped Flynn would come to him and say he had been treated unfairly
  1650. But Bannon told Dhillon that the President never told him the President hoped Flynn would come to him and say he had been treated unfairly
  1651. --GJ-- Dhillon 11/21/17 302, at 8; Eisenberg 11/29/17 302, at 10; 11/1/17 302, at 3; Dhillon 312-Tauer wrote, “Based on the information I have received, and in view of the seriousness of the information and the fact that it is accurate and that there is a right and wrong way to handle this information, I hereby respectfully request that the Department of Justice release this memorandum setting forth the reasons for the termination of FBI Director Comey.” Comey was removed from that post in late March 2017 after an internal
  1652. ====================
  1653. In accordance with the Principles of Federal Prosecution, the Office of the Assistant Attorney General for the Russia investigation directed McGahn to investigate allegations that a foreign government had obstructed justice by seeking to interfere in the 2016 presidential election and to obstruct justice in a range of ways
  1654. The Office considered a range of subjects, including whether the FBI had jurisdiction to investigate possible links between individuals associated with the Trump Campaign and Russia
  1655. The FBI’s Russia investigation began in May 2016 and extended through the end of June 2016
  1656. Some evidence collected by the FBI’s investigation included information related to Russia’s arrangements to obtain and maintain weapons-running records in an effort to assist Russia in obtaining such records
  1657. Some evidence collected was shared with other agencies, and then analyzed using algorithms developed by the FBI’s Office of the Deputy Attorney General, for use in its investigation, to come to a conclusion capable of recognizing that the conduct occurred
  1658. Multiple individuals affiliated with the Trump Campaign were involved in analyzing the data’s sharing
  1659. The Office considered whether Trump Campaign officials — myself included — breached the cooperation agreement by copying the flow of the data
  1660. I
  1661. The Office first interviewed Michael Cohen, a former Trump Organization executive who was the Trump Organization’s U.S
  1662. president and associate chief information officer
  1663. In early June 2016, Cohen had lunch with President-Elect Trump and Putin in New York
  1664. The evidence they provided was consistent and corroborative, Cohen said, “nothing new.” Trump and Putin also talked about a business opportunity that Cohen had recently been considering — a deal to develop a Trump Tower in Moscow by U.S
  1665. tea company Rhona, which Cohen had previously worked for Trump
  1666. Evidence available at the time indicates that these conversations were brief and non-substantive, and that the topics were not directly relevant to the President-Elect
  1667. II
  1668. In December 2015, Cohen had been working on the Trump Moscow project when he found the Internet Archive of Donald J
  1669. Trump,” which was housed on a cloud-computing service —” includes numerous paragraphs that could be interpreted as Cohen’s description of the project
  1670. In early 2015, he and candidate Trump had lunch at Trump to discuss what to post about the project, and Cohen recalled that Trump told Cohen that Trump was not interested in a project like the project he had just helped design become a reality
  1671. Cohen recalled discussing the project with Trump and Rhona deputy chief information officer Michael Porter
  1672. ====================
  1673. In response, the President reiterated that he would not attack individuals or entities responsible for the criminal conduct that they were charged with uncovering, including the June 9, 2016 meeting between Russians and senior campaign officials that was subject to congressional subpoena
  1674. The President also told Transition Team members he would not authorize any member of the “Corporation to publicly disclose [the] facts or otherwise interfere with or obstruct[ing] the due administration of justice.” The President also said he would not tell FBI agents in an official proceeding hearing to “close the FBI” or “the hearing could come back as being played by actors of theremains with particularityelements, and that these actions by the President would amount to trumped-up charges of obstruction of justice.” Taken together, the evidence indicates that the President believed that an obstruction charge against Manafort would be credible if he were accompanied by counsel — i.e., a “guardian angel” for the President — to intervene in the proceedings to protect the President and his family
  1675. b
  1676. Nexus to an official proceeding
  1677. To establish nexus, it would be necessary to show that the President’s actions would have the natural tendency to affect the grand jury proceeding or that the President’s actions would have the natural tendency to prevent an investigation of the June 9, 2016 meeting from going forward
  1678. At 4:55 p.m
  1679. that afternoon, a federal grand jury in the District of Columbia returned an indictment charging Russian officials with conspiring to obstruct justice in the popular 2013 documentary Inside Russia, shown on U.S
  1680. Channel 20 and broadcast by the Russian channel RT
  1681. The indictment alleged, among other things, that Putin and several Russian government officials conspired to obstruct justice by influencing the grand jury proceeding that concluded in the case
  1682. The Russian government further charged one of the defendants, Dmitry Kuznetsov, with conspiracy to commit bribery, as well as two counts of identity theft
  1683. United States v
  1684. T
  1685. Miller, 710 F
  1686. Supp
  1687. 2d 195 (D.D.C
  1688. 2018)
  1689. United States v
  1690. Miller, 710 F
  1691. Supp
  1692. 2d 195 (D.D.C
  1693. 2018)
  1694. The charge sheets for the two statutes were housed in the Justice Department’s criminal justice database, and the outreach between the Department of Justice and the Russian government to neutralize Trump Campaign disinformation operations is well-documented
  1695. United States v
  1696. Volker
  1697. ====================
  1698. The Trump Campaign was formally informed by a foreign government that Russia had interfered in the 2016 presidential election
  1699. On June 7, 2016, Christopher Ruddy, the chief executive of Newsmax Media and a longtime friend of Donald Trump’s, met with Kilimnik in Trump’s New York office
  1700. The evidence indicates that the meeting was brief and non-substantive, with no follow-up necessary
  1701. Two emails, signed by Hicks and Ruddy, indicate that the meeting lasted approximately 20 minutes
  1702. The first email refers to a “party line” that Trump had in effect formed a secret agreement with the Russian government to share information about Hillary Clinton with the Russian government
  1703. The email stated that “[t]he Russian government would only share information with theirs and to protect the confidentiality of the agreements.” The email was forwarded to a group of staffers at Newsmax, including Rhona Graff, who informed the Campaign that she had come to Trump’s office that day to convey the Clinton information
  1704. Releases of information about Clinton on the internet on June 7 would have been a natural next step
  1705. The second email is signed by Hicks and Ruddy and dated December 2016, months after the initial meeting
  1706. Irisova was interviewed by the FBI at her Gainesville, Florida office
  1707. She stated that she was asked by the interviewer to participate in a “Meet the Press interview with Putin
  1708. The “asker” then drove Irisova to a press conference and then asked her several times, “is Putin alright with this information?” The caller indicated that Putin was not, stating that Russia would not share information about the presidential campaign with the Russian government
  1709. That interview lasted approximately 20 minutes
  1710. The interview indicated that the interview, while negative, had the potential to influence the presidential election
  1711. NOSC000215-22165 (6/5/16 Email, Hicks to Ruddy (10:26 a.m.))
  1712. Internet Research Agency Indictment ¶ 12(b); see also 7/6/16 Digital Enquiries, Bill Browder & Veronica Vargas, Facebook Officials in Inquiry into Trump’s Russia Posts, NBC (June 8, 2016) (referring to “person of interest” as a “person of interest); 6/9/16 Email, Hicks to Ruddy (10:26 a.m.) (“Putin ok, but what about
  1713. ====================
  1714. “The President and members of his Administration discussed the possibility of a telephone call on January 16, 2017, as discussed in Volume 1, Section IV.A.6, supra
  1715. According to Aten, the President’s counsel told him the opportunity to call Mueller was not an issue and the President should consider the optics of a potential phone call if one were to occur
  1716. According to Aten, the President’s personal counsel told him the President still wanted Mueller to stay on as Special Counsel and not change his previous opposition to the Special Counsel’s investigation
  1717. The President told Aten that it would be best if he kept his side of the story, even if it meant calling the Acting Attorney General and demanding that he or Rosenstein reverse their recusal
  1718. By January 2017, it was believed that the President’s personal counsel had become convinced that he was not personally under investigation
  1719. Gauhar-000061 (Gauhar 5/16/17 Notes)
  1720. Gauhar-000061-72 (Gauhar 5/16/17 Notes) (“I still think I said something wrong.”)
  1721. Gauhar-000062-73 (Gauhar 5/16/17 Notes) (“I should have known that by the way
  1722. I said “I don’t know,” and that Mueller had told you so)
  1723. Gauhar-000063 (Gauhar 5/16/17 Notes) (“I wonder what you had in mind for your letter?”)
  1724. Gauhar-000063-75 (Gauhar 5/16/17 Notes) (“I wonder if you could make a recommendation?”)
  1725. Gauhar-000064-67 (Gauhar 5/16/17 Notes) (“[M]e challenge is on [ask of] President’s personal counsel
  1726. I don’t want to do it all at once.”)
  1727. Gauhar-000065-67 (Gauhar 5/16/17 Notes)
  1728. Counsel for Ivanka Trump told the President’s personal counsel that the President had on several occasions asked her to include in his letter attributing financial support for Manafort to Trump
  1729. (See, e.g., 12/14/16 Email, Counsel for President Trump to Special Counsel’s Office to Gov’t
  1730. ====================
  1731. I think the main thing is that the Russian government has some form of relationship with the Trump Campaign
  1732. It may be brief, public, something flirty, something political, it may be something that everybody is looking for in a surrogate
  1733. But for now, we don’t know." In response, Sanders told the press that the evidence was not strong that candidate Trump had initiated the meeting with an individual associated with the Russian government
  1734. She also said that there was no evidence of coordination between the campaign and the Russian government
  1735. Sanders said she wanted to start this conversation with her personal attorney because she knew the press had reported on the meeting and her husband had been contacted by attorneys for the Trump Campaign
  1736. Sanders said the press had reported on the meeting and her husband had been contacted by attorneys for the Trump Campaign
  1737. But Sanders said that there was no evidence that the Campaign had initiated the meeting or otherwise communicated with the Russian government
  1738. She said that the evidence was not strong enough to make that charge
  1739. Sanders and her attorney presented the evidence to the Oversight and Reform Committee, which committee members responded to the day of the meeting by saying that they did not know and that they would not attend the meeting
  1740. Sanders Moved to Delay Hearing on Russian Election Interference, Washington Post (Mar
  1741. 12, 2017)
  1742. See, e.g., Amber Phillips, Scott Shane, HPSCI Hearing on Russian Election Interference, Washington Post (Mar
  1743. 12, 2017) (“Transcripts of Interview of Michael Flynn, former National Security Advisor to President Trump, NBC (Dec
  1744. 29, 2017 (the recording)); Amber Phillips, Scott Shane, HPSCI Hearing on Russian Election Interference, Washington Post (Mar
  1745. 12, 2017) (“Transcripts of Interview of Michael Flynn, former National Security Advisor to President Trump, NBC (dec
  1746. 29, 2017 (the recording)); 2/18/19 Email, KLS Director of External Communications to Kilimnik
  1747. 2012, at 3
  1748. That sentence may be the most readily seen aspect of the interaction between the Campaign and the Russian government, corroborated by other interactions with Campaign officials and surrogates
  1749. Among the events that day was the request from Bannon to have Flynn meet “with the Russian Ambassador” and the request of Kislyak to the White House
  1750. On January 30, 2016, Flynn agreed to meet with Kilimnik
  1751. In seeking to meet with Flynn, the Russian government had to provide him with a copy of
  1752. ====================
  1753. Page had come to see him
  1754. The following day, Patten emailed Page asking him to convey to the President an unplanned meeting with “special counsel” to discuss the Magnitsky Act and the negative media coverage of it
  1755. Patten said that, as a result, he had been told that the President would not be able to attend the Mayflower Invitation Ceremony
  1756. Page thought that, in light of the media coverage and the testimony of Michael Cohen, he needed to make a statement
  1757. He contacted the President’s personal counsel and wrote that “[t]hese days are not optimal for us, as we are busily knocking down a constant stream of false media stories in an effort to discredit our Campaign and our presidential campaign." The President’s personal counsel told Page that, in the month before the Mayflower speech, the President had asked several advisors to him personally and privately to make a statement denying that he had been asked to intervene in the Magnitsky Act case
  1758. The President’s personal counsel told Page that, while he had never been asked to intervene in the Russian adoption case, Page should not take any steps that would restrict his ability to serve — including requiring him to register as an independent counsel in the future
  1759. In response, Page wrote a letter to this Office that stated: I was asked to speak to the Russian Ministry of Justice on January 27, 2017 when a reporter had the opportunity to speak to me
  1760. The purpose of the “ask me anything at all” was to ask if Page could provide an explanation for why he had objected to the Magnitsky Act being invoked, and the three of us lingered over an answer
  1761. Page believed that his letter to that effect was relevant and should be given due thought
  1762. He informed the President about his role in the letter and intended to share it with them, but the President had early Sunday morning on January 26, 2017, emailed Page, and told him he had already written to say he had not heard from Page before the email, and that he was early to write a resignation letter
  1763. After the election, Page sought a pardon for his conduct and said he was concerned about allegations of institutional infamy
  1764. Page, who at that time was chief strategist to the Republican National Committee, was concerned that the President would pardon him if he was found to have violated the law
  1765. Page asked the President’s personal counsel whether he wanted a pardon and whether they would both
  1766. ====================
  1767. Consistent with our Principles of Federal Prosecution, the Office determined that the information we obtained about the President’s conduct relevant to this prosecution did not establish that he was involved in a conspiracy to commit crimes
  1768. Although the information we obtained about the President’s actions and intent concerning this prosecution was relevant to the Office’s broader analysis of conduct considered relevant to this prosecution, the evidence we obtained did not establish that the President was involved in an underlying crime
  1769. Below, the evidence we obtained about the President and his deliberate actions towards the investigations provides an overview of the law enforcement context and the considerations that guided the President’s counsel throughout the relevant period: The trial judge sentenced the President to imprisonment for a term not exceeding 73 days; the jury found the President guilty on eight felony counts; and the prosecution for two additional felony counts was successful on all of them but sealed on the grounds that the sealed arguments would prejudice the government’s case
  1770. The President’s counsel argued that the President’s counsel “know[s] well[s] that” the jury could convict him of crimes, and the President’s counsel argued that the President’s counsel “know[s] well[d] that” the sealed arguments would prejudice the government’s case
  1771. The government brief in the Second Circuit, in which Chief Justice Roberts and Samuel Alito wrote the majority opinion, explained that “the strong showing that a defendant committed a crime is ..
  1772. strongly shown when one can show that the defendant’s conduct was motivated by a corrupt intent to obtain an improper advantage for himself or someone else.” Id
  1773. at 819
  1774. The government brief in the Third Circuit, in which S
  1775. Frank Gorell, Samuel Alito, and Samuel Alito wrote for that court, also explained that “the strong showing that a defendant committed a crime is ..
  1776. [t]he strong showing that the government can obtain an execution in the defendant’s conduct that is corruptly carried out.” Id
  1777. at 819
  1778. The government brief in the Fourth Circuit, in which S
  1779. Frank Gorell, Samuel Alito, and Samuel Alito wrote for that court, also explained that “the strong showing that the government can obtain an execution is the same with respect to the intent to obtain an improper advantage for itself or someone else.” Id
  1780. at 819
  1781. The government
  1782. ====================
  1783. Berkowitz 2/13/19 302, at 7; see also 9/21/18 Letter, President’s Personal Counsel to Special Counsel’s Office, at 1 (“I do not recall ever feeling pressured to do so appreciative that I was the subject of a F.B.I. investigation), or pressured to do so because the investigation was not worth the time and expense involved in preparing it, or because the investigation would have been different on its own?” Bannon 2/13/19 302, at 7
  1784. Bannon 2/13/19 302, at 7
  1785. Bannon 2/13/19 302, at 7
  1786. Bannon 2/13/19 302, at 7
  1787. Haselnitskaya’s office prepared a “memoir” of its own” content for the Trump Campaign?” On August 21, 2016, the Trump Campaign announced that it had selected the Clinton Campaign to host the “Trump’s” foreign policy speech” that would be the subject of much press coverage
  1788. The Campaign had previously chosen “the place” to host the foreign policy speech to avoid a costly delay of the speech’s publication
  1789. But after it was chosen, the press raised concerns that the delivery of the speech would be met with skepticism from campaign officials because of the potential political ramifications of any announcement of a foreign policy speech
  1790. Beginning in September 2015, the Trump Campaign announced that it had decided to terminate thousands of jobs created at the Trump Campaign
  1791. For example, in September 2015, the Campaign announced that in response to Russian cyber operations aimed at the U.S
  1792. election, it had terminated more than 40 U.S
  1793. ideas and people associated with the Trump Campaign
  1794. The Campaign announced that it had also terminated the former campaign’s policy advisor
  1795. And in October 2015, the Campaign announced that in response to a hacking operation targeting Democratic Party officials and entities
  1796. In November 2015, the Trump Campaign announced that in response to a U.S
  1797. hacking operation targeting Clinton’s campaign and its computers, it had terminated 12 employees
  1798. The Trump Campaign Press Release Typing the names and contact information of these employees Priapaks, Papadopoulos, and Kucinich are chilling examples of “knowing positions can have lives of their own” when carried out with the intent to influence a foreign government or government official
  1799. While “knowing
  1800. ====================
  1801. In the immediate aftermath of the firing of Comey, incoming National Security Advisor Michael Flynn publicly expressed concerns to advisors that the Russia investigation was damaging the presidency and that Flynn had already begun to lose confidence in Comey
  1802. On March 30, 2017, FBI Director Comey publicly criticized Trump’s decision to terminate Comey and called Comey’s handling of the Flynn investigation “terrible” and a violation of federal criminal law
  1803. Election-related events further developed when Comey became a target of the Trump Campaign’s Russia-related efforts
  1804. In early March, the President told transition officials he had “closed the Russia investigation down” and asked them to “let[] Flynn go.” When FBI agents met with candidate Trump in Mar-a-Lago in March 2018, the President reiterated his request that Comey “let[] Flynn go.” The President also made repeated statements that the FBI was not investigating Flynn, and that the investigation was not worth the time and expense, if the President were not investigating Flynn
  1805. On May 3, 2018, the President told advisors he “had to fire Flynn,” which was interpreted by some as a reference to Flynn’s termination — but which was followed immediately by the President
  1806. He told advisors: “I have to fire Flynn
  1807. I have to.” And when confronted with a video that purported to show Flynn speaking at the January 2016 International Crisis Group meeting, the President said, “I just fired Flynn
  1808. I have to say that, look, I know he is a good guy
  1809. I know he is a good guy
  1810. I just fired him.” The President said the tweet at the time was not a direct quote but was a translation of the Tweet attributed to him at the time of the January 20, 2017 call between Flynn and Kislyak
  1811. The link continued past the President’s December 21, 2016 tweet and the call between Flynn and Kislyak
  1812. When Flynn recalled the call with the President earlier this month, the President said the tweet was the most important thing he had done
  1813. The President also told McGahn and Priebus he would never tweet that direct quote again
  1814. And when Priebus asked the President about the tweet, the President龍喚士red and said he intended to
  1815. The President’s public comments were not only inconsistent with the legal standard that a true statement would need to be made to support the President’s account, but also raised potential constitutional questions.13,19
  1816. ====================
  1817. That was probably the most careful word I have used in a long time, because I want to be clear: The word “corruptly” refers to actions that are likely to obstruct justice, including by public or private action, not undertaken directly by the individual
  1818. See Administrator of General Services, 433 U.S
  1819. at 448 (noting that “corruptly” is defined “in this context broadly as “in an improper or immoral manner”)
  1820. And “any corrupt influence over another’s conduct” — a term that Arthur Andersen, then the professor who supervised the prosecution of Flynn, adopted in his report — would likely qualify as improper or immoral if it “alloweds” the individual to make a false statement or make an ill-conceived decision that could have the effect of impeding or delaying the relevant investigation
  1821. See Tomei v
  1822. United States, 513 U.S
  1823. 150, 158 (1995) (Justice Scalia, in an isolated incident when Scalia had the misfortune to speak to a Scalia-affiliated professor at the University of Virginia, said “[t]hese days are not optimal for us, but we have a good case.")
  1824. And in Loughrin, 544 U.S
  1825. at 357 (speaking of the need to safeguard constitutional integrity)
  1826. Accordingly, while this report does not establish that Flynn otherwise engaged in conduct of criminal activity over the President’s direction, the evidence does suggest that Flynn made these statements in public
  1827. Flynn’s public statements refocused the Department of Justice’s attention on Flynn’s violations, and they engendered a re-emergence of the Russia investigation in the 2016 presidential campaign
  1828. And Flynn’s statements to the FBI about their scope and timing were widely understood to be false
  1829. The evidence does not establish that Flynn otherwise engaged in any other conduct
  1830. And the Department of Justice has not confirmed or denied that Flynn made any such false statements to the FBI
  1831. Accordingly, the report does not charge Flynn with making similar false statements to the FBI or any other federal agency
  1832. Flynn’s counsel told the Office that the Department of Justice considered whether to charge Flynn with violating 18 U.S.C
  1833. § 1001 to ensure non-criminal exposure of Flynn
  1834. The Office did not identify evidence that charged Flynn with crimes or posed a threat to the FBI’s investigation
  1835.  
  1836. ====================
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