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MUR# 1J(Q5 .-··, "•- R
MUR726500001 BEFORE THE FEDERAL ELECTION COMMISSION COMMON CAUSE 805 Fifteenth Street, NW, Suite 800 Washington, DC 20005 --,-, (202) 833-1200 ~-'l MUR# 1J(Q5 .-··, "•- r , . ' PAULS. RYAN 805 Fifteenth Street, NW, Suite 800 C) Washington, DC 20005 (202) 833-1200 v. MUR No. ___ DONALD J. TRUMP FOR PRESIDENT, INC. 725 Fifth A venue New York, NY 10022 DONALD TRUMP JR. d o The Trump Organization 725 Fifth A venue New York, NY 10022 COMPLAINT 1. This complaint is filed pursuant to 52 U.S.C. § 30109(a)(l) and is based on infonnation and belief that Donald Trump's 2016 presidential campaign committee, Donald J. Trump for President, Inc. (I.D. C00580100), and Donald Trump Jr. solicited a contribution from a foreign national in violation ofthe Federal Election Campaign Act ("FECA"), 52 U.S.C. § 30101, et seq. 2. Specifically, based on published reports, complainants have reason to believe that Donald J. Trump for President, Inc. and Donald Trump Jr. violated FECA's ban on soliciting a contribution from a foreign national in connection with a Federal election, 52 U.S.C. MUR726500002 § 3012l(a)(2), by meeting with a "Kremlin-connected Russian lawyer during the 2016 campaign" in an effort to obtain "damaging information about Hillary Clinton." 1 3. "Ifthe Commission, upon receiving a complaint ... has reason to believe that a person has committed, or is about to commit, a violation of [the FECA) ... [t]he Commission shall make an investigation ofsuch alleged violation ...." 52 U.S.C. § 30109(a)(2) (emphasis added); see also 11 C.F.R. -
Rob Goldstone
1 UNCLASSIFIED, COMMITTEE SENSITIVE EXECUTIVE SESSION PERMANENT SELECT COMMITTEE ON INTELLIGENCE, U.S. HOUSE OF REPRESENTATIVES, WASHINGTON, D.C. INTERVIEW OF: ROB GOLDSTONE Monday, December 18, 2017 Washington, D.C. The interview in the above matter was held in Room HVC-304, the Capitol, commencing at 1:35 p.m. Present: Representatives Conaway, King, Ros-Lehtinen, Gowdy, Stefanik, Himes, Quigley, Swalwell, Castro, and Heck. UNCLASSIFIED, COMMITTEE SENSITIVE PROPERTY OF THE UNITED STATES HOUSE OF REPRESENTATIVES 2 UNCLASSIFIED, COMMITTEE SENSITIVE Appearances: For the PERMANENT SELECT COMMITTEE ON INTELLIGENCE: For ROB GOLDSTONE: G. ROBERT GAGE, JR., ESQ. BERNARD W. OZAROWSKI III, ESQ. GAGE SPENCER & FLEMING LLP 410 Park Avenue New York, NY 10022 UNCLASSIFIED, COMMITTEE SENSITIVE PROPERTY OF THE UNITED STATES HOUSE OF REPRESENTATIVES 3 UNCLASSIFIED, COMMITTEE SENSITIVE Good afternoon. This is a transcribed interview of Rob Goldstone. Thank you for speaking with us today. For the record, I am a staff member of the House Permanent Select Committee on Intelligence. Also present today from HPSCI are a number of members and staff, who will identify themselves when they ask questions. Before we begin, I wanted to state a few things for the record. The questioning will be conducted by members and staff. During the course of this interview, members and staff may ask questions during their allotted time period. Some questions may seem basic. That is because we need to clearly establish facts and understand the situation. Please do not assume we know any facts you have previously disclosed as part of any other investigation or review. This interview will be conducted at the unclassified level. -
Fusion GPS Interim
Gauhar, Tashina (ODAG) From: Gauhar, Tashina (ODAG) Sent: Monday, April 23, 2018 2:24 PM To: JCC (JMD) Subject: Scan into TS system Att achments: Pages from Binder1_KMF.PDF Howard - thanks for taking just now. As discussed, I need these emailsscanned onto the TS system and emailed to me. Can you let me know when completed and I will go into the SCI F. Thanks for your help, Tash Document ID: 0.7.17531.18512 20190701-0008383 OIUUN G. HATI:H. UTAH OW.NC f l'\,STll"• CAI ·001," u r,DSEY o. GRAHAM sovn, CAROU-'1A P.A I RICIC J t.11Y Vl'RM0'-1 JOH!, COl!'IYN. "'EXAS Ror•RO J DURerr, rwe,;oes ''ICIIAE, S. lff:. I.IT AH SH[d>ON v.~ TUIOUSE, AltOOE IS~ND TED CR\iZ. ll:XAS All!Y KI.OSXHAR.11!,Nt..'UOTA BE'I 5.ISSE. ll.£8AAS<A C~R.ISTOPHCR A C~'S. Dfl,t,W~ tinttrd iSmtc.s ~cnatc J(ff fl.AK(. AR1lONA RIC!iARO l!l.u,,r,.rhAI CQ",f;("'lC\/T " <E CRJl1'<l, aOA>tU Ml'l • , >lf<O"'O• HAW• I COMMITTEE ON THE J UDICIARY lttOM lu.tS.hOAT>ICAROI.IP.A COIIY A. IOOKC,. f..[~•1 JCR£L "'f JOHN KfN~EDV LO\,, S!ANA KA'JALI' I>. HAIIRIS, CAl,lfo;lt, A WASHINGTON. DC ,0610-6276 Kov.tJLOA\,tt..Cbw/Cows./~ dSl~H°'1ad<N .;1ro ...,,n ouc."' ~0t,..tf'",qm1.,;•f'tdSr•lfOr.-.ctJ:r February9,2018 VIA ELECTRONIC TRANSMISSION PaulE.Hauser,Esq. Partner BryanCave 88WoodStreet London, EC2V7AJUK DearMr.Hauser: TheUnitedStatesSenateCommitteeon theJudiciaryhasbeeninvestigatingissues relatingtotheRussiangovernment’sdisinformation effortstargetingthe2016Presidential election,aswellas thenatureoftheFBI’srelationship withChristopherSteele. -
The Steele Dossier an Assessment of Allegations
THE STEELE DOSSIER An Assessment of Allegations Throughout the Russia investigation, the “Steele Dossier” has continued to command attention. The transcript of Carter Page’s testimony before the House Intelligence Committee on November 2, 2017 has refocused that attention where it belongs: on the substance of the report. Since BuzzFeed published the Steele Dossier in January 2017, subsequent reporting has confirmed or substantiated many of Steele’s claims. What is the Dossier? The Dossier is a human intelligence, or HUMINT, report and therefore should be viewed not as evidence to be used in a trial, but as a road map for investigators. Christopher Steele, the author of the Dossier, is an experienced and well-respected former UK intelligence officer who has served not only as an MI-6 officer but also worked on behalf of the FBI in the successful FIFA corruption investigation. Steele and the Dossier were credible enough for former FBI Director James Comey and Director of National Intelligence James Clapper to brief President Obama and then-President elect Trump on its contents. BuzzFeed’s decision to publish the Dossier has itself attracted a lot of attention. The Dossier is part of ongoing lawsuits filed by parties named in the dossier and may be part of congressional investigations. In analyzing the contents of the Dossier, it’s important to remember, as former CIA analyst John Sipher explained, that Steele was writing it in real time beginning in June 2016. The dossier largely contains intelligence related to internal Russian efforts to interfere in the election, not intelligence about the Trump campaign. -
In the United States District Court for the Southern District of New York
Case 1:18-cv-03501-JGK Document 216 Filed 01/17/19 Page 1 of 111 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK DEMOCRATIC NATIONAL COMMITTEE, ) Civil Action No. 1:18-cv-03501 ) JURY DEMAND Plaintiff, ) ) SECOND AMENDED v. ) COMPLAINT ) COMPUTER FRAUD AND ABUSE THE RUSSIAN FEDERATION; ) ACT (18 U.S.C. § 1030(a)) ARAS ISKENEROVICH AGALAROV; ) RICO (18 U.S.C. § 1962(c)) EMIN ARAZ AGALAROV; ) ) RICO CONSPIRACY (18 U.S.C. JOSEPH MIFSUD; ) § 1962(d)) WIKILEAKS; ) WIRETAP ACT (18 U.S.C. JULIAN ASSANGE; ) §§ 2510-22) DONALD J. TRUMP FOR PRESIDENT, INC.; ) ) STORED COMMUNICATIONS DONALD J. TRUMP, JR.; ) ACT (18 U.S.C. §§ 2701-12) PAUL J. MANAFORT, JR.; ) DIGITAL MILLENNIUM ROGER J. STONE, JR.; ) COPYRIGHT ACT (17 U.S.C. ) JARED C. KUSHNER; § 1201 et seq.) GEORGE PAPADOPOULOS; ) ) MISAPPROPRIATION OF TRADE RICHARD W. GATES, III; ) SECRETS UNDER THE DEFEND ) TRADE SECRETS ACT (18 U.S.C. Defendants. ) § 1831 et seq.) ) INFLUENCING OR INJURING ) OFFICER OR JUROR GENERALLY ) (18 U.S.C. § 1503) ) ) TAMPERING WITH A WITNESS, ) VICTIM, OR AN INFORMANT (18 ) U.S.C. § 1512) ) WASHINGTON D.C. UNIFORM ) TRADE SECRETS ACT (D.C. Code ) Ann. §§ 36-401 – 46-410) ) ) TRESPASS (D.C. Common Law) ) CONVERSION (D.C. Common Law) ) TRESPASS TO CHATTELS ) (Virginia Common Law) ) ) ) Case 1:18-cv-03501-JGK Document 216 Filed 01/17/19 Page 2 of 111 CONSPIRACY TO COMMIT TRESPASS TO CHATTELS (Virginia Common Law) CONVERSION (Virginia Common Law) VIRGINIA COMPUTER CRIMES ACT (Va. Code Ann. § 18.2-152.5 et seq.) 2 Case 1:18-cv-03501-JGK Document 216 Filed 01/17/19 Page 3 of 111 TABLE OF CONTENTS Page NATURE OF ACTION ................................................................................................................. -
Document Requests
Tony Fabrizio DOCUMENT REQUESTS Please produce the documents set forth in Schedule A, provided, however, that in order to facilitate production of documents on an expedited basis, you may limit your production at this time to documents you furnished at any time after November 8, 2016 to: (a) the Special Counsel’s Office established by Department of Justice Order No. 3915-2017 (May 17, 2017); (b) the United States Attorney’s Office for the Southern District of New York (“SDNY”); (c) any other federal or state regulatory and/or law enforcement agency; (d) any congressional committee; or (e) in civil or other litigation. This includes but is not limited to documents that were voluntarily provided, produced under compulsion, or seized. Instructions for producing documents appear in Schedule B, and definitions appear in Schedule C. SCHEDULE A 1) All documents relating to the following: (a) Any loan, financing transaction, or capital investment by the Russian Federation, any Russian national, any Russian business, or any other Russian entity to the Trump Organization, Donald Trump, Ivanka Trump, Jared Kushner, or any of their Business Interests. This request shall include the period from January 1, 2015 to the present and shall exclude documents relating to the purchase of individual condominium, cooperative, or apartment units. (b) Trump Tower Moscow (also known as the “Moscow Project”) or any other proposed or possible real estate development in the Russian Federation by Donald Trump or the Trump Organization from January 1, 2015 to the present. (c) The June 9, 2016 Trump Tower meeting (the “Trump Tower meeting”), including but not limited to contacts or communications about the meeting involving one or more of the following individuals: Donald Trump Jr., Natalia Veselnitskaya, Donald Trump, Paul Manafort, Jared Kushner, Emin Agalarov, Aras Agalarov, Goldstone, and/or Rinat Akhmetshin. -
Trump Just Made 2 Problematic Admissions About the Trump Tower Meeting by Aaron Blake the Washington Post August 5, 2018
Trump just made 2 problematic admissions about the Trump Tower meeting By Aaron Blake The Washington post August 5, 2018 Trump did not dictate the Trump Tower response. Until he did. President Trump's lawyers now say he dictated Donald Trump Jr.'s response to the 2016 Trump Tower meeting, contradicting months oF previous assertions. (JM Rieger/The Washington Post) President Trump has yet again tweeted about his personal legal issues in a way he perhaps shouldn't have. The Washington Post reported Saturday that Trump had expressed concerns in the past week about his son Donald Trump Jr.'s legal exposure From the 2016 Trump Tower meeting. In a tweet about that report on Sunday, Trump said, “This was a meeting to get inFormation on an opponent, totally legal and done all the time in politics - and it went nowhere. I did not know about it!” Two issues. The First is that Trump appears to have broken some new ground here when it comes to admitting the true purpose oF the Trump Tower meeting with a Kremlin-aligned lawyer — and even Further contradicted the initial statement he helped draFt about it. At the time, Donald Trump Jr. issued a statement explaining that he and the lawyer, Natalia Veselnitskaya, had “primarily discussed a program about the adoption oF Russian children.” We have since discovered that the elder Trump actually dictated that statement. Quickly, though, that explanation Fell apart, and we learned that Trump Jr. had actually been promised harmFul inFormation about Democrats, including Hillary Clinton. The president himselF seemed to shrug it oFF, saying in July 2017 that, “from a practical standpoint, most people would have taken that meeting.” He added: “It’s called opposition research or even research into your opponent.” (Trump also tweeted along these lines.) But at the same time, he still suggested that the meeting was, in large part, about adoption. -
Appendix to Considering Collusion: a Primer on Potential Crimes October
APPENDIX TO CONSIDERING COLLUSION: A PRIMER ON POTENTIAL CRIMES OCTOBER 31, 2018 BARRY H. BERKE, DANI R. JAMES, NOAH BOOKBINDER, AND NORMAN L. EISEN* This document lists in chronological order the key known facts relating to the Russia investigation that are potentially relevant to the collusion crimes discussed in our paper. The items in this chronology are drawn from public sources, including legal filings, newspaper articles, congressional testimony, social media posts, and interview transcripts that were available at the date of publication. Abbreviated chronology of key facts 2014: According to a federal indictment filed on February 16, 2018, beginning as early as 2014, Internet Research Agency LLC conducts operations to interfere with the U.S. political system, including the 2016 presidential election. These efforts are financed by Yevgeniy Viktorovich Prigozhin and companies he controls, including Concord Management and Consulting LLC and Concord Catering. 13 individuals allegedly worked at Internet Research Agency to carry out its interference operations.1 “In or around” 2015: Internet Research Agency and its agents begin to purchase social media advertisements as part of their efforts to influence American politics.2 June 16, 2015: Donald J. Trump announces his candidacy for president.3 Early-to-Mid 2016: According to court filings, Internet Research Agency LLC develops “a strategic goal to sow discord in the U.S. political system, including the 2016 U.S. presidential 1 Indictment, U.S. v. Internet Research Agency, No. 18-cr-32 (D.D.C. Feb. 16, 2018) (henceforth “Russian Interference Indictment”) at ¶¶ 1-3, https://www.justice.gov/file/1035477/download. 2 Id. -
November 2, 2017
1 UNCLASSIFIED, COMMITTEE SENSITIVE EXECUTIVE SESSION PERMANENT SELECT COMMITTEE ON INTELLIGENCE, U.S. HOUSE OF REPRESENTATIVES, WASHINGTON, D.C. INTERVIEW OF: IKE KAVELADZE Thursday, November 2, 2017 Washington, D.C. The interview in the above matter was held in Room HVC-304, the Capitol, commencing at 3:20 p.m. Present: Representatives Conaway, Rooney, Himes, Speier, Quigley, UNCLASSIFIED, COMMITTEE SENSITIVE PROPERTY OF THE UNITED STATES HOUSE OF REPRESENTATIVES 2 UNCLASSIFIED, COMMITTEE SENSITIVE Swalwell, and Heck. UNCLASSIFIED, COMMITTEE SENSITIVE PROPERTY OF THE UNITED STATES HOUSE OF REPRESENTATIVES 3 UNCLASSIFIED, COMMITTEE SENSITIVE Appearances: For the PERMANENT SELECT COMMITTEE ON INTELLIGENCE: For IKE KAVELADZE: SCOTT S. BALBER, ESQ. JOHN J. O'DONNELL, ESQ HERBERT SMITH FREEHILLS NEW YORK LLP 450 Lexington Avenue 14th Floor New York, NY 10017 UNCLASSIFIED, COMMITTEE SENSITIVE PROPERTY OF THE UNITED STATES HOUSE OF REPRESENTATIVES 4 UNCLASSIFIED, COMMITTEE SENSITIVE Good afternoon, this is an unclassified transcribed interview of Ike Kaveladze. Mr. Kaveladze, thank you for speaking with us today and we apologize for the delay in getting started. For the record, I'm a staff member of the House Permanent Select Committee on Intelligence. Others present today will introduce themselves when they speak. Before we begin, I just want to confirm that you've all left all of your electronics outside? Is that correct. MR. BALBER: That's right. MR. O'DONNELL: Yes. And before we move on to questions, I'll state a few things for the record. The questioning will be conducted by staff, and also by Members during the allotted time period. Some of the questions may seem basic, but that is because we need to clearly establish facts and understand the situation. -
Document Requests
Michael Caputo DOCUMENT REQUESTS Please produce the documents set forth in Schedule A, provided, however, that in order to facilitate production of documents on an expedited basis, you may limit your production at this time to documents you furnished at any time after November 8, 2016 to: (a) the Special Counsel’s Office established by Department of Justice Order No. 3915-2017 (May 17, 2017); (b) the United States Attorney’s Office for the Southern District of New York (“SDNY”); (c) any other federal or state regulatory and/or law enforcement agency; (d) any congressional committee; or (e) in civil or other litigation. This includes but is not limited to documents that were voluntarily provided, produced under compulsion, or seized. Instructions for producing documents appear in Schedule B, and definitions appear in Schedule C. SCHEDULE A 1) All documents relating to the following: a) The June 9, 2016 Trump Tower meeting (the “Trump Tower meeting”), including but not limited to contacts or communications about the meeting involving one or more of the following individuals: Donald Trump Jr., Natalia Veselnitskaya, Donald Trump, Paul Manafort, Jared Kushner, Emin Agalarov, Aras Agalarov, Goldstone, and/or Rinat Akhmetshin. b) Any contacts, direct or indirect, from January 1, 2015 to January 20, 2017 between or involving the Russian Federation and its officials, agents, intermediaries, and/or instrumentalities and any of the following: Donald Trump, the Trump Campaign, the Trump Organization, Paul Manafort, Rick Gates, Michael Cohen, Michael Flynn, Jeff Sessions, Jared Kushner, Thomas Bossert, Roger Stone, Jerome Corsi, George Papadopoulos, Carter Page, Konstantin Kilimnik, K.T. -
Document Requests
George Papadopoulos DOCUMENT REQUESTS Please produce the documents set forth in Schedule A, provided, however, that in order to facilitate production of documents on an expedited basis, you may limit your production at this time to documents you furnished at any time after November 8, 2016 to: (a) the Special Counsel’s Office established by Department of Justice Order No. 3915-2017 (May 17, 2017); (b) the United States Attorney’s Office for the Southern District of New York (“SDNY”); (c) any other federal or state regulatory and/or law enforcement agency; (d) any congressional committee; or (e) in civil or other litigation. This includes but is not limited to documents that were voluntarily provided, produced under compulsion, or seized. Instructions for producing documents appear in Schedule B, and definitions appear in Schedule C. SCHEDULE A 1) All documents relating to the following: a) The June 9, 2016 Trump Tower meeting, including but not limited to contacts or communications about the meeting involving one or more of the following individuals: Donald Trump Jr., Natalia Veselnitskaya, Donald Trump, Paul Manafort, Jared Kushner, Emin Agalarov, Aras Agalarov, Rob Goldstone, and/or Rinat Akhmetshin. b) The “Republican Platform 2016” provisions relating to Russia and Ukraine, including, but not limited to, the exclusion of language related to providing lethal defensive weapons to Ukraine and the inclusion of language about providing “appropriate assistance” to the armed forces of Ukraine. c) Discussions or attempts to provide or receive election information, campaign data, or campaign communications with, to, or from foreign entities or individuals in connection with the 2016 U.S. -
The Scope of the Foreign National Spending Ban in Campaign Finance Law
CAN “LOVE” BE A CRIME? THE SCOPE OF THE FOREIGN NATIONAL SPENDING BAN IN CAMPAIGN FINANCE LAW Zachary J. Piaker * Federal campaign finance law prohibits foreign nationals from making contributions or expenditures of “money or other thing of value” in connection with American elections and prohibits anyone from solic- iting such a contribution or expenditure. The revelation that officials from Donald Trump’s 2016 presidential campaign met with Russian nationals after being told they would receive “information that would incriminate” Hillary Clinton, Trump’s political opponent, raised the question of how broadly the foreign national spending ban extended. This Note uses the circumstances of the June 2016 meeting to examine the scope of the foreign national spending ban. It analyzes whether “thing of value” should be construed to encompass intangibles such as information about a political rival. It then questions whether a broad reading of the statute would violate the First Amendment. It con- cludes by suggesting ways in which institutional actors such as the courts, Congress, and the Federal Election Commission might consider clarifying this area of the law. INTRODUCTION In June 2016, a number of officials from Donald Trump’s presiden- tial campaign—including Donald Trump, Jr., Paul Manafort, and Jared Kushner—attended a meeting with Natalia Veselnitskaya, a Russian law- yer who offered to share documents that “would incriminate Hillary [Clinton] and her dealings with Russia and would be very useful to [Donald Trump] . [as] part of Russia and its government’s support for Mr. Trump.”1 The meeting’s public disclosure a year after its occurrence immediately sparked a debate over the legality of what had transpired.2 This Note joins that debate by examining several of the questions arising from the meeting’s circumstances.