llrn rrrt 5urcs - just security · 8/22/2017 · cunningham levy muse llp 1250 connecticut ave,...

l lrn rrrt 5urcs 5 rnatt

August 3, 2017

VlA ELECTRONIC TRANSMISSION

Joshua Levy Cunningham Levy Muse LLP 1250 Connecticut Ave, N.W. Washington, D.C. 20036

Dear Mr. Levy:

' :S,, ;°if· .· .. 1 ·! • • • -:·

EXHIBIT

We are writing to confirm our agreement for the Committee's interview of your client, Glenn Simpson:

1 . The interview will take place in room 181 of the Dirksen Senate Office Building at 9:30 a.m. on August 22, 2017.

2. The interview will be conducted by Majority and Minority staff officers of the Senate Committee on the Judiciary. Members of the Committee may attend and participate.

3. The interview will be transcribed. 4. This interview is occurring 'wi thout prejudice to any future discussions with this

Committee, and the Committee expressly reserves the right to request Mr. Simpson's participation in future interviews or to compel his testimony.

5. Mr. Simpson ' s participation in this interview docs not constitute a waiver of his ability to assert any privileges in response to future appearances before this Committee.

6. Mr. Simpson and his attorneys will make their best efforts to produce documents as far in advance of the interview as possible that are: (a) responsive to the Committee's July 19, 2017 document request, (b) pertinent to the scope of the interview, and (c) responsive to priorities identified by the Committee during ongoing discussions about the document request.

7. The scope of this initial interview will include, at a minimum, matters related to: a. The information requested in questions 5- 13 in the March 24, 2017 letter from

Chairman Grassley to Mr. Simpson; and b. The information requested in questions 6 and 7 in the July 19, 2017 letter from

Chairman Grassley to Mr. Simpson. Any additions to the scope may be negotiated in good faith by the parties.

Charles E. Grassley Chairman

Sincerely,

Dianne Feinstein Ranking Member

EXHIBIT

?: 8 -~jo:;>, I .. ) r 0:. ,

08.17.2017 Privilege Log in Response to ReQuest for Internal Communications Related to Fusion GPS Communications with Conj?ressional Memoc1:. o, v•-· · - - -- --.

Date Sent Email From Email To Email CC

5/13/16 Rinat Akhmctshin Mark Cymrot Ed Licbennan; Glenn Simpson

5/13/16 Rinat Ak.hmetshin MarkCymrot Glenn Simpson; Ed Liebennan

5/13/16 Mark Cymrot Rinat Akhmetshin Glenn Simpson; Ed Liebennan

5/ 16/16 Loura Alaverdi Mark Cymrot; Glenn

Simpson

Rinat Akhmetshin; Ed

5/16/16 Mark Cymrot Glenn Simpson Lieberman; Loura Alaverdi; Paul Levine; Molly Levinson; Ryan Toohey Rinat A.khmetshin; Ed

5/16/16 Glenn Simpson Mark Cymrot; Lieberman; Loura Alaverdi; Paul Levine; Molly Levinson; Ryan Toohey Mark Cymrot; Rinat

5/16/16 Paul Levine Ak.hmetshin; Ed Lieberman;

Glenn Simpson; Loura Alaverdi

Rinat Akhmetshin; Ed

5/16/16 MarkCymrot Paul Levine Liebennan; Glenn Simpson; Loura Alaverdi;

Mark Cymrot; Rinat

5/16/16 Paul Levine Ak.hmetshin; Ed Lieberman; Glenn Simpson; Loura Alaverdi·

RELEASED BY AUTHORITY OF THE CHAIRMAN OF THE SENATE JUDICIARY COMMITTEE Eoflfidefltial fer Proauetiofl to SeAate Judiciarv CoFAFAittee Only

Subject/Description Privilege Asserted Basis for Claim

Confidential communication

Re: Appointment with Cong. Attorney Work Product

performed at the direction of

Hill counsel in anticipation of litigation Confidential communication

Re: Appointment with Cong. Attorney Work Product performed at the direction of

Hill counsel in anticipation of liti11ation Confidential communication

FW: Appointment with Cong. Attorney Work Product

perfonned at the direction of

Hill counsel in anticipation of liti2ation Confidential communication

Re: Collection of Press Attorney Work Product


Stories counsel in anticipation of litigation Confidential communication

Collection of Press Stories Attorney Work Product performed at the direction of counsel in anticipat ion of litil!ation Confidential communication


perfonned at the direction of


Re: National Review Attorney Work Product performed at the direction of

counsel in anticipation of litisrntion Confidential communication

Re: National Review Attorney Work Product performed at the direction of counsel in anticipation of liti2ation Confidential communication

RE: National Review Attorney Work Product performed at the direction of counsel in anticipation of litigation

1


Mark Cymrot; Rinat

5/16/16 Paul Levine Akhmetshin; Ed Lieberman; Glenn Simpson; Loura Alaverdi;

Glenn Simpson;

5/16/16 MarkCymrot Loura Alaverdi R.inat Ak.hmetshin; Ed Lieberman

5/16/ ]6 Loura Alaverdi Mark Cymrot; Glenn Simpson

5/17/16 Mark Cymrot Rinat Akhmetshin; Ed Loura Alaverdi; Paul Levine Liebennan; Glenn Simpson

Paul Levine; Rinat

5/ 18/ 16 MarkCymrot Akhmetshin; Glenn Simpson; Loura Alaverdi; Ed Lieberman

5/ 18/J 6 Mark Cymrot

5/J 8/ 16 Mark Cymrot

5/18/ 16 Mark Cymrot

5/18/ 16 Mark Cymrot

5/ 18/16 MarkCymrot

RELEASED BY AUTHORITY OF THE CHAIRMAN OF THE SENATE JUDICIARY COMMITTEE CoAfiaeAtial for Proa1,1EtioA to Senate J1,1aiEiarv (91'.J'lrAitt@@ Onlv

Subject/Description Privilege Asserted Basis for Claim


RE: National Review Attorney Work Product performed at the direction of counsel in anticipation of litigation Confidential communication




RE: Collection of Press Attorney Work Product



FW: United States v. Attorney Work Product performed at the direction of

Prevezon counsel in anticipation of litigation

Fwd: Important message from Confidential communication

Bill Browder about Sergei Attorney Work Product


Magnitsky before HFAC counsel in anticipation of

mark-un litigation

Re: Important message from Confidential communication Bill Browder about Sergei

Attorney Work Product performed at the direction of


mark-uo litigation


Bill Browder about Sergei Attorney Work Product performed at the direction of

Magnit.sky before HF AC counsel in anticipation of

mark-uo litigation

Re: Important message from Confidential communication Bill Browder about Sergei

Attorney Work Product performed at the direction of


mark-uo litigation

Re: Important message from Confidential communication



Magnitsky before HF AC counsel in anticipation of

mark-uo litil!.ation





mark-uo litieation

2


Paul Levine; Ed Lieberman;

5/18/16 Mark Cymrot Rina! Akhmetshin; Loura

Alaverdi; ; Glenn

Simoson

5/20/16 MarkCymrot Paul Levine; Loura Alaverdi; Rinat Akhmetshin; Ed

Glenn Simpson Lieberman

Peter Fritsch MarkCymrot Glenn Simpson

10/27/16

Peter Fritsch Mark Cymrot Glenn Simpson

10127/16

RELEASED BY AUTHORITY OF THE CHAIRMAN OF THE SENATE JUDICIARY COMMITTEE ConfiaeRt ial for Proa1:Jction t o Senate h,1Eliciarv Committee Onlv

SubjecUDescrrption Privilege Asserted Basis for Claim





mark-un litigation

FW: Statement in Response

to Representative Dana Confidential communication

Rohrabacher's Remarks at the Attorney Work Product


House Foreign Affairs counsel in anticipation of

Committee Mark-up on litigation

Global Ma,mitskv Confidential communication

Fwd: Collection of Press Attorney Work Product

performed al the direction of

Stories counsel in anticipation of

litiization


Fwd: Collection of Press Attorney Work Product performed at the direction of

Stories counsel in anticipation of

liti2atioo

3

f • ' - t CONFlDENTIAL/SliNSITIVE SOURCE EXHIBIT

COMPANY JNTELIJGENCE REPORT 2016/080

US PRESIDENTIAL EtECTION: REPUBLICAN CANDIDATE DONALD TRUMP'S ACTIVITIES lN RUSSIA AND COMPROMISING RELATIONSHIP WITH THE KREMLIN .

Summary

Russian regt~e,has.been .cultivating. s·upportlng and a'sslsting·TRU~PJor at least S'ye#l.rs:·A1m,.endorsed by PUTIN, has been to encourage.splits and divisions In western alliance

· So far TRUMP has d·eclln~d various sweetener real estate business deals offered him In Russia in order to further the Kremlin's cultivation of him. However he and his inner circle have·accepted a regular flow of Intelligence from the Kremlin, including on hls Democratic and other political rivals ·

Former top·Rl,lsslan 'intelligence officer cl~lm~ FSB. has .c9~prom.ls~d TRUMP through his activities in Moscow sufflcle.ntly t.o be a~le ~o . . blackm·a11 him. Accord!ng to several knowledgeable sou_rces, his co~~uc~ · . · In Moscow.has included perverted sexual acts which have been · .. ·.' · . . ; : arranged/monitored by the FSB

. -· . A dossier of compromising material on Hillary CLINTON has bee·n collated · · · by the Russian Intelligence Services over many year.s-and)natn}Y, comprises bugged conversations she ~ad on varfous-~l~:to-Russla_and in~rcepted phone calls:rather than any embarrasstng·cpndutt The dossier is controlled by Kremlin spokesman~ PESKOV;'·ciJrectly on .. i>QTtN's orders. However it has. not as yet been. di~trlbut~d abroad; .. in~llidlng to . TRUMP. Russian.Intentions for Its (Jeployment still unclear . . .

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Detail . . ..... ·. . .. · .... ·:, .· : : ... ··.· <: . ··: ... :.:. _- :_./_/\>.:·.\\ .. ) .::\~{.::·.'.·>_:.. -"'·. 1. Speaking·\~ a :trus.ted cQ_mpatr.iot.hfJuhe ·2016. ·soµr,ces· Aal;ld :B],a·senfo{-. ·. · . . '

Rus~ian·. f oreign_}f 1.~istry ,(igur,i:~-~~(~ .fo r.rrie.riqp;i~v,etRµssi~i{;:,; · ... · ·... . . ;· ·. .· ... lnte~lgeo~ .. ~~c~t.~11:~c.li~e.hi.$..ld,~\be Kr~.W.1!J:(~~li~~V.~ly/t'fie;Russlan: . ·· · . ·: · ·:: . ~utho.rl_~~,.~.~~:~~e~-c~.l.tj~tl~g ·,~~:~lp~~r~!#~~~:~~~~li~~~::·,· .. :.:'· .. .:,;. :·.·:.: : . ·.; .. , presiden.~1~.1 ;~ .n~fdat~f Ponald TRUl\:1? for .atJeast-:5: ye.~rs)S0'i1rce B- . _. · · · a~se~ted ~,~:.t4.e.::fR~:Mf:' ~~-ei:a~.9~~~as b~t~ sujippr.te(~ntl 'dit~cted by. . Russt~n P~~i·~-~~ .. ~,;V_l.adi~tnPU'.[lt~f.J,~ ai~·was-t<> sow:di~eord\~nd · . · ··

. ··.··.~9~~inL1.~~~l~SOUR~i ••• : •• · .. . ·.· ..

i. • j•ti: .. ;';;l;{Jj(;ii.;i !}!:ti! . :;~j:;;j:t1 / : '. •• ·. • · .. · ....•. ; _ · .. · .. CONFIDENTIAL FOR SENATE JUDICIARY COMM. PRODUCTION ONLY CLMSJC00041391

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CONFIOENTlt\t./SENS IT IVE 'iOUHCE

dis11111ry holh within the US it-;clf, hut mor1· especially w11hi 11 the Trnn,;atbntic alliance which was viewed os 1nlmlcal to Ru!i~ia's inwrcsl'i Source C:, a senior Russian li11.11ici.il official. alt.I the TRU MP opennion should Ill· seen in terms or PUTIN's desire t , return ro Ninl'Lct:nth Century ·r.rc:n Pc,wcr' politics anchored up.,u c.m111t11es· imcrcsls rr1tltt'r 1 h..in lht· 1<lcals-b,ised intl.'rnt1t1011al ordl!r ,_...t.iblisltt:J after World War Two. S/lw had overheard PUTIN talking 111 ~his way to close ns~oci.:itc:s on several occnslons.

2 In terms 11f spec1f1cs. Sourrc A con11dcd th it the Kn:mlln h.id been feeding TlWt.lJ> .ind his t•·.im valuable intell igf'nc1 1,11 l11s uppontnt.'i, 111dt1ding 01..•mocratic prcs1denwll r,rnclidJlc Hillary 1:L1NTON, for several years (se~ more below). This wa,; confi rmed by Sciurcc D. 11 close a5~ociate of TfHJ~I P who had organized a11d managed his recent trips to Moscow, and who reported. also ill June lO 16, th:1l thb Rus:,l:111 intelligence had been ··very h.:-lpiul ". The Krl'mlin's cultivation 1•pe1-.1uun on THUMP alsn had rnmpr1$l'U otfe1 mg htm v,1rn,w. lt1cral1vL· 1 ~al cstalc devdopmenL hustncss deal~ in Hussin, Pspedal!y in rel 1' ion to I he ongoi ng 2018 World Cup socce r tourn.1ment. llowi.•ver, :.o far, lor n.:aso11s unknown. TRUMP h..id not t,1k,'11 up any of Llwse.

:!. Huwevt-r, there were other .1spccts l<> Tr, l 'M P's engagement with the RussiJn authoritks. One which h..id born, fruit for them was to rxploll TRllMP's pe, sonal obsessions and sexual P<:rvcrsion rn order to obtain suitablt• 'kompromtll' (wu1promblng m .:lcrial) on him. According to Sounc D, whert' s/he had lwen present, I RUMP's (perverted) conduct in Mosco\,\ tncluded hit mg t hl, prc3idetllia'. -.uite ol Lhe Ritz Carlton Hotel. ,, ncre he knew Prcs1dcnl nod Mrs OBAM.\ (whom he hattc.l) had stayed on one of th<.:ir uffidal trips w Rus'iia, a111' ddiling the bed where they had slept by e1nploying a numb~, ol prostillttvs to perform a 'golden showers' (urination) show in front of him. The ho t,·l was known to be under FSB control with microphones :md concealc I cameras In all t.he mam rooms tn record anything they w,111ted to.

-I The Moscow Ritt Carll t

wnfirmed by Source E, wl10 ,;aid th:it sflw and sevt'rt1l or the st.1! r werl' aware ot it al t e L11ne and sub:,.equl·ntly. S/he believed it had ~1.1ppct1cd in ~013. Source E provided .m mtroduction for a company eLhnk Russian operative to Sottr'ce F, a fl•mnlc staffer .it the hotel wli~n TROMP had stayed there, who ~lso confirmed Litt.! slory. Speakiug scp .. 1 :-itely m June 2016. Source 13 (lite tormc:r top level Rus.sian intell1genre oll· ·er) ,isscrLed that TRUMP's unorthodox behavior in Russia over th · ·,•ears had provided thl' authorities there with enough ernbarrc.: :, ,Ing material on the now R~publican presidentia l candidate to b } .1ble to blackmail him if they so w1she-u.

5. Asked nbout Lhe Kremlin's reported in.Llligcnce feed to TRUMP over recent years and rumours about a Rus --.1.1n dossier of 'kornpromal' 011

CONFIDENTIAL/SENSITIVE SOURCE

· M lvv . <;J Ol'JLY RELEASED BY AUTHORITY OF THE CHAIRMAN OF THE SENATE JUDICIARY COMMITTEE

CONFIDENTIAi - EQR SENLITE JUDICl"Rv COHH PRODUCTIO CLMSJC00041392

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Hillary CLINTON (being rirl'ul:lwd), Sow·ce r3 confirmed the nte's t!Xistcnce. S/he confided In a trusted co mpatriot that it had been collated oy Dcpanmcm K oft he FSB for many years, dating back tn h<.·r husband Bi!l's prcsldtmcy, and comprised 11iainl ·: ,•avesdropped co11v1.m,a1ions of various sorts rntlwr than dt•tails/evide ll. e or ,inorthodox or embarrassing behavior. So111c Clf the conversations were from hugged comments CLINTON had made on her v,1rious trips to Russia and focused on things she had said which rn11 1radic: t,•d her current position on various isl.ucs. Others were most probably rrot!I phone inten:cpls.

6. Continuing on this theme. Source G, a sen ior Kremlin official. confided that Lhe CLlNTON <lossier was controlh·d exclusively by chie f Kremli n spokesman, Dmltriy PESKOV, who was r~sponslble for compiling/hand ling It on the ex-plicit in,;: ruction:; of PUTIN himself. T he dossier however had noL as yet been 111.1d e av:iilable abroad, including Lo TRUl\1P or his caltlpaign team. J\l prcsc11L 1t w.is unclear what PUTIN's i11tent io11:, were in this reu:ird.

20 Ju ne 2016

CONFIDENTJAL/SENSITI VE SOURCE

COJIJFIDEf~TIAL- FOR SENATE JUDICIARY COMM PRQQl JCTION ONLY

RELEASED BY AUTHORITY OF THE CHAIRMAN OF THE SENATE JUDICIARY COMMITTEE

CLMSJC00041393

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CONFIDENTIAL/SENSl1'lVE SOURCE

COMPANY INTEUIGENCE REPORT 2016/086

RUSSIA/CVBER CRIME: A SYNOPSIS OF RUSSIAN STATE SPONSORED AND OTHER CYBER OFPENSIVE (CRIMINAL) OPERATIONS

Summary

- Russia has extensive programme of shltt'·sponsored offensive cyber operations. External targets Include foreign governments and big corp!)rations, especially banks, FSB leads on cyber within Jlussian . apparatus. Limited success In attacking top foreign targets like G7 governments, security servic~s.and lfls but ~uch ~ore oi:r.second tier ones through JT back. doors, usi.ng corporate and oth·er visi.~rs ·to Russia

FSB often uses coercion and blackmail to ·recruit most capable ·cyber operatives In Russia into its state-sponsored programmes. Heavy use also, both wittingly and unwittingly, of Cl~ cmlgres working In western corporations and ethnic Russians employed by neighbouring governments e.g. Latvia . .

· Example .cited of successful Russian. cyhe~. operatlo~· ~rg~ti~g senior . West.em bu·stness visitor. Provided back ~oor .i_nto lnip~rtant Western insttrutions.

Example given of us citizen ofRussian origin.appr:oach~d.b~ PSB and offered incentive of "investment" in his b~in~s whe~\is!ting ~oscow.

Problems however for Russia~ aut~orities them~el_ves.lil co.un~e~lng local . hackers and cyber criminals, operati~g ou~\de sta~fc9~tiQJ_.:Ceittr~·Bank claims there were over 2o·serlou.s .at?clcs on ~orr~.sP,oi)~~tkacc.ounts · held by CBR tn 2015, compri.sf~g Roµblcs several ~Uliqn.tp fraud ·

.. : . : .. . ~· ' ' • ·•• . • .. ·.·' ;' :; · . . ~ ·<. ·.: . ........ !..~ ,?.;:.. . . .

Some ~etails gfven·of leading. non~~tc 1'~:s~i,an cybe,r ·c_rtajlti~l:'group·s · . . . . ~ ' . . . .·· . . . ... . .. . ~ . .

Details . . . . ' ; .

1. Spe~ng. ~n J~~. 2016~,a ~u~~~f _'~t~us~i~1f~k4~~iijtll}.~~,d~~ll:ed . · .. · ·. · . ·. ~owled$e:of-~.a~o~i11 .o/ber :~ffi~?~:bt~)tat~sP.<>.*-~~i},f~nch,theiwise, · .. : .... ou~b)ed ~e curr.e11t$1~a_ti~P;!tj,J~~fare~;AJorm~·t;~eni'or, iri~lllgence · ·. ::: .. offip~r- di_~.~e-~··R'1$s,la~:St:a~~~POJiiaj'e d'.offenslv~ :cy~·er: 9.t>'e·rations· info. :· · ·

. ft?.~~ c~teg~~t~, .. Q~t~~~:~2 .. ~r:·~ij~-~~).f t~ge#ngJ~t.~f~f~~p,~t~lly' .. ·, . .-. .. ·~: ;. <: .: ... );; ::i.:t\._:.t:t:~;~(?;\liW;PJ~· !??L/ _. ... ,,:·t/\:.?:\· .. / :· ·. ·: . · :· ... :.: >:::. /·:· .. · .. . · · · · ·· .. · ···· , -:~0NPID6NT~SENS1Trvt .. souacir·· : .. > .. ~::. · · · ,·. · :<·1

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~~.~~';i~~Fii~~f~~t~~i;t)}JBR~~~-~~~dit':_·,_·~~M~J~i~a.';L·•·.··. · . RELEASED BY AUTHORITY OF THE CHAIRMAN OF THE SENATE JUDICIARY COMMITTEE

,• .. CONFIDENTIAL/SENSITIVE SOURCE

western governments; penetrating leading foreign business corporations, especially banks; domestic monitoring of the elite; and attacking political opponents both at home and abroad. The former intelligence officer reported that the Federal-Security Servlc~ {PSB) was the lead organization within the Russian state apparatus for cyber operations.

2. In term~ of the success of Russian offensive cyber op~rations to date, a senior government figure reported that there had been only limited success In penetrating the "Orst tier" foreign targets. These comprised western (especially G7 and NATO) governments, security and intelligence services and central banks, and the 1Fls.1'o compensate for thls shortfall, massive effort had been invested, with much greater success, in attacking the "secondary targets", particularly western private banks and the governments of smaller states allied to the West S/he mentioned Latvia in thls regard. Hundreds of agents, either consciously .cooperating wlth the FSB or whose personal and professional IT system~ h·ad been · : unwittingly compromised; were recruited. Many were people who _had · · ethnic and family ties to -Russia and/or had been incentivized financially to cooperate. Such people often would receive monetary inducements or contractual favours from the Russian state or its agents in return. This had created dlfficulties'for parts of the Russian state apparatus ln obltging/indulglng them e.g. the Central Bank of Russia knowingly having to cover up for such agents' money laundering operations through the Russian financial system .

. 3. ·. ,n terms of the FSB's recruitment of capable cyber operatives to carry out · its,·Jdeally deniable, offensive cyber operations, a Russian IT speclaltst . 'with direct knowledge reported In June 2 o 16 that this was often done using coercion and blackmail. In terms of 'foreign' agents, the FSB was

· approaching US citizens of Russian Oewish) ~rig~n on business trips to Russia. In one case :i US citizen of Russian ethnicity_ had· b~e·n visiting . Moscow to attract investors in his new infu'rmad~n tech!tology.pi:pg~~:: The FSB clearly knew .thls·and had offered tcf pro~d.e-~eed c.~pltaf.tc{tl)ls person In returri for th.eh) bei~g able to ·_acres~ _arid)n9dUy.hisJP; .wlth·a'·:' view to targeting priority foreign targets by.planting a ·Trojatl'.Vlrus ln:the software. The us visitor was told this was common practice .. The FSB also had implied slgn.ificant operational success as a.result ofinstalling cheap Russian JT games containing their own malw~re unwittingly by targets on their PCs and other platfonns. · · · .·. . .

4. Jn a more advanced an_d successful FSB _oper,at_lo;11, an.IT _operator ti1sJde a . leading Russian SOE, who previously hB;d been em.p_loyed on conventional ·. ( defensi.ve) IT WOfkth~r:e, had been. u~.dt!r ili$tj'.~_cti9:~. (~r t,he last y¢ar to . condu~ an f;)ffensly, .Cf.Q~ 9pe~ati~l'.l-~~in~t ~ ~qreign. ·~i.J'.ector of the . ·; ~om_pany: Al~9~~bJ~~ .1.~~er w~~ ap~~entlf~ij)~fl,:equen~ v.isitQr-to ·'.· . .. Russia, the-FS~: now .s1:1c~essfully had)~Jl t: t@~~,12,~~J>e~onall'f: antf. · . : through this h~~ mana;~4;to_ac~s:var:tous·irnpqrtai\tlnstltutions in the .. ·

.. •. •, . ( . --; · ..... . :.· . . _::,..·..: • ' ··.~-: ;~ :~. :,:· ··: .. : . •. . . . . . . .• ...

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5. In terms of oLher technical IT platform~ an FSB cyber operative f1agg1:d up the 'Telegram' enciphered comrner• .I system as having been of l'spedal concern and thc1 efore heavilj 1.1rgcted L>y th<: FSB, not least lwc.:ausc it was used frcqucutly by Rus~i tn Internal political activists and opposiLionists. His/her undcr·st;rnding , .. as that the FSB now succes!-fully had crackcd this communications sofl\\' ,1re and therefore it was no longer secure to use.

6. The :mnlor Russian govcrn111cnt figure u ted above also reported that 11011-stale sponsored cybcr crime was becoming an increasing problem inside Russia for the government and m,thoritles there. The Central Bank of Russia claimed tJiat in 2015 alone tht:rc had been more than 20 attempts tit serious cybcr embezzlement of money from corresponding accounts held there. comprising sever.ii billions Roubles. More generally, s/he understood there were circa 15 n;_ jor organised crime groups in the counLry involved in cyber crime. all of , .. hich contin ued to operate largely outside st.are and FSB control. These it,( uded the so-called 'Anunak', ·nuktrap' and 'Metel' organisations.

Z6 July 2015


CONFIDENTIAL FOR SENATE JOOICIARY COMM. PRODI ICTION ONI Y RELEASED BY AUTHORITY OF THE CHAIRMAN OF THE SENATE JUDICIARY COMMITTEE

CLMSJC00041396 l

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COMPANY INTELLIGENCE REPO~T 2016/095

RUSSIA/US PRESIDBNTIAL ELECTION: FURTHER INDICATIONS OF EXTENSIVE CONSPIRACY BETWEEN TRUMP'S CAMPAIGN TEAM AND THE KRErdLJN

Summary

Further evidence of extensive conspiracy between TRUMP's campaign team and Kremlin, sanctioned at highest levels and involving Russian diplomatic staff based in the US

• TRUMP associate admits Kremlin behind recent appearance of DNC e· malls on Wik1Leaks, as means of maintaining plausible denlabillty

• Agreed exchange of information established in both directions. TRUMP's team using moles within DNC and hackers lri the US as well as outside in Russia PUTIN motivated by fear and hatred of Hilla.ryCLINTON. Russians receiving intel from TRUMP's team on Russian oligarchs and their families in.US· .

• Mechanism for transmitting this.Intelligence involves "pension" disbursements to Russian emfgres livtng in US as.cover, using consular offid~s in New York, DC and Miami ·. ·

Detail

Suggestion from source close io:TRUMP and MA1'1AF9RT that Republican campaign team happy to have .Russia asi:nedia'bogeyman to mask mor.e extensive corrupt business ties t_o. China and other ~~erging countries

.. ·. -: • : • • :. •• : • • • • ;., , : ; .... ' • • • \ • • .:· • •• : ~' • • > • • • • .'. . : • ,.; • '·., • •

1. · Speaking in confld~nce to ~ C?.~P~t1i9,t,J.tl :!~~e. l~W~;?P.W?•:.SQ~~~e·-&~ aA:·'_.-- · · ethnic. Rus~ian d~s.e. ~sso~~~~-~f.{~ep~p).\?,.~-'.~~;Pt!~.i~~~ticil_.,~di4~te . · . Donald TRUMP; a~1tted thartAere was;i ·w~U .. (\eV,~lope_d:c:onspt~cy of CO•operation between thern ·a·n~...the R~sian-:r.e.aij~~ip .. Thls was . ,- .... managed on the TRVMP side b~thc -~P.~b-litaJi'aiiicU4ate's·:campaign mariaget, Paul: MANA~d RT;: wn~fYva s'~$fng-'f or~.tgf p'olicy a~vlsor, ._Carter. PAGE, and others as-lntermedia,r.Jes. :tl:fe .. ~o'sldes had-a mutual interest ii:i defeating, Democratic. presiµ~1't ial.~ndteul.te]U\l.acy. .. CL1NTON, whom .Presiderit.PUTIN.apparentlybQJh hatj!~·ana,(ea~¢;:,:::: . ·, :.. . - .

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The.reason for using WfklLeaks was "pl~1uslble denlabllltyH and the operation had been conducted with the full knowledge and support of TRUMP and senior members of his camp;1ign team. In return the TRUMP team had agreed to sideline Russian Intervention in Ukraine as a campaign Issue and to raise US/NATO defence commitments In the Baltics and Eastern Europe to deflect atlcntion away from Ukraine, a priority for PUTIN who needed to cauterise the subject

3. ln the wider context of TRUMP campaign/Kremlin co-operation, Source E claimed that the Intelligence network being used against CLl NTON comprised three elements. Firstly there were agents/facilitators within the Dem<1cratlc Party structure itself; st·condly Russian emfgre and associated offensive cyber operators based In the US; and thirdly, state· sponso·red c:yb.er operatives working in Hussia. All three elements .had. played an Important role to date. On the mechanism for rewarding relevant assets based in the US, and effecting a two-way flow of lntelllgence and other useful lnfonnation, Source E claimed that Russian diplomatic staff In key cities such as New York, Washington DC and Mlamf were using the emigre 'pension' distribution system as cover. The operation therefore depended on key people In the US Russian emtgre community for lts success. Tens of thousands of dollars were involved;

4. In terms of the intelllgence flow from·thc TRUMP team to Russia, Source E reported that much of this concerned the activities of business oligarchs and their famllies' activities and assets tn _the US, with which PUTIN and the Kremlin seemed preoccupied;

5. Commenting on.the negative medla publicity:surroundlng alleged Russian intei:ference in the US el~ctlon campaign In ·support of TRUMP, Source E satd·he understood that the Rt!pubUcan candidate and hls. team · were relatively relaxed about this be·c,use·lt·d~fle~~d ~edia an~ the . Democrats' attention away frQm TRU.M P's b~ne5$.dealings.in China·and . other emerglng·markets. Unlike.tn·Russia, t,h~e,were $UbSbµ1ti11l:ah~.· .· Involved the payment of.large:~.r,~bes and kickpac~\vhich, we·re they to. become public, would be pote11tially ~~ry d~agi:ng-~o their.cam)>ai~ . .

6. Finally, regarding TRUMP's claimed mi'nima·l i~ves'tment profile in Russia, a separat~ so'urce with direct knowledge? sal~ thls·had riot been for want of trying. TRUMP's previous.efforts ~ad in.clu[Jeci'e,tj>lortng th~ .. reaL~state .. sector in St Pctersburg.'as well as' Mc;,scmv but.fn'·the end TRUMP had had to settle for the use of extensive sexual s~rvices·th~re from local : " prostitutes rather than business succ~ss.

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COMPANY INTELLIGENCE REPORT 2016/94

RUSSIA: SECRET KREMLIN MEETINGS ATTENDED BY TRUMP ADVISOR, CARTER PAGE IN MOSCOW UULV 2016)

.Summary

- TRUMP advisor Carter PAGE holds secret nwetings In Moscow with SECHIN and senior Kremlin Internal Affairs official, DIVYEI<IN

- SECHJN raises Issues of future bilateral US- Russia energy co-operation and associated lifting of western sanctions against Russia over Ukraine. PAGE non-~ommittal in resporise

• DIVEYKIN ~iscusses release of Russian dossier of 'kompromat' on TRUMP's opponent. Hlllary.CL.INTON, but nlso h_ints at Kremlin possession of such material on TRUMP

Detail

1. Speaking in July 2016, a Russian s.ource close to Rosneft President, PUTIN. close associate and US-sanctioned tndlvldu;1l, Jgor"SECHJN. confided the details of a··recent secret meeting between him and visltlng·Forelgn Affairs Advisor to Republican presidential candidate Donald TRUMP, Carter PAGE. . .

2. According to SECHIN's associate, the Rosneft President (Ceo) had raised with PAGE the issues of future bilateral energy c~.ope_ration an~ . . . . prospects for an associated move to·lift.Ukr:.ilne-r.eJated·western . sanctions against ·Russfa. PAGE had reacted positiv~ty:to this de·marche by SECHJN but had been generally non•c;omm_i~lln respo~e. ·

3. Speaking separately, also .in July 2016, an.offici;ll,ctose-.to Presicfo~tial Administration Head, S. IV~NOV, confided in _a· co~patrlot thata senfrfr colleagu~ in the Internal Political Oep~rtrncnto.f t~e P,\ 0IVYEKU'f (1)fdl also had met s.ecretly with PAGE oi1 his ·~e.ccnt-vi~lt.°Theifage~da ~ad-,:°/ · included DJVEYKIN raising·a dosster·of'kompro~a(the.KremUn ·: :::·: . · possessed. on TRUMP's Dem·ocratic pr~identi~frl~l;:Hill~rY,°'Cl.lNTO~; . and its possible _release to the Republican's qunpa,~gn teain; : . · .

4. However, the Kremlin official dose to S. IV J\NQV added that s/heJ>.~lieve_d· ·.. . . DI VEY KIN als~ ijad hinted. ( or indicated mo re °strongly)· that~e -~µss~~n .. .... · · · . . leadership also ~ad 'ko·mpto~~t':o·n·TRVM P \\'.hltji the·tatter sho·ult\ '6:ear :. ··_, ·.: . in mind in his: d.~aJings with tlie.m .. · ,-:. · · · .. · · .· : · · · ·. . .' Y · '.

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1 1) July 2016

COl>JFIDHHIAL FOR SEl>JATE JUDICIARY GOMM. PRODUCTION ONLY RELEASED BY AUTHORITY OF THE CHAIRMAN OF THE SENATE JUDICIARY COMMITTEE

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CLMSJC00041400

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RUSSIA-US PRESIDENTIAL ELECTION: KREMLIN CONCERN THAT POLITICAL FALLOUT FRO~ DNC E-MAIL HACKJNG AFFAIR SPIRALLING OUT OF CONTROL

Summary

Detail

KremHn concerned that political fallout from DNC e-mail hacking operation Is spiralling out of control. Extreme nervousness among TRUMP's associa.tes as result of negative media attention/accusations

Russians meanwhile keen to cool situation and maintain 'pla~sible denlablllty' of existing /ongoing pro-TRUMP and anti-CLINTON operations. Therefore unlikely to be any ratcheting up offensive plays in immediate future

Source close to TRUMP ·campaign however confirms regular exchange with Kremlin has existed for a, l~st 8 years, Including Intelligence fed back to Russia on oligarchs' activities In US

Russians apparently have promised not to use 'kompromat' they hold on TRUMP as leverage, given high levels of voluntary co-operation fo~hcomlng from his team

1. Speaking In confidence to a trusted assoclat~ In l.:i te July 2016, a Russian emlgr~ figure dose to the Republican us presidential candidate (?.o~~Jd'"TRUMP's campalg,:i team commented on the fallout from pu~llciiy··surro~n(:lipg:: the ':'.Oe.m.ocf!tic , National

Committee (DNC) e-'mail hacking scandaJ; Jf:ifernigr~ ':S~!~)b:~i~ w.as.:a h.ith le~.el :of. anxiety within the TRUMP,team as ·a result.of val'ious,accus,itloris levelled against them and ind,ications from ·the Kre~jin ·:tt:,~i Pres,i~ert·.~q;i'l~.:an{ otryefs ·.ln the leadership thought things had gone too far ~ow and.rJsked·splralllng_out of control.

. ·: . . .

2. Continuing on this theme, the emigre.assodate of'.TRVMP·opin~d·that the .Kremlin wanted the situation to calm . but ,•,fQr.<·'p(a'.~sible·:;~·~.ni~bil!W~: .to. '.'b~ .. mai~tairied. concerning its (ex.tensive) pro•TRUMP arid"a:nt'i-CLIN'.T;Ot{Qperatlons: ·s/he.t.herefore

judged that it was unlikely these wo.uld be.r:aic_heted l:11?, ad~~st for. the time,being.

3. However, in terms·of.e$iabilshed oper:atio~al;UaisQn,be.tw@~;the ·TRUMP.:team and· . . . ~ :. . .. ·. . . . : .. . \' •·. ,., .. ~ . . . ·. . . . ... . . . . . the Kremlin,. th~-:~rtllgre :co~flrn,ed th~~ .'.~Jl·.:.lritcllig~i;\~.··~harigi::hath~e~otunnlng. between them Jor) t:ieast)f vears. Wi."11~: tbis.. con~~?~tiTfNif i>ri1dr)tv.'teci~ir.emerit ·. had been ior.1ntell.1$¢nce:~n.~e~ctiv.1tt~;"~t~1pess'.a.rit(othen..vlie, in'.the US· .. of.l~aalng ·· Russian ollg~.r.(hs·.~?.:~:~~-l~~f'l.1.1.J~s. J'ij.~.~p1~))p hls_:,.~sg~~~.~10,1,1ly h~~f ob~\.ned and· .... supplied the.,Kr.,mlln -Mth.~hts·ftiformattorr, ,,/·.... . :. ·;,>:·/·:/>'': .. ·.' .. , · ... · . · ... ,> '' ··.·, ·

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4. Finally, the cmigre sold s/he understood the , .. remlin had more intelligence on CLINTON and her campaign but he clid not know the details or when or if ic would be released. As far as 'kompromat' (compromis1· g inform.ition) on TRUMP were concerned, although there was plenty of this, he , riderstood the Kreml in had given its word that it would not be deployed against th r:: Republican presidential candidate given how helpful and co-operative his team 1ad been over several yea rs, and particularly of late.

30 July 2016

GO~fflDENTI/\L FOR SHJATE JUDICIARY COMM. PRODUCTION ONLY RELEASED BY AUTHORITY OF THE CHAIRMAN OF THE SENATE JUDICIARY COMMITTEE

CLMSJC00041402

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RUSSIA/USA: GROWING BACKLASH IN KREMLIN TO DNC HACKING AND TRUMP SUPPORT OPERATIONS

Summary

- Head of PA IVANOV laments Russian lnterv~ntlon In US presidential election and black PR against CLINTON and the DNC. Vows not to supply Intelligence to Kremlin PR operatives again. Advocates now sitting tight and denying everything

Presidential spokesman PESKOV the main protagonist in Kremlin campaign to aid TRUMP and damage CLIN1'0N. He Is now scared and fears being made scapegoat by leadership fo r backlash in US. Problem compounded by his botched interventJon 111 recent Turkish crisis

- Premier MEDYEDEV's office furious over DNC hacking and.associated anti-Russian publicity. Want good relatlor:ts wl~ US and ability to travel there. Refusing to support or help cover up after.PESKOV

- Talk now In Kremlin of TRUMP withdrawing frof!l p_resldentlal race altogether, but this still largely wishful thinking by-more liberal elements ln·Moscow

Detail

1. Speaking in early August 2016, two w~U-placed·a:n~ established Kremlin source_s outlined the divisions and_ pac~ash in ~os_cQw .. arislng fro~ the Jeakt~g of Democ~tic National Com·~itW~ ( DNC} e~·mails~~d .the. W.l<:ler pro-TRUMP operation being condu¢te.<f{li the Osi ij_ead.ofrre.s)4~n$.l . Administration, Sergei IVANOV, ·was.angry at the recertt turn of-events, He believed the Kremlin #tec1m" lnvolyed, Jcu by pr~idential ~9kesman Dmitriy PESKOV, had gone too far in fnt~rferlng lJ1:forelgn affaii:s-~ith their "elephant In a china shop blackPR'\IVAN:OV:dalmea always to'.have opposed the handling and exploitation Qf Intelligence by this Pll'.~te~m". Followiog the backJash against such for~lgn tnier.fetencein .Us'°politics, lVANOV was advocating that the only sensible course of action now for the Russian le~dersbip ~s to "slt.tight·and detjf~v~iWting'.' .. ~ : .

2. Continuing on·thfstheme the SQur.ce;~~~e lo iv~~QV~~p~~d th~t.: .:: . . · .. • ' , . . •' • •• :. ,. .. . l .. .. .. •• . . ' • sf,'~ ' .. • ' • • • • ••

PESJ<OV now was_ .:se;tred shitle~(-_ th~t~e w~.~~~:li~,J~~~6,9.~~c;for .,.: .... : _· .. ' ,.'. . . . PUTIN an~ ~e-~em_ltn:.~d ~eld,-~~~~,ijhleJor.JP.~-.~~~~-~b~~gai9st: . ·.:~ ::_\<.'·· ·. · Russia~ ·pohti~l ~te.rference tn .$.(r_QS,electiQnnYANOVwas,~tefinill~·d::: :: / ·- : . . ..


..

lo stoµ PESKOV ph1yi11g an inclcpcnclcnt r o:c in relation to the US going fonvard and the sourre ful ly cxpcclccl thr presidential spokesman now to lay low. PESKOV's pos ition wns not helped '.1y a botched ntte111pt by him a lso to interfere in the recent failed coup 11 Turkey fr o m a government relations (GR) pcrspectiVl' (no funlwr dc1:· !s ).

3. The e xtcut ol disquie t and division w ithin :·.toscow caused by the l,acklash against Russi.:in rntl'rfcrnnce In t h.? US clenion was underlined by a second source, close Le, pn.-'mier Omi tr y MEDVEDEV (DAM). S/he sale! the Russian prime minister a nd his c1J!!eagucs wnntcd to have good rclatious with the US, regardless of who w, s in power there, and not least so .,s Lo be able LO uuvcl there in future, C:Lt i1er officially or privately. They were openly refusing to covc1 up for PES!<OV a nd o thers involved in the DNC/TRUt-l P operations or Lo supporl hi:, ,·ountcr· allack or allegations agamst the USG for its Jlleged hacking of 11 e Russia n governme nt and state agencies.

4. According to the firs t source, close to IVA\OV, thcrc had been talk in the Kremlin of TIUJM P being forced lo withd1 . '/\/ from th!! presidential race al together as a result of recent events, ostnsibly on grounds of his psychological state a nd uns uitability fo r lu~h omcc. This might not be so had fo r Russia in the circu111sta nces but in the v iew of the source. il ruma in ed largely wishful lhinking 011 lhc p.m oflhose in Lhc regime oµposed LO PESKOV and his "bolchcd" opt·1 a tions. at lease for the time being.

5 August 2016

GOt>lFIDENTIAL FOR SEt>V\TE JUDICIARY GOMM. PRODUCTION Ot>JLY RELEASED BY AUTHORITY OF THE CHAIRMAN OF THE SENATE JUDICIARY COMMITTEE

CLMSJC00041404

' ' ' COMPANY INnLLIGENCE REPORT 2016/101

RUSSIA/US PRESIDENTIAL ELECTION: SENIOR KREMLIN FIGURE ounlNES EVOLVING RUSSIAN TACTICS IN PRO-~UMP, ANTl-CLINTON OPERATION

Summary

Head of PA. IVANOV assesses Kremlin Intervention in US presidential election and outlines leadership thinking on operational way forward

Detalls

No new leaks envisaged, as too politically risky, but rath•?r further exploltatlonof (WlkiLeaks l material al ready disseminated to exacerbate divisions

Educated US youth to be targeb?d as protest(againstCUNTON) and swlngvote in attempt to turn them over ID TRUMP

Russian leadership, including PUTIN, celebrating percelwd success to date In splitting US hawks and elite

Kremlin engoglngwlth several high proflleUS players, Including STEIN, PAGE.and (former DIA Director Michael Flynn), and funding their recent visits to MOSCO\Y

1. Speaking in confidence to a close colleague In early August 2016, Head of. the Russian Presldehllal Administration (PA), Sergei IVANOV, assessed the Impact ~nd results of Kremlin Intervention In the US presidential election to date. Although mostcomme~tors · bellev~ that the Kremlin was, behind the leaked DNC/CUNTON e-mails, this remained technically deniable. Therefore tl:'e _Russians would nC:>t risk their position for the time being with new leaked matetlal, even to a third party llke WlklLealcs. Rather the 13CtlCS WOUid be to spread rumours and rrt1Slnfor~t10n about the content of whatalready had been leaked and make up new content ·

2. Continuing on this theme, IVANOV said thatthe-audiencP. to be· targeted by such operations was theeducated youth in America as the PA assessed that there was still a cha rice they could be persuaded to · vote for Republican candidate Donald TRUMP as a pr.otest'aplnst the Washington establishment ~n the form of Democratic candidate Hillary CLINTON). The hope was that~ If she won, as a result of this CLINTON In power would be bogged down In worfdnt; for .. intetnaJ rec~l)tl!latlon In the US, 'rather than being able.to focus on foreign p~iicywhlch wou~4'.~a,~B!!)us.s_ils l~~is.. !'h~s.jl~.o~houldd~· . President PUTIN more room for manoeuvre In the (un.,:Yp toA°u~sla;s ~n·p~l.oei\tiit'I electicin in.2018.'. ·.

3. IVANOV reported that.although the ~remHnhad "n;e'resti;~ th~ ~~~~-~{G~~la0

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reactionto the ONC hack and TRUMP'S linkstoRussia;i>u!'iNwasgenerailys~tisfledwiththe progress' .

of the anti-CLINTON operation to date. He recently had had adrlnk.wlthPOTINto markthls.ln IVANO\/s view, the us had tried to divide the Russlanelltewi~s~nctlo.~ butfa)le(J,\~h!lstthey,by contrast, had succeeded In spll ttl ng the US hawks I nlmical .. to Russia _a_nd ~ :W~s.hlniio.~ ,11te}nore generally,·ha lf.ofwhom had refused to endorse any pteslde,,trat candidate as':a i:~ul~of.R\ISSla~·,~wilendon. : . -.. .

. · :· . •,:: · :· : .. . \.~ :· .. . . . ' . 4. Speaking separately; also In early August 2016, a Kretnli n offl~lat lnvolvect:'ln US relations commented

on aspects of the Russian op.eta ti on todate.·lts goais.ha d ~n'.dir.~fold~ ·a}ldng_syrnpathetic US ii_ctars how Moscow could :~elp th~m; : gathering . r~levant I nt~l)g~nce; -~nd \c.r~ti,ng and · .. dlssemlna~ng. compromlsl ng lnforma~on ('kompro~t').1his.had I n.vplv~~e'.IC~tnlt'ri ·s'.uppo_ning~a~fous US polhlcal figures, lncludl".g f1:1n.d.ln~-l~d.1~~y'·.t,tie1~. ·rec.eM,'.~fs:Jts to.\M9scoV!':·s1.~~-iiia~_,.a:·deJ.esa~onJrQ~ _ _. . · Lyndon LAROUCHE; ·p~ldeotSal,C~l')~!dateJ_lll.'~l~q~;th~(~ii~j'::p~(t;y;-;fiiQM~JQ~e.tso;pollcyad~ise--': . .

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. '.t5

Caner PAGE; and former O!A l)irC(tOr Michael Flynn I this reg31d .)nd as succ<:Ssfu! In terms of pcrcelvcd OUICOrTI<'S

JO August 2016

COl!>JFIDENTI/\L FOR SHJ/\TE: JUDICIARY GOMM. PRODUCTION ONLY RELEASED BY AUTHORITY OF THE CHAIRMAN OF THE SENATE JUDICIARY COMMITTEE

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COMPANY INl'lLLIG~NCE REl'OKT 2016/10?

RIJ!.SIA/US PRE510ENTIAl ELECTION: REACTION IN lRUMP CI\MP l.J RECENT NEGATIVE PUBLICIIY ABOUT RUSSIAN INTEJtf(AENCf t.NO LIKElY RESULTING TI\CTICS GOING I C, I\\VAl!O

~unun.iry

Detail

'i\U/\'' c .Jtr:p;uen in\,d,•r ·,·r,ni rec en· DNC ,. m .. 1111:.i~ .,,,. J1111c:d al) .v,1ch1nl SAl',OrRS (protest) voter~ Jw.iylron, (LINTON nndo11crto TRUMP

,\.;trtllh Rt:pulllican c.1111p.1lg11 u11dr?res1,rn,H<!J ,esullint: 1 ,c1tlv1: rt.'c1cuo11 from US llberals,elitcand med1.i ,, nd forced to cha nee coo, staH<!HJI!

ri.:co no ..... to :urn lollies on CLJNTON's u~c of PUIIN ~ ooscvma11 10 election, iilthough some resen tment at Hussian president's percc,ved ,1ncmp1 to ,. derm,n\, USG and ,y)lem over and above ~wlll(l,ng pr es1de1ulc1I clecuor

'(Jf'illtjn1: 111 conf,dcnrc nn 9 August 20l6. an ~Lhmc Ru• .u, as;.ull..it.eof Rt!fJullllcan US prt>1dc:nt1al

und,da1c: Oona Id TRUMP dlS(U~~ thr rcac1Jo,1 ln>lde h , nrnp, and, evlsed ta<llt) th1:,ein resulting

from ,~.Ml n,:ga t,vc publ,c1l'( coocermng Moscow'\ , 1ndesone ln11olvl!/1\Cnt ,n the campc1!gn f '<l.l/1.1?' 4HOC .itc rcportc:CI that l hc Jln101 l.:akingthcOM c m.tllstoWlklleab tluringtheOemocratic

Co11vc111,on h.Jo occn to sw•ngsupporwrs ol Bernie SANO' S .,._.ayfrom Hllld1y CLINTON and across 10 fiCUl,lr'. lhe,c votcr-s were µc,cc,\"cd a~ act,vistand ant, • IIU) quo and anu c:~ta bllshmentand ,n that tl'f::lrdshJrl"£fflllnyfoatu1e\ wtth the TRUMP camp.111cn. , dudlngavlsce1.ildlsllkcor HIiiary CLINTON. ?111. ob1c:Clt ·,e h.-d b~n conle111t:CI dnd ;,. omoted, ,ni.:r a ,. by TflUMP's foreign Policy11d1:lser Carter PAGf ·,ho nao chscuHed 1tdtr!)ctfy,.v11 ., tne ethnic Russi aHocl.ite

2 (ur 1 ,,,.. rgon :.1·1s lh.,,mo, tht- tthn,c Russ,an associutec• ltUMP ass~se<! that tht:. problem was that u, .. 'KUMJJ c.impJ 1gn hJd unC!l't<'sti1n.1ted the s11engtl I the neg3uve reacuon lrom hbec.alsand

d pt .1a 1ly 1htconse,vat1vE:tl11t,to Russian interference ,, swas rorclnga rethink and a llke?'(chani,? of u1u 1cs lhc 111.1111 obJec1111e 1n the short term was 10 c 111 ;:I,: Ocmocratlc candidate l-llllarv CUl\'TON's

\UtteHlul e•plottation oflhE PUllN as bogey111an/Ru~s o I ln terhirence story to ldrnlsh TRUMP and boiner her own (patrlot1cl crcdentlals . The TRUMP com1 i:. gn wns focusing on tapplnu 11110 support tn

the American tt:ltvl s1on media to c>chievc this, as they rcd.oned thl~ resource had been underused by thl!•n 10 date.

3 HCJ\\>t,ver, rRUMP's .c1nociate also admltteo that there .,. ,~ a fair amount of anger and resentment wllh1n u,c Republican cand,oa1e'!i team at what was percl, 1ed by PUTIN as going beyond the ob}ect,ve

ul wl!11luml ng CU NTON and bolstenng TRUMP, by attemp ., •g 10 exploit the situation lo undermi ne the

US tlOvernment ,;nd demoetattc system more gl!lletally I was unclear at present how this aspect of

the situation would play out in the wo.,eJ..s to come.

JO Aui:ust .!016

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l1

CO:\ll'ANY INTl:.LLIGENC.E REl'ORT 2016/ 136

R L;SSL\/US l'llrS IIJl:!\ flAL fl.ECTlO N: FURTH ER DE1 \ .!.S OF TllUMP l r\\VYER COIJc.,,"s SECRf:T LIAISON WITH THl: Kl{L::-.tuN

Sumni~t)"

ls..r, mlin 111-,i .. lt•, rq1(11ts I RU/I.IP lawv<'r C ( ll 11:N', '-l'(fl'I ,,, •ding/., with Krc11din ofr1n,1b 111 .\u!'u-.i 2011, V,".h l\'t'rt· IH'ld in h,1i;u~

l,u ,; ,i,1111.,.i,.1:..t<lt.1l l'tg.111i,.1ti,>11 Rl1,:..otrndrnd 11·,-tvn u:-l·d .,, 111v,·r for lhi:: li,1i,on nnd pn.m1isc~ Ill t n·,h C,IJ'l l.1 ! 111.1 1· h.i,,• b,•1•11 u,,·d fnr tlw mPt'ling/!'>

P!lt·Pl l l'\i k-.1d111g Duni.1 tig11tt'. KOSt\CHF \ ', repurtcJI) 1 1volvcd ,b "plJu:..ibly d,,niabk" l,lt il1t,1tor ,in.I 11\cl) h.n , .. partirip.llt!d in till' , \11gu,;t meet in;:/:,. with CO! JEN

Detail

t;p(·;ikini-; Iv a compatriot c1nd friend ,, n 19 lktob~r 20 16, ,, Kremlin insider provkkd furtlwr dt•t.11b ot rt•porh.>J cl,mdc:-.tuw nwPlinM I:,. between Rcpul•! ca n prL•:,.iJenli,ll c.,ndid,1tc, Donald f l<l '1'11''., L1wycr ~lid1,wl COi H:N an,1 Kwndin rcprt'$L'l .t 1lt\'t'::. in ,\ugu•,I 2016. ,\! though !ht'

i:ommurnrnthm bdwc,•n them had to be Cf) plic !or sccun •y rc.ii;ons; thc Krt>mlin in~idm cl1·,1rly i11d1c,11t.-J w hi.;/ her fric.>nd Lhilt !ht: n•porh:d cont.a\ t /s tool.. plac,• in Prague, Czed, Rt'public.

2 Continuing on thi:s tlwm1:, tlw Krt'mlin im,,dl'r hit,hl ishh ·LI the im portanc-.:? n( th<.' Rw,.,ian pnr:i,;t.11:il organi-..:i tfon, Ros:-.otrucinid ws l\'o, in this cont.1, t bcnvecn TRUMP rnmp,1ign ll'JHc'"c·nt<1tn L' 1 .., and Krc•mlm official, Ro,,<1trudnichcst ,·,, w.:1s being used .1s cover for thii; rt'lt1ti,)nship and it,; ol fit"l' in Prague m,1y \\ ell have been u.,ed to host the COl lEN / Rusi;ian 1'1 t'~H:.knt iJI 1\Jmini~tr.1 tto11 (PA) meelingh,. It was considered a "plausibly deninblc" vdttcle Im this, whibL rem,1ining entirely under Kremlin control.

3 Thl' Kr~mlin in~idcr went on to identify leading pro-PUTI 'l Oumn figure, l(onstant1n KOS. \Cl II.: \I (1 lead oi tlw Fcm·ign Rek1tio11s Committee') .is an importnnt figure in the TRUMP c,11np,1:gn-hn:mli11 li,1be>n opl.'r,1lion KUS.\CI IEV, ,,lso · ! tausibl) deninbk-" being part of Lht> Ru,-.,ian ll·ghl.ituri: r.i!ht'r than executive, h,,J facilita t('d 1. 1«.• contact in Prague and by impl:c,itam, mav h.1w .1ttc11dcd the mc•eti11M/ s wilh COi lt~N there in August.

Company Comment

\ \"<:> H'pt,IIL'J prcviou~ly, in our Compnny lnh·lhgcnce Rl•po11 :016/ 135 of 19 Och.>bcr 2016 from the -.,mh'· 't1111H1, tl1tJl COHEN met offici.ib f1on1 the PA Legal Dv ,.11tment dandesti.nely in an EU count I y in Augu:-.t 2016. Thi-. W,b in 01 dt•r to\. hm up the rn, ··.s left behind by west<:rn media r11, d.itio:,., of rnUMP ex-(,,mpaign manager i\ !ANA FOR f ' .. , orrupt rcldtionship with the former pn)· l~u,~i.111 YA1'UKOVYCI I regime in Ukrnin1..' and TRUMI ' forcil)n policy advi~or, Carter P1\CE's M'cr~t meeting::. in Moscow with :,enior wgimc figurv-. in July 2016. Accordi,1& to the Kremlin ,1dvi:;cH, thc.'$t' mucting/ s W<?r(' originally scheduled ! t)J' COHEN in Moscow but shifted to

1 •

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wh.11 \\',t~ ron:-i,'l,•r ,·d ,ll1 l'!wr.1l i,111.illy ' ':-,,fl " l~U ,ou111ry 1, I ,•ni l w,,,, jud~cd l(Kl ;,;umprombing 1111 hin\ t,> 11,1,·,·I 11~ tlw Ru.;-.i,111 ,·.1pit.il

:!( 1 < ")t'llll' t'I 2tl I (I

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RlJSSIA/UJ<RAINE: THE DEMISE OF TRUMP'S CMvlPAJGN MANAGER PAUL MANAFORT

Sum111<1.ry

Detail

f:,-lJl:r.uni..111 Pr L' .;tdt:lll Y/\NllKO\'YCI I con·! les directly to l'lJTIN that he aut horis~d kick-b,1d ( pay111ents to M/\NAFLl,ff, as .1llc:ged in wcstl·rn media. Assures Russian President however Lhere is no docu111cntary t'videncc/trail

PUTIN and Russian lL•adersh1p remai 11 wo1 1 ~cl however and scepllL'al that YANUl<OVYCH has fully covered the traces 1 1 these payments to TRUI\IP's to1 nwr cam paign 11in11ager

Clusc associate of TRUMP explains rcason1 11g behind MANAFORT's recent resignation. Ukrnine revelations played part but others wanted ~1ANAFORT out for various reasons, especr. lly LEWANDOWSKI who 1~mai11s inOuen tial

1. Spe..iking i11 latc August 2010.1n the imnu. t11ale aftermath of Paul ~li\NAFORT's resignation as campaign ma111gcr for US Republic~n prcsidcnu:il candldaLc Donald TRUMP, a\\, ll ·placed Russian figure reported on a recent meeting between Prl' :..1dent PUTIN and ex-President YANUl<O\'YCH of Ukraine. This had been hlld in secret on 15 August near Volgograd, Russin anti the western media n 1velations about MANAFORT and Ukraine had featured prorninently on the agenda. YANUKOVYCH had wnf1dl'cl in PUTIN thaL hE:' did authorise a11d order substantial lock-back payments to MANA FORT as illleged but SOL .ght to reassure him chat there was no documentary trail left behind whk l. could provide clear evidence 0f this.

2. Given Yt\NUJ<OVYCI l 's [unimpressive) rec1ml in covering up his own corrupt tracks in the past, PUTIN and olht·r-. in the Russian leadership ,, ere sreµlical about the ex-Ukrainian pn.--. dent's reassurnnccs on this as n:lating Lo MANA FORT. They therefore sl.i. feared U1e scandal had legs, c:speclally as MANAFORT had been comnw,·cially active in Ukraine right up to lhe time (in March 2016) when he joined TRUMP's campaign leant For them it therefore remained a point of pDLential political vulnerability and embarrassment.


').0

3. Speaking separately. also in late August 20 ! 6, an Anierican politic.11 figure associated with Donald THUMP and :1is carnpnign outlined the reasons behind MANAFOHT's recent denlis~i. S/he snid it was true that the Ukraine corruption revclutions had ph:.1ed a part in th1s but also. sever.it senior pl,,yers close lO TRUMP h.id .vanred MJ\NAFORT out, primarily to luost:n his conll ol on strateg~ · ,n<l policy formulation. Of partirn!ar importance in this regnrd wns t.L\NJ\FOlff's predecessor as campaign manager, Cor\?y LEWJ\NOOWSKI who hated MANAFORT pt'rsona lly and J cniaincd dose to T RUM P\. ith \"-ilmm he disrnssed the presidential cnmpnign on a regular basis.

22 August 2016

Ki foi "''1 'ii'~t=:IO~l<l I Ot.C FU~ SENATE JUDICIARY COMM. PRODUCTION ONLY


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COM PAN\' INTELLIGENCE REPORT 20 l 6/ 111

IWSSII\/US: !<REMLIN FALLOUT FIWl\1 MEDI,'\ EXl'OSURE OF MOS<.:OW'S INTEHFERENCE IN THE US PRESJDt:NTlAL CAl\tP/\!CN

S111nmary

Derail

l<rcmlin ortlcn; senior sralf tu rC"main silenr ni n1c:dia and private on ;illcg:1uons nf Russian interference in US pr<:'> denlial <:ampa1gn

S1:nior figure how~vcr confirms gi:;L of alleg,,t:ons and reports IVANOV s.1rked :.is He.id of Adini11istr,nion on accoun1 if giving PUTIN poor advice ,rn issue. VAIN() selected as hi!> replacemen t J .H'Lly because he was not im·olvcd il1 pro-TRUMP. anti-C:I.INTON oper,11ion/s

Huss1o.ws do have further 'l<ompronrnt' 011 Cl.1.-l'l'ON (e-mails) and considering dis.semi1111ti11g it ilfter Duma (leg1 • lative elections) In !ale Sl'pkmber. Prcs1tlc11Lial spohcsinan PESKO\' ,onlinues to lead on this

HowcvC'1, L'qually unportant b k'.1 cm li11 objet'!lve l<J shift policy con!>cnsus favou rahly lo Rusc;iJ in US post-OBAMA whol·ver wins.. Both prcsidcmial cant!i<lat~:,· opposition to TPP .111<.l TTIP vie\'., d as n result in this respect

Senior Russian diplomat withdrawn from W.i ,hington embassy on account of potemtal exposure in US preside1!lml election operacion/s

1. Sµt,1k1ng i11 tunf1<Jencc: to <1 trustcd compat1 t• >L in mlcJ-Scptcmbcr l016. a sc11io1 membc1 of the Russian Presidential .\•lm inblration (P,\) rnmmcmed on tht political fallout from rect•nt western media revelations :.ibout Moscow's intervention, ill tavourof Donald TRUMP and against llillary CLINTON, in the US preside11 t,::il election. The PA official reported thcit the issue had Lwcome incredibly sensitive and that President PUTIN h .. ,d issued direct orders th t Kremlin and government insidt:rs should 11ot dis< us~ it tll public ore, l·ll in p1ivc1te.

2 Despite this, the Pl\ offk iJI ccrnfh med, frnrn I ircct knowledge, that the gist of the allegations wa~ true. PUTIN had ln en ret.eiving conflicting c1dvice on iutcrforing from three separate a.id expert groups. On one side lwd been the Hussian ambassador lO the U5. ,ergci KISLY AK, an<l the i\linistry or Foreign Alfoirs, together with au ndcpcndcnt and informal ncrwork nm hy presidenlic1l foreign policy 1.lvisor, Yu1i USl1AKOV


(l<!SI.Yl\l<'s prt?decessor in \Vashi11gto11) wht· .1<1d urged caution and the potential negative impact on Hus~,~ from tht ,perntion/s. On the other side was former PA Head. Sergt•i !VA NOV, bal ,L'd by Russian F01 cign lntclligl'llt'c (SVR), who h.1d ;idvist•d PUTIN 1:1 n the pro-TRUMP, anli· CLINTON opcrntio11/s would be both cffeclin and plausibly deniable with lilllc blowl>.ick. The lirst group/shad b l.! ·n µroven right anct this had been the catalyst in PUTlN 's deusion to sack l /,\NOV (u11cxrectedly) :is P:\ lie.id i11 .-\ugu-;t. llis successor, "·llton VA! \(1, had been. e!ccLcc.! for the job partly bc,ausc he lwd nut bet!n invol ved i:1 the US president ial dection oµer,1tion/::- .

3. Continuing on this theme, the senior Pl\ offit i.tl said the situallon now was that the Kremlin had further 'komprom,it' on t'andidatc CLINTON uncl had been considering n.:IL'asing this via ··1 l.n1sibly deniaulc" channels aflcr the Du1n:i (h::gbla tivc) l'icctiuns were out 11f lhl' w.1y in midSeptemhcr. There was however a growing tr.1111 of thought and associated lobby, ,ffgL:i11g that the Rus5ians could still 11 1.ike candidate CLINTON look "we.ik :ind stupid" by provoking her in to rai l rng against PUT! N and Russin vvithout the need to release more of her c-mnils. Presidential Spokesman. Dmitriy PESJ<OV remained a ke\' figure In the operation, although any final decision 0 11 d1sse minatio11 of further material would be taken by PUTIN himself.

4. The sc.:nior PA t>ffkial also repon,•d that a gr 1'.Ving element in Moscow's intc.:rvt1ntion in the US presid1:mti~1I election t ,, mpaign wa'i tht' object ive of s h1 fung the US polir!c::il consensus in Russia's perceived interests regardless of who won. It b;isically comprisl'd of pushing candidate CLINTON away from Presitlenl Ol3AMA's policies. The best example of this was that both candidntes no,v openly op, ,osed the draft trade agreements, TPP and TTTP, which were asses.;t!d by Mo~cow as detrimental lo Russian imere~ts. Olher issm•,. where lhe I<rcmlin was looking to sll1ft the US policy consensus wer~· Ukraine and Syria. Overall however, the preside11tial election was cons., .ered still to be too close lo call.

5. Pinally, speaking separately to the same compatriot, a senior Russian MFA official reported that .1s a prophylactic 11\easure. a leading Russian diplomat. ~likhail KU LAG IN, had been wilhcl1 .1wn from Washington nt short nottce bcc.:ausc Moscow feared his heai. y involvement'in the US presidential election operation, includi ng th-: so-called wterans' pensions ruse (reported previously). would be exposvd in the media there. His replacement, Andrei BONDAREV however\'.' :-, clean in this regard.

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Company Comment

The substance of wh.n was reponed by the senio ,· .{uss inn PA official i11 par<1s l and 2 nbovc:, including the rensons fur Serge i IVA'.':OV's dismissal, was corroborated independently by n former top levci Hussian Intelligence officer and Kremliu ins ider. also in mid-St•ptt:mher.

14 September 2016

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COMPANY lNTEl.LIGENCE REPORT 2 016/1 12

1WSS1i\/1JS PHESIDENTlA L ELECTION: l<REMLIN·All'HA GROUP CO· 0 PER,\ TIO N

Sununary

Detail

'l'op it!vl'I R11s~Llll o ll ici.1: (\m1inns cu rren t clos, 1 cs~ of /\lpha Croup· PUTIN relat ion8h1 p. Signific:an l f.tvours co nli11uL· •" u be done in both dir1.:<:t1un~ an d FRIOM/\N .ind ,'\VEN still giving i11lormal advice lo PUTIN, <-'Spcfrilly on the US

l<ey in termedia ry in PUTIN-Alpha relationship il'('ntif1ed as Oleg GOVORUN, cu1Ten1ly Head ofa Prl.!s idenlial Ad1 11 11istration clepartment but throughout the J 990s. the Alpll,1 executive\\ i10 delivered ill icit cash dirt'nlv to PUTIN

PlJTIN pl'rso11ally unbothcrcrl obou t Alpbc1's curre nl la<:k nf investmen t in Russia but un der pressure from co l leagues o ve1 this and obit: Lo <~xploit it <1:. IL',cr uv1:1 Alpht1 interlocutors

1. -.;peaking w nu ust<.:cl comp~ll n ol 111 mid-Septen1ncr 2016, a top level Hu.,..;i rn governmen t official rn111111e1Hed on the· :1 is Lory anti current s La l~ ol relations between Presiden t PUTIN and the ,\!pha Group of businesses led by oligarchs Mikhail FRIDMA N, Petr AVEN ~rn d German KHAN. The Hus::,ian government figure reporl~d lhat although lhey had had their ups Jnd downs, the leading figu res in Alpha curren t:r were on very good terms with PUTIN. Signifi cant favours continui ·t. lo be done in both diret tions, prtmari ly polltical ones for PUTIN c11, d business/legal ones for /dpha. Also, FTU DMAN and AVEN continued to g!ve informr1I advice lo PUTIN on foreign policy, and cspc:c!a lly about the US where he distrusted :1dvice being given to him by officials.

2 Althuugh FRIDMAN rc.·cently ha<.! met directly \\ 1th PUTIN in Russia, much c,t the dialogue and busmcss betwct:n Lhem w,1!, mediated through a sc111or l'r1:sidcn1 ial l\dmintslnition uffidaL Oleg GOVORUN, who currently hcadL·d the dtpartmcnt Lh ercin responsible for )Ocial Co-operation With the CIS. GOVORUN was trnsted by PUTIN and n ·cently had accompanied i11 111 to Uzbekistan lo pay respects at the tomb oi former president l<MU MOV. Howevci- r1cco rding to the top level Russian government of/ici;:il, during the 1990s GOVORUN had been I iead of Government Rel;H1ons al Alpha Group and in reality, lhe "driver" and ''bag carrier"

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used by FRIDM/\N and AVEN to deliver brge amou nts of illicit cash to the Russian president, at that time deputy Mayor u: St Petersburg. Given that and the continuing sensitivity of the PU'J'IN-1\ !;1 1a relationship, and need for phwsi!Jlc de11iabilily, much of the contact between them was now indirect and entrusted ro the rebtively low prolilc GOVORU N.

3. The top level Russian government offirial desc1 il>ed the PUTI N-/\lpha rclatinnship as both cc1rrot and sl ide Alpha heh' 'kompromat' on PUTIN on<! hl-s corrupt busi11ess ac:l!vltics from the 1 ti•.i Os whil-;t although not personally overly bothered by Alpha's failure l • reinvesl the proceeds of ns TN K oil company sale into the Russian eco1 1\1ll'ly since, the Russian presidem was able to use pressu re on this count from senior Krl!mlln c:olle:-igucs as a lever on FRIDMAN and J\ VEN to make them do his politic31 bltld ing.

14 September 2016

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, ,

COMPANY INTELLIGENCE REPORT 20 16/113

RUSSIA/US !'RESIDENTIAL ELECTION- REPUBLI CAN CANDIDATE TRUMP'S PRIOR ACTIVITIES I N ST PETtRSOURG

Summary

Detail

Two knowledgeable St Petersburg sources t..iim Repubhrnn nrncliclnte TRUMP has poid bribes ;rnd engaged in sexu,11 .ictivitlcs then• but key witnesses silenced n11d ev1c.le11cc hnrd to oot:1in

Both believe Azeri business .. 1::.sociate of TR I MP. Arai AGAu\ROV will know the details

1. Speaking tu a trusted compatriot in Scptc111.ier 2016. two well-placed sources based in St Petersburg. one in the p,ilitical/husincss elite and the other invnlved in Lhe local se, vice'> t1nd Lut11 ,.,t inJu-;try, commented on llL·public,rn US president ial candidate Don:tl ti TRUMP's prior act ivities in the c ity

' ) Both kn~w TRUM P had visit11 cl St Peters bu,;.: 0 11 several occMions in the past 3nd had hcen imerestt!cl In doing busi ness deals there inv()lving real estate. The local business/political elite figure reported that TRUMP had paid bribes there to further his interests but very discreetly and only through afllllmed companies, making it ve ry hard to prove. The local services induslry source rcµorlec.l that TRUM P had participated in sex parties in the city too, but that :tll direct w1l11esses to this recently had been "silenced" i.e. brihed or coerced to di ,a ppear.

3. The two St Petersburg figures cited belicv~·d an Azeri business figure, Araz AGALAROV (with ofnccs in Daku and London) had been closely mvolved with TRUMP in Russia and \-vould know rnosl of the uelails of what the Republican prcsidc11tial candidat~ had got up to there.

H September· 2016

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-

COMPANY INTELLIGENCE REPORT 20161, 30

RUSSIA. KREMLIN ASSESSMENT OF TRUMP ANO RU~i ~-'IAN INTE;AFERENCE IN US PRE:SIOENTlAL ELEC TlON

Swmnar)'

Buyl!r 's romorse s!.!\$ In w1rt1 Krmnlm ovor TRUMP sur, ,ort operation m US presidentlrJI eldCh:J n Rus::.,nn l0<.1drm;.h1p Ot::.dppe,lnteo 111<.11 leaked EH 1~ils on CLINTON h.avo not had gr oacor impact u1 campalgt)

Ru~s1ans have lnJac1Gd lurtt1er Mlt•CLINTON materla1 1:110 tne ·ptaussbly denlable' l.aaks plpalinfJ which will contH1u~ 10 surface, but best rnatorlal ,Jready In public domain

PUTIN ar)yry wrm san,o, otrlclals who "overprom,soo· c n TRUMP and lurlh~r heads likely' to roll a~; result Fora,y,1 M1r11st8r LAVROV may be next

TAUMP supportea by Kremlin because soon as dlvislvu, antl-establlshn',ent c~nd,data who would shaxo up currant lruern21rlonal status quo ii, Ru$.S·~·s favor. Lead on TRUMP opera\Jon rnovea irom ForE!lgr'l M1t'llSlry 10 FSB tind 1har1 to pr~slduntlal adrr'\lralst,atlon wh<J(-0 1l noi.v sits

Dotall

1 SJ.)tlaking separately ,n conhdonce to a lrustGd compa•r ot tn ear~y October 2016. a seruor Ru~ s1an lo<1oersh1p lrgurC> and a Foreign M1n1i.lry oftlcul 1eported on recant cte-velopments cur.cern,ng tl-ia Kremlin 's o~ ratior'I to suppoft R(3publl< -111 ca11dldate Oonatd TRUMP .n lt)ll US pressd8nltal elG<:ltt>n. The s ~rHO! l!:)aderstup hgu re s utd that a dogma of buy~r·s remorse wa::; setung ,n wnong Rus.slun leaoe,s concerning TRUMP. PUTII.J ano his colleagues were ::;urpnsed ano dlsappo1nted shat leaks of D i:tmocrotlc CJ,ldtdato, Hillary CLINTON'S haclc~a &·mall~ had not had groa1er ,mpa.cl on the carnp,:l1gr\.

2. Cor\l1nu1ng on ths~ !hr?rne. the senior leadsrshlp rtgure '~) rnmant8d that a stream or rurth&r h<Jckeu CLJNTON mn19r,al already llad baon Injected 1)'1 tha Kremlin Into complLru1t west&tt'l medw outlt:11s 11ka Wlkllsak:. . which rernrunad at laast --;.,ausibly <!gma.bte•. so th& stream of these would continue- 1t1rouyh October an.a up to tM El ltcllon. l"io1naver s/he understooct that ti re best rnaterim u·.e Rugs1m1s llad alr~ady was our a, ,0 lhart:) W&riiJ no real garna-changers to con,o

3

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Tho Ausslan Forn,gn M1 111stry ofl1c1a1. who had direct ,.i.:cess to the TRUMP support q Jural,or\, re3ported that PU1 IN was angry at h11; :subo1.:.hnato's "01J8r~promls,ng"' on th,a Rupubl1c an µresldenUal candidate, both 111 te,,,,s of hh, d )ancela and rahatnlity and being illl ,~ 1<J cowr arH1.'o, contt11n th-e US backlc.1.sh over Kr(J11\l!n 1nteJference. More h~acts U1i.lrelo re were likely to roU. with the MFA tt,e easiest t .. ugat. Ironically, desp,te •11-S t onslst~nt ur91ny 01 cautrOI'\ or, the ls.su~. Ferolgn Minister LAVROV could be the f"IEixt ctt-a to go • .o.sked to explain w1,y PUTIN ar1d the Krernlln had laund1ed such ar1 ag~r" SSl'we TRUMP suHxirt o~ratlon 11"1 thB t,rst pl~ea. th~ MFA offlcta.l so1u that Russi~ r\a.ed&d to ul)set the

iiboral lnt&rnational s tatus quo, Including on Ukralna-r..:i laled sanc11ons, which was ser1ously

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msadvantag1ng tha country. TA UMP was viewed as dtvb 1ve In disrupting the whole US pollttCill s>,:;tem: anll-Establlsflment; and ei pragrnatls1 11t 1!1 , wham they could oo bus1nass. As the TRUMP support oµeratton t1c1d gained momentum. <.onrrol o f ,t had passed l rom the MFA to the FSB Md then tnto the pras1d8'111tal admtrtistrallon •,,here 11 rGfl"latned. a reflection ol lls g,ov, 1ny slgni11caoc~ ovetr time. There was stlll a view In l'Ht Kremlin that TRUMP would conrinue cJS a (dlv1s1ve) pollucrd lorce ovon 11 he lost IM pros1ci1:tncy and may run lor and be elocteci lo tlnolher public o1hce.

12 Oclabt:Jr 20 16

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C"O!\lP:\NY IN'! Fl l t( a:NCF lt El'OKI 201(o/ J34

I·! L '.', I.\ L.., 1'1,l ~ I Df 'l I.\ l I.I l L 11 O:--:: l· LIU H LI< Dl.l \ 11 S OI· h. l{F \11 I .'\I LI,\ !SON v, ITI I

l'RL .\11' C \.\11 '.\ IC.'\1

- LI,,,.._, ,1s,o, 1,ll\.' nr Sl!L I !I N (t>niirm-. hi., !-1 ' , rd rmvting in \ i.,,;, 01,· \, 11h C:irtl'f PA< ,1 in July

- ::-.uu ... t.mu• uwlud,·d ,,ff,•r 11f lcHl:,• .,tal,..p m l{,,.,m,ft in r<'.'tur ,,1 liiltnl; ..;ilJ1,~twn:o on Ru-...;1a PACE ,·,111fi rm, this 1, I Hl ~ rr·,; 111knhon

'1l ( I I I'. , , ,11linut·d t,> tlu11l.. l RlitvfP n,utJ win rt,~1Cfonc. J f' l(• 17 (J,-t0b,•r '\,CJ\\ lool..lnb ll' 11?on ,·nt 111• lw, 1.•11g.1g,•11wnt wuh th~ L'~

- Kr l'mlm •11,1d,•r lnghlil'htl> import,\nc,' ,>I I RL MP' .... l.i,,·y, 1 \h1.h,wl 1...'0I !EN 1111.ovt>II rcL1ti,111-.h1p ,, 1th Rus'la.l . CO) ![N's wift) i-, oi Rus,;;i;m di?!-< •nl .md lwr (JthN :i lc:.,d1ni; properly dn t• J. ,p,•r in ;11,~ ... , ro,,

Detail

'>p,,.,kin)-; 1u ,1 tn1,h•d .-ompc1tnol :n n11J lld,-.l'<:'1 2016. a , .,,c.,t· ,h~ci..1k of Rosnctt Pr~..,,d..,11t .111 ! l'L II:\ ,ill\ 1601 · :,!:.Cl Iii'. el.ihor.1h•d l•n th1.• rl•portl .. ~Cl'l't ffil',.,.ttng bet\\'~'" the l,1tt1.:r .uhl Cm.:r P•\GE, 01 uS R<'puhlican prt•:,1d,' niL:>l l.andid., t0 ~ foreign poltry l1.:,1m, in '.\ lo:,cow in ft!!\ 2tll 1> l 1,,_. !'.CCr,'l '111.'t'!,ng had bt.'ltll l' l.lnfirmcd to hin , li.-r by" .... l' ll tor m,•mlx r uf ~rU llN'l, -.t .1!1 111 .,dd1tion lu b~ the lfo,111 ... ft l 11c)id1.-ot hun.~lf. It l '"~ pl~Kt: 011 eitlwr 7 m 8 July. thl'.' :-JnX' J,1~ or th._. lHl" Jlk'r C,1rt1tr PAGE m,1,k• a public ::.f><X',h i. , the Higher E(c,nomic <;cbool in 1,lch('('"I\\'

., In tt'flll'- fl! tlw i. Jb.,,t..tnl."C or tht•1r di~cu~:.ion, SEC! llN's i· -.ocialt> said that thl' Rosneft 1'1V,idt•n1 \\ ,,., '><> ~ ecn tu lift ~rS<.mal anJ cot porat~ we!:-t~·1 n sandiC'11,s impo!>l.'d on tlw con:p,ln~. th.it h1• offPrl-ti Pr\l ,E TRUtvtP' .,. a~ociatei. lht· !,rok~rn~c of up lo 3 19 per to.ml (p ri , ci ll-.t·~i ) ,ta "-,~ 111 !fo-.1wlt 111 1<:turn PAGE hdd t>xpru!>,.-d inteN:.I and l·onfirmed th..,t won:: n, L'~ ! P ~ k1.tt•d GS pi.•,11kn t, then -;anctwns on Russia \\ ,uld l~ Ii ftcd .

~ ·\,w nlin,; ,o '1Ll '! 11 ~·., dtN' a.,sod,,te, lhi:> Ro~wft Pre"-1 .ll·nl haJ {llnlinUL·<l to l,x,lh. .. vc that ! l,l' \ II' wu ld w i11 thl.' LS p1~:;iJcncy right up lo 17 Oti11t ,~~r, wh1:n lw ilb~'>St'<l lhis was no lnn8t'r po,-,1bk· <;t,e. I !IN w,,., h•,m to rn·,hlc1pt ;iccordin1~l·.1 ,:nd pu t k><:l0rs out t<:' OLIH'r bu,int•..,, and pohtk.11 u>nl,ll'h in tl11~ US in-;tc-c1J

-~ P~"~ ins '-<..'pJrnl<:ly h) tlw !,arne compatriot 1n mid-Och l··~r 2016, n K1w nlin im,i<ler with direct J1 t•.•:.:, to 1h1.: 11.'ad~r,hip confirmed U1a t o kc) role m the .,, (rct TRU~.{P campaign/ Kremlin rd ilit•n~lup wn!> bein plawd b ' the Re ublican candiJ ,rt0's pcr:..onal li\wwr Michael COi fF"'i -

CLMSJC00041420


S11u1<"~ ComnH.·Ul

; -.I l 111, ., ,h,;1w1.1tnlpt11L·d th,11 ;ilthuti~h I' \t,L h,1d nol ,t. h•d lt t•,plidtlv w <;EC! II N, lw liild dv,ll !\ ti11p,11·J th.it In h•rms 111 hi, l',)!1111H'nl fll1 ·r l{Ul\lP", lll'lll ltlll 11,, liit Ru:.•,i,11\ SJ1'Cllu11•, ,r d..-d1·,i i'"'"id" 111 h1• \\ .:i, "Jl<',1k1ng "1th tlw Rt•pubhl.lll c, 11 ,.lid.,tl··~ ,H1thonl)

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;...,.. - - - -~ -- ' .. - -- . - - - - -- -. . , -. ' ' .

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RUSSIA/US PRESIDENTIAL ELECfl ON: THE IMPOlff/\NT ROLE OF TRUMP 1.!\\VYER, COHEN IN CAMPAIGN'S SECRET LIAISO\ WITH T HE KREMLIN

Summa1-y

Detail

Kt emlin insidL·r C1utlincs important role play,·d by Tf{UM P's lawyer COHEN tn secret liaison w11h Ru'i!.ia11 lcJdcn. l1 p

COHEN cng.1gcd with Ru-;~ian~ in trying lo Ct>\' .-r up scandal of MANA FORT and exposure ol PAGE and meet. <rcmlln ofl1cials secretly in tht• FlJ in August in pursuit (>ftl11s go.ii

Thes<.: secret contacts continUl' but nrc now Li. med out to trusted agents in Kn:mli n -linkcd institutes so ,Ji, to rcmntn · 1 ,ilUSibly deniable" for Rus ian regime

Furthl'r LOnfirmat1011 lhJt :;acki11g of IV I\NO\ nd .:ippointmencs of VA INO ,rnd Kl RIYF.N KO li11l,1:d to t!l'vd to c.ovcr up 1(1 emlin's TRUMP support opcr,llion

l. Speaking in confidence tu a longstanding co.npatrict friend in mid· October 2016, a Kremlin insider highlighted t nc importance of Republican presidential candidate Donald TRU MP's lawyer. Michael COHEN, in the ongoing secret liaison relatio11:,hip between the New York tycoon's campaign and the Russian lcadcrsl.1p. COHEN's role had grown following rhc tlC'parturc of Paul MANNAFORT :1s TRUMP's u1mpaign managet in August 2016. Prior lo that MAN \J .\FORT had led for the TRUMP ~ide.

2. Accort.Jiug to tht: Kreml in insider, COHEN now was heavily engaged in a rnvc1 up arid damage limitation opcr.ttion i.i ,he allcmpt to prevent the full details of TRUMP'!> 1 cl,llionshir> with Ru·, ia being exposed. In pursuit 01 this aim, COHEN had met secret!) ,. 1idt several Russit1n f'n•sidcnlial Administration (PA) Lt•~al Oep 11 tmcm offidal:dn iln EU country 111 August 2016. ThL" immediate iss1., ., hod been to contain tm thcr scandals in\'olving MANNAl·ORT's c-., .11 mercial and political role 1n Russia/Ukraine ;rnd to limir the damage ,,1 "ing from exposure of tnrmer TRUMP foreign policy advisor. Cart<!' PAGE's ~ecret meetings with Russian leadership figures In Mm~cow u .c previous month. The

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ov.:?rall objective had l>t>en to "tu sweep it all ui:dcr 1he carpel and 111.Jk<' Sllrc no connect ions could br lully t•stnblishcd ,}r proven"

3. Things had become cvcn .. hotter·· sim.c i\ug11s1 on the TRUMP-Russia tr.ick 1\rcording to thc 1<1 cmlin insidi.:r. this Lt.I meant that direct mntnct hct wct:11 the TRUM I' lcnm .ind Russia had be ., farmed oul by the Kremlin tu trusu .. •d ng1mts ot inflt1cnc.:c workint, in pro-government policy institmes like that of Law and Compilralivc ]l. r 1sprudcncc. COIi E~ however continued rn le,1d for the TRUMP k 1 ,

4. Rcfening back to the (su rprisc) sacking of SE:qci l VAN OV .is Head of PA in August 2016. his replacement by Anton VAi ·wand the appointment of former Russian pr('111icr Sergei KIRIYENKO tu 1nothcr senior position in the PA, the Kremlin Insider rcpi:nted th,lt thi~ :iad been directly wnnecled lo the TRUMP support operation •. r,d the need to cover up now that it was being exposed by the: USG am! in th , western media.

Company Commcnl

The 1-:rcmlin insider wa.s unsure of the idemfucs oft 1 • P,\ officials wi th whom COHEN met sen"t'tly In Augu!>t, or the <:x.1ct datc/s a·HI locations of the mceting/s. There were significant i111crnal securiry h,• rricrs being erected in Lhc PA as t.he TRUMP issue became more contro\'e rsial ,,nd damaging. However s/hc continued to try to ohtain these.

J 9 October 2016

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US/RUSSlA: FURTHER DETAILS OF SECRET OJALOt;lJE BETWEEN TRUMP CAMPAIGN TEAM, !<REMLIN ANO ASSOCIATED H1\CKERS IN PRAGUE

Summary

rnUMI'':; rq>rt'!,.('l ll.tlivc COHEN accontp:irne,, n f'r,lguc m /\ug11st/St.'pl c:m bl·r 20 16 by 3 coll1!Jgucs for:,, 1c·t d1scu~slons with !<rcrn hn rl'presc11tat1vcs Jnd a:-:-octated 1">per,, :,,rs/hac:kcrs

Agt-nda Included how to prorcss deniable ras11 ;,ayment~ lo opn,1tives; , 01111ngcrlly plt1n <; for covcnng up opi:1 Jl1<>11s. nu Jetton 1n event of a CLINTON eltxtio11 victory

Sv111c: furthc1 dPt,111:i ot Ru,;s1:1n rl.'prCSC'lll,lli \ , /ope, at1vt•S tr1Vt)!ved; Rom.rnian h.ickt·r s 1:111ploycd :,nd US\.' o( Bulg I i,1 as bole hole to "lie lowft

Anti-Cl INTON hJcken ~nd otlwr opl'rativcs J u by bolh TRUMP team .in<l l{n•mhn, but with ulumatc 1oy<1lty to Hl'a• ,r PA. IVANOV ant.I hrs SllCtl?S!>Of / s

Detail

J. We rcpnrn•d prcvmusly {201 h/ 135 and / 13£ J ,1n secret mecling/s held 1r1 Pr ,1gw: . C.1.l·Ch RcpJl>l11: tr1 /\u~usl 2016 bet:. t·Cn then Rep\lbhcan pr~'i1dl'ntnl c.111drd,11e Don..ild ffHJM P's rcpr, ~·ntauvc, Michael COHEN .inJ hi:. i11tc1 !Clr.tll<H:i from the Kremlin v.•ark1n i under cover of Ru:,siao !IJGO' Ros!>ot rudnichcstvo.

2.

prnv1dcd furtht·r U\!l.iils of tli~st· meeting/s a11 I ..associated ,mti· Ci IN ru •"\ /!kmocr,1ric Pa rt)' op1:r,1rions. C:011 r l h acl hl'cn ,'lccom,lJ nied rn l 'r.ir,.ie by 3 rnllc..i~u<'s ancl the: 11ming ol lt.c visit was either in the last wt•ck of Augu-; t or th~ first week of Septemb< , One of their main Russian ,nrnlorulon, was Oleg SOLODllKIHN opc1at11 : umh~r RPs,11t111d111chestvo cov:ir. Acc·,1 ding tr--·- ---~--· the agenda rnnipr1sed qucst1011s 1>11 how l.ll 1H,1bk• cash p n,ents we:re to b~ rnt1de to hacker~ who had worked i11 Europe uniti!r K11 Hlin diret tion against the CLl"JTON campaign and v.mous connng<.'11ti1 mr covPrmg up th~se orerncions and Mos~ow's serrN liaison with t e TIWMP team more geni:rally.

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3. reportt?d tha! over lhc pi r .ud M.irch-Septcmber 2016 a company called and its aifi li.,1,·~ had been using beaners a11d porn traffic to trJn•;in11 vin1Sl'S, plant bu , 'it<•al d;ira and cor1d11rt ~ t1ltcring op1;t ,lllllll,." .1g.1111st lhP Demon ,1tit I 11 !y lec1Ch!1~hip. Enlltic!: linked lll 011 'Vt' l"t! 111volV!·d ,ind ht' and another hacking exp<!rl, both 11.?cru1tcJ under duress •>:. rhe FSH-

• wcres1gn1 f1c.rn1 players in tl11 operation. In Pr<1guc. CllHEN ..igrccd wn1111grnr) pl.in~ for vanou~ •. 1'n,1nos to protccr the oper,H1on, blll in p<1rta:ul,1r wh.11 \V'JS to bed 11 , . in tlw cvc1H that Hillary CLINTON won th<' pr1?s1dency It w.,s 11nport.,11t ,n 1h15 event that :ill CJsh flJymcllls owed were 111.1d1• q111rkly .ind d1sc1, ,·tly .,ncl rJ iat rybcr and orht'.'r opl.!Tctlo1 s we, t> :.tuod tfow11/Jhh: ru go , l.:dtvc!y to ground lO wwr their traces ('v\11! rqior't<'tl t'ol1 liN tlut 11 1nvolvcmcnt of poli<icJI Op1.•rJtivcs P.1ul MANA FORT ,ind CJrtt!r Pi\G I. ,·1 the :-cuct TRllfl.lPKrl'lllhll li,11so11 had been expo~ctl in tlw mc<I ,. 1n the run-up to Prague .ind th.11 d.1111.igc l11nit.t11<>1 vf the:.~· also ,,·as ! !iCus~cd by COi/EN wtth the Kremlin ~prcsem:it,vc:.).

4. In terms of pr Jct 1l"'JI mca~urt·i. to be t:1kcn. 11 ,,,. ,., agreed by the rwo sides 111 Prague> 10 s1~nct down \•,1nous "Korn,111,an I •1 kcri.» (pn•,umJlily b,1~cd in thl!ir homt;<l.rnd m ndghhourn1g t•,t s !Nn E, .. 1pc) ,11Hl th,1L other op~, Jt1vt>s shoulu he.id 101 J bolt-hole III Pio, d1 \, lfolgana whcr1:: they sltuuld -1.iy low· On p.iynicni:.. IVt\NOV'::, as~.1. 1.1tc s<1id that 1hc opcr,1t1\'l'S lllvol\'t·d h.1d ht•cn pJ1d b} bnlh T1:1 MP's tc:i1n Jnd the Krcni ltn, though tht·11 ordc1 s ;md ultimate lo) , ty lay with IV1\NOV. as Ht:,ul of th e Pl\ .int.I thus uh i11 1Jtt!ly rcsponsibk lot the opcr.llion. am! his des1gn<1tt-d .\.lltct.'i.sor /!> .1ft1:r h1c· w.is d1c;nuss1 , ! hy pr~s1den1 PUTIN 111 con neu ion with 1111· .111 ti · C:LI NTON operatio n 111 mid August.

13 December2016

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EXHIBIT

t..,I l -r~ ~· ,9;) . I '

IN THE HIGH COURT OF JUSTICE

QUEEN'S BENCH DIVISION

/ ·.-t: cffa'1fii.No. Q11Doo413 !

BETWEEN:--, APR 2017

' ,----· "?

(1) ALEKSEJ GUBAf\~~ ..... ,JUD ,q_"-· (2) WEBZILLA B.V. ''<lC•N f)X'"'

(3) WEBZILLA LIMITED -'·'-"--~ (4) XBT HOLDINGS S.A.

-and-

(1) ORBIS BUSINESS INTELLIGENCE LIMITED (2) CHRISTOPHER STEELE

DEFENCE

Claimants

Defendants

References in this Defence are to paragraphs in the Particulars of Claim unless otherwise stated.

Introduction

1. Save that it is admitted that the Second and Third Claimants are hosting infrastructure companies based in the Netherlands and Cyprus respectively, no admissions are made as to paragraphs 1 and 2.

2. Paragraphs 3-5 are admitted.

3. Orbis was founded in 2009 by the Second Defendant and Christopher Bu.rrows.

4. The Second Defendant and Christopher Burrows were formerly senior and experienced Crown servants in the Foreign and Commonwealth Office.

5. Sir Andrew Wood GCMG was the British Ambassador to Moscow between 1995 and 2000. He is an Associate Fellow of the Russia and Eurasia Programme at the Royal Institute for International Affairs at Chatham House. He is also an Associate of Orbis.

1

6. Fusion GPS ("Fusion") is a consultancy based in Washington DC providing research, strategic intelligence and due diligence services to clients.

7. Prior to the events in issue in this case the Defendants had developed a working relationship with Fusion over a number of years.

8. At all material times Fusion was subject to an obligation not to disclose to third parties confidential intelligence material provided to it by the Defendants in the course of that working relationship without the agreement of the Defendants.

The pre-election memoranda

9. Between June and early November 2016 Orbis was engaged by Fusion to prepare a series of confidential memoranda based on intelligence concerning Russian efforts to influence the US Presidential election process and links between Russia and Donald Trump.

10. The Defendants produced sixteen such memoranda. These will be referred to for convenience as "the pre-election memoranda", having been prepared before the 2016 US Presidential election. The last one was produced in the latter part of October 2016. None were produced in November 2016. None of the pre-election memoranda contained any reference to, or intelligence about, the Claimants.

11. As an Associate of Orbis, Sir Andrew Wood was aware of the Second Defendant's intelligence gathering for the pre-election memoranda.

Senator John McCain

12. Senator John McCain is the Chair of the US Senate Armed Services Committee and a member of the US Senate Committee on Homeland Security and Governmental Affairs.

13. David Kramer is a former US State Department civil servant and was US Assistant Secretary of State for Democracy, Human Rights, and Labor from 2008 to 2009. He is the Senior Director for Human Rights and Human Freedoms at Senator McCain's Institute for International Leadership.

14. After the election of Donald Trump as the 45th President of the United States on 8 November 2016, Sir Andrew Wood met Mr Kramer and Senator McCain. As a result of their discussions Sir Andrew arranged for the Second Defendant to meet Mr Kramer, as the representative of Senator McCain, in order to show him the preelection memoranda on a confidential basis.

2

15. The meeting between the Second Defendant and Mr Kramer took place on 28 November 2016 in Surrey. Mr Kramer told the Second Defendant that the intelligence he had gathered raised issues of potential national security importance.

16. An arrangement was then made upon Mr Kramer's return to Washington for Fusion to provide Sen. McCain with hard copies of the pre-election memoranda on a confidential basis via Mr Kramer.

17. On behalf of Sen McCain, Mr Kramer requested to be provided with any further intelligence gathered by the Defendants about alleged Russian interference in the US Presidential election.

The confidential December memorandum

18. The Defendants continued to receive unsolicited intelligence on the matters covered by the pre-election memoranda after the US Presidential election and the conclusion of the assignment for Fusion.

19. After receiving some such intelligence the Second Defendant prepared the confidential December memorandum, referred to at paragraph 8. 1, on his own initiative on or around 13 December 2016.

20. The Defendants considered, correctly, that the raw intelligence in the December memorandum:

a. was of considerable importance in relation to alleged Russian interference in the US Presidential election;

b. had implications for the national security of the US and the UK; and

c. needed to be analysed and further investigated/verified.

21. Accordingly the Second Defendant provided a copy of the December memorandum to:

a. A senior UK government national security official acting in his official capacity, on a confidential basis in hard copy form; and

b. Fusion, by enciphered email with an instruction to Fusion to provide a hard copy to Sen. McCain via Mr Kramer.

Liability for the publication complained of

22. Save that it is admitted that the words complained of and set out therein were contained in the confidential December memorandum, paragraph 6 is denied.

3

23. It is denied that in their natural and ordinary meaning, in their proper context, the words complained of bore or were capable of bearing the meaning pleaded at paragraph 7.

24. Read in context the natural and ordinary meaning of the words complained of was that there were grounds to investigate whether the Claimants had been coerced by Russia into hacking the computers used by the US Democratic Party leadership, transmitting viruses, planting bugs, stealing data and conducting altering operations.

25. Save insofar as it is admitted above paragraph 8.1 is denied.

26. The first sentence of paragraph 8.2 is noted. This is understandable. The contents of the December memorandum were highly sensitive and the Defendants only disseminated copies of it in strict confidence as aforesaid.

27. The remainder of paragraph 8.2 is, in the premises, denied in its entirety.

28. Sub-paragraphs 8.2.1, 8.2.2 and 8.2.4 are admitted.

29. As to sub-paragraph 8.2.3:

a. In so far as this sub-paragraph refers to the pre-election memoranda:

i. The first sentence is too vague for the Defendants to plead to in any meaningful way;

ii. The second sentence is denied;

b. In so far as it refers to the confidential December memorandum:

i. The first sentence is again too vague for the Defendants to plead to in any meaningful way. The December memorandum was provided to the recipients identified above so that that the information in it was known to the United States and United Kingdom governments at a high level by persons with responsibility for national security;

ii. The second sentence is denied.

30. The first sentence of sub-paragraph 8.2.5 is noted. The Defendants did not, however, provide any of the pre-election memoranda to media organizations or journalists. Nor did they authorize anyone to do so. Nor did they provide the confidential December memorandum to media organizations or journalists. Nor did they authorize anyone to doso.

31 . The second sentence of sub-paragraph 8.2.5 is denied.

4

32. Save that it is admitted that the Second Defendant gave off the record briefings to a small number of journalists about the pre-election memoranda in late summer/autumn 2016, sub~paragraph 8.2.6 is denied.

33. Paragraph 8.3 is admitted but liability for such publication resides with BuzzFeed.

34. No admissions are made as to paragraph 8.4.

35. Paragraph 8.5 is denied. The Defendants are not liable for publication by BuzzFeed.

Qualified privilege

36. Further or in the alternative, the confidential December memorandum was published by the Defendants, as pleaded at paragraph 21 above, in good faith, on an occasion of qualified privilege.

37. In the circumstances set out above the Defendants were under a duty to pass the information in the December memorandum to the senior UK government national security official and Sen. McCain so that it was known to the United Kingdom and United States governments at a high level by persons with responsibility for national security. These recipients had a corresponding duty or interest to receive it in their capacities as senior representatives of those governments with such responsibilities.

38. The incidental publications to Fusion and Mr Kramer were reasonable as a means of bringing this sensitive document securely to the attention of Sen. McCain.

39. The Defendants did not publish the December memorandum to any of the said recipients with the intention it should be republished to the world at large nor did they ask any of them to republish the December memorandum to others. If any of the recipients did so with the result that it was published to the world at large the Defendants, in the circumstances, retain the protection of qualified privilege.

Harm

40. In relation to paragraph 9, it is admitted that publication of the words complained of by BuzzFeed (or any subsequent internet republication of those words by third parties) was likely to cause serious harm to the reputation of the First Claimant. Save as aforesaid, paragraph 9 is not admitted. In particular, it is not admitted that the publication of the words complained of by BuzzFeed (or any such subsequent republication) has caused serious financial loss to any of the Claimants or that it is likely to do so in future. The Claimants are required to prove the existence and extent of any past financial loss and/or any likely future financial loss caused by the publication of the words complained of.

5

41. Paragraph 10 is noted. It is not admitted that the law of each of the jurisdictions in the European Union in which the words complained of were published was and is, so far as material, the same as the law of England and Wales.

42. In relation to paragraph 11:

a. Paragraphs 23 and 24 above are repeated and sub-paragraph 11.1 is denied;

b. Sub-paragraph 11.2 is admitted but it is denied that the Defendants published or caused the publication of the words complained of extremely widely;

c. Sub-paragraph 11.3 is not admitted;

43. The first sentence of paragraph 12 is not admitted.

44. In relation to the second sentence of paragraph 12, it is denied that the Claimants are entitled to claim damages, whether aggravated or otherwise, against the Defendants as opposed to BuzzFeed.

45. In relation to paragraphs 12.1 and 12.2, it is admitted that the Defendants did not contact the Claimants prior to the publication of the words complained of by BuzzFeed. In light of the matters pleaded above the Defendants had no reason to contact the Claimants in relation to the publication of the December memorandum by BuzzFeed.

46. Paragraph 12.3 is denied. The First, Second and Third Claimants sent a letter before action to the Defendants on 23 January 2017. The Defendants acknowledged receipt of the letter before action through a letter from their former solicitors, Schillings, on 30 January 2017. The Defendants then provided a detailed response to the letter before action four days later on 3 February 2017. The Defendants pointed out that the Claimants' letter before action did not meet the requirements contained in the PreAction Protocol for Defamation. In particular the letter before action:

a. stated that McDermott Will & Emery were instructed by "affiliates' of the Second and Third Defendants, but did not provide the names or any details of those "affiliates". Nor did it state whether McDermott Will & Emery were instructed by the Fourth Claimant;

b. did not identify the particular publication(s) that were the subject of the prospective claim, contrary to paragraph 3.2 of the Pre-Action Protocol for Defamation;

c. did not identify the meaning that the First to Third Claimants attributed to the words complained of, contrary to paragraph 3.3 of the Pre-Action Protocol for Defamation.

The Defendants therefore requested the Claimants to provide the necessary information in order to enable the Defendants to provide a full response to the

6

proposed claim. Notwithstanding the fact that the Defendants provided a detailed response to the Claimants' letter before action within 11 days of that letter being sent. and notwithstanding the numerous deficiencies in the letter before action, on 3 February 2017 the Claimants issued and served proceedings on the Defendants. In the circumstances, the Claimants' decision to issue proceedings less than two weeks after the letter before action was precipitous, incompatible with the overriding objective in the Civil Procedure Rules, and breached the requirements of the Preaction Protocol for Defamation.

47. It is denied that the Claimants are entitled to an injunction against the Defendants as pleaded in paragraph 13 of the Particulars of Claim or at all.

GAVIN MILLAR Q.C.

EDWARD CRAVEN

STATEMENT OF TRUTH

The Defendants believe that the facts set out in these Particulars of Claim are true.

Signed:

Position:

Date:

TBH23475964 v1

Christopher Steele

Director, Orbis Business Intelligence Ltd

03 April 2017

7

IN THE HIGH COURT OF JUSTICE QUEEN'S BENCH DIVISION

BETWEEN (1) ALEKSEJ GUBAREV

{2) WEBZILLA B.V. (3) WEBZILLA LIMITED (4) XBT HOLDING S.A

and

EXHIBIT ._s,-

.-·d i:) · I ·- )

Cl . ~-aim no. n"" •. - _

Claimants

(1) ORBIS BUSINESS INTELLIGENCE LIMITED (2) CHRISTOPHER STEELE

Defendants

DEFENPANTS' RESPONSE TO CLAIMANTS' REQUEST FOR FURTHER

INFORMATION PURSUANT TO CPR PART 18

Under paragraphs 7 and 8

Of: "At all material times Fusion was subject to an obligation not to disclose to third parties confidential intelligence material provided to it by the Defendants in the course of that working relationship without the agreement of the Defendants."

REQUESTS

1. Whether the alleged duty of confidentiality is said to arise by contract or in equity.

2. If by contract, state whether the duty arose under (a) a general contract of retainer; or (b) specific contracts relating to the specific work.

3. In either event state whether any contract(s) relied on were written or oral; if oral, stating when and between whom they were made.

RESPONSE

The duty arose both by contract and in equity. A written non-disclosure agreement was concluded between the First Defendant and a representative of Fusion in January 2010 in relation to work conducted by Fusion for the First Defendant. Furthermore, Fusion was aware of the confidentiality of intelligence reports through the course of business with the Defendants and, in relation to the disclosure of the memoranda to Mr Kramer, the Second Defendant and Fusion had had specific discussions in which the confidentiality of the memoranda had been emphasised and Fusion was instructed to inform Mr Kramer of their confidentiality.

REQUEST

• 1 • RPC

4. State whether the alleged duty not to disclose such intelligence to 'third parties' without the prior agreement of the Defendants in the course of the working relationship extended to disclosure by Fusion to their own clients (ie the clients who had commissioned the intelligence material : see paragraph 6 of the Defence).

RESPONSE

In relation to the pre-election memoranda the duty not to disclose intelligence to third parties without the prior agreement of the Defendants did not extend to disclosure by Fusion to its client(s), although the Defendants understand that copies of the memoranda were not disclosed by Fusion to its client(s).

In relation to the December memorandum, this was not prepared pursuant to any contract as stated at paragraph 18 of the Defence. The duty not to disclose this intelligence report to third parties without the prior agreement of the Defendants therefore did extend to disclosure by Fusion to its client(s).

REQUEST

5. State whether the Defendants owed any reciprocal duty of confidence to Fusion and/or Fusion's clients in relation to the intelligence they provided.

RESPONSE

Since it was not produced pursuant to the engagement with Fusion described at paragraph 9 of the Defence, the Defendants did not owe any obligation of confidence to Fusion and/or Fusion's client(s) in relation to the intelligence contained in the December memorandum.

REQUEST

6. State whether Fusion's clients, insofar as disclosure to them was permitted (see Request 4), were under any duty to the Defendants and/or Fusion not to (a) use and/or (b) disclose the intelligence, and, if so, give like particulars as to how that duty is alleged to arise.

RESPONSE

The response to question 4 above is repeated. The Defendants understood that the arrangement between Fusion and its client(s) was that intelligence would not be disclosed. As explained above, the December memorandum was not produced pursuant to the engagement referred to at paragraph 9 of the Defence and therefore disclosure of the December memorandum to their client(s) was not permitted.


Of "Between June and early November 2016 Orbis was engaged by Fusion to prepare a series of confidential memoranda based on intelligence concerning Russian efforts to influence the US Presidential election process and links between Russia and Donald Trump".

REQUEST

. 2. RPC

7. Please identify (see paragraph 6 of the Defence) Fusion's client(s) in relation to this particular engagement.

RESPONSE

This request is neither reasonably necessary nor proportionate to enable the Claimants to prepare their own case nor to understand the case they have to meet.

Of "The Defendants produced sixteen such memoranda. These will be referred to for convenience as 'the pre-election memoranda', having been prepared before the 2016 US Presidential election. The last one was produced in the latter part of October 2016. None were produced in November 2016. None of the pre-election memoranda contained any reference to, or intelligence about, the Claimants".

REQUEST

8. In view of the assertion that no memoranda were produced in November 2016, please state the nature of the engagement in early November 2016 as referred to in paragraph 9, and whether this engagement was performed and what intelligence it related to.

RESPONSE

The nature of the Defendants' engagement by Fusion did not change during the period between the preparation of the last pre-election memorandum on 20 October 2016 and the date of the US Presidential election. However since the Defendants did not receive any relevant intelligence concerning Russian efforts to influence the US Presidential election process and links between Russia and Donald Trump during this period, no memoranda were produced pursuant to the engagement after 20 October 2016.


Of "Senator John McCain is the Chair of the US Senate Armed Services Committee and a member of the Us Senate Committee on Homeland Security and Governmental Affairs" and "David Kramer is a former US State Department civil servant and was US Assistant Secretary of State for Democracy, Human Rights, and Labor from 2008 to 2009. He is the Senior Director for Human Rights and Human Freedoms at Senator McCain's Institute for International Leadership".

REQUEST

9. Please confirm (as paragraph 29b(i) of the Defence suggests) that Senator McCain and Mr Kramer are alleged (a) to have been acting in these official capacities; and (b) only in relation to those capacities in the course of the matters pleaded in paragraphs 14 to 17 and 21 b; and, if not, identify any other capacity in which they were acting and when and for what purpose(s).

RESPONSE

. 3. RPC

The Defendants believed that Senator McCain and Mr Kramer were acting only in their official capacities and were not informed of any other capacity or purpose in which they were acting. There were no grounds that led the Defendants to suspect that Senator McCain and Mr Kramer were not acting in their official capacities at any time up to and including the publication of the December memorandum to Mr Kramer.

Under paragraph 14

Of "As a result of these discussions Sir Andrew arranged for the Second Defendant to meet Mr Kramer, as the representative of Senator McCain, in order to show him the pre-election memoranda on a confidential basis".

REQUEST

10. State what is meant by 'on a confidential basis', indicating precisely what use or uses Senator McCain was/were permitted to make of the pre-election memoranda and whether these uses were specified to Senator McCain and Mr Kramer.

RESPONSE

The Defendants understood that the contents of the memoranda would be treated in the strictest confidence and would only be used by Senator McCain in his official capacity for the sole purpose of analysing, investigating and verifying their contents to enable such action to be taken as necessary for the purposes of protecting US national security. The Second Defendant expressly informed Mr Kramer that the pre-election memoranda were only to be used for this exclusive purpose before he showed Mr Kramer any of the memoranda. Mr Kramer was not at this time provided with copies of the memoranda that had been prepared as at that date, but was shown copies.

Under paragraph 18

Of "The Defendants continued to receive unsolicited intelligence on the matters covered by the pre-election memoranda after the US Presidential election and the conclusion of the assignment for Fusion".

REQUEST

11. Please state whether such intelligence was actively sought by the Second Defendant or merely received (as presently pleaded).

RESPONSE

Such intelligence was not actively sought; it was merely received .

Under paragraph 19

-4. RPC

Of "After rece,vmg some such intelligence the Second Defendant prepared the confidential December memorandum, referred to at paragraph 8. 1, on his own initiative on or around 13 December 2016".

REQUEST

12. Please state whether the words 'on his own initiative' mean that the December memorandum was not (a) created; or (b) provided to Fusion pursuant to any contract. If not, please specify the contract in question.

RESPONSE

The December memorandum was not created or provided to Fusion pursuant to any contract.

Under paragraph 20

Of "The Defendants considered, correctly, that the raw intelligence in the December memorandum: a. was of considerable importance in relation to alleged Russian interference in the US Presidential election; b. had implications for the national security of the US and the UK; and c. needed to be analysed and further investigated/verified".

REQUEST

13. Please state whether the Second Defendant only reached this conclusion on behalf of the First Defendant or whether Christopher Burrows and/or Sir Andrew were party to his assessment.

RESPONSE

The Defendants' assessment that the pre-election memoranda and any subsequent related intelligence which they received should be disclosed to the individuals referred to at paragraph 21 of the Defence was reached following separate discussions between the Second Defendant and (i) Christopher Burrows of the First Defendant; (ii) Sir Andrew Wood (who had spoken with Senator McCain); (iii) David Kramer (who was acting on behalf of Senator McCain) and {iv) the UK national security official referred to at paragraph 21(b) of the Defence. Mr Burrows shared the Second Defendant's assessment at the relevant time. The Defendants considered that the issues were self-evidently relevant to the national security of the US, UK and their allies and that subsequent intelligence relating to these issues ought to be disclosed to the individuals referred to at paragraph 21 of the Defence. Each of the individuals with whom the Second Defendant discussed the issue shared this view at the time and, to the Second Defendant's knowledge and belief, continue to hold that view.

- 5- RPC

Under paragraph 20c and 21

REQUEST

14. Please state whether the December memorandum was provided to (a) the UK national security official; and/or (b) Fusion; and/or (c) Mr Kramer and Senator McCain with the source of the allegations against the Claimants redacted or not.

RESPONSE

Information pertaining to the status of the source(s) of the intelligence contained within the December memorandum was not redacted when it was provided to either the UK national security official and/or Fusion and/or Mr Kramer and Senator McCain. The information contained within the intelligence reports pertaining to the status of the source(s) was consistent with the Defendants' conscious efforts to protect the identity of the source(s).

REQUEST

15. Please state whether the instruction to Fusion contained any express reference to confidentiality (contrast paragraph 21a which expressly refers to 'on a confidential basis').

RESPONSE

In the Second Defendant's communications with Fusion surrounding the provision of the instruction by enciphered email, it was explicitly stated that the memoranda were only to be provided to Mr Kramer for the purpose of passing them on to Senator McCain. Substantive conversations between the Second Defendant and Fusion relating to this matter were conducted using secure telephone communications. During those secure communications, the Second Defendant expressly emphasised that the December memorandum was subject to the same strict restrictions on disclosure to third parties as were contained in the written agreement described in the response to requests 1 to 3 above.

Under paragraph 21a and b

Of "Accordingly the Second Defendant provided a copy of the December memorandum to: a. a senior UK government national security official acting in his official capacity, on a confidential basis in hard copy form; and b. Fusion, by enciphered email with an instruction to Fusion to provide a hard copy to Sen. McCain via Mr Kramer".

REQUEST

16. Please state whether intelligence provided by the Defendants to Fusion was generally provided in enciphered form.

-6- RPC

RESPONSE

Intelligence provided by the Defendants to Fusion was provided securelyand where provided electronically it was provided in enciphered form.


Of "It is denied that in their natural and ordinary meaning, in their proper context, the words complained of bore or were capable of bearing the meaning pleaded at paragraph 7" and "Read in context the natural and ordinary meaning of the words complained of was that there were grounds to investigate whether the Claimants had been coerced by Russia into hacking the computers used by the US Democratic Party leadership, transmitting viruses, planting bugs, stealing data and conducting altering operations".

REQUEST

17. Please identify the context relied on and the reader(s) to whom it was allegedly known.

RESPONSE

The readers referred to are the readers of the December memorandum who accessed and read the words complained of via the article that was published on the BuzzFeed website on 10 January 2017.

The December memorandum was a raw intelligence report which contained information gathered from a confidential source(s) about various national security issues that warranted further investigation.

Further, the words complained of were published by BuzzFeed as part of an article which stressed that the contents of the dossier (which included the December memorandum) were "unverified", "unconfirmed' and contained "unverified, and potentially unverifiable allegations". The article added that, "BuzzFeed News reporters in the US and Europe have been investigating the alleged facts in the dossier but have not verified or falsified them." The article reported that the President-elect's attorney, Michael Cohen, had said that allegations in the dossier «were absolutely false".

In these circumstances, readers of the words complained of were therefore aware that (i) the contents of the December memorandum did not represent (and did not purport to represent) verified facts, but were raw intelligence which had identified a range of allegations that warranted investigation given their potential national security implications; (ii) persons mentioned in the December memorandum were unlikely to have been approached for comment, and therefore many of those persons were likely to deny the allegations contained in the raw intelligence; and (iii) while the December memorandum was prepared in good faith, its content must be critically viewed in light of the purpose for and circumstances in which the information was collected.

• 7 - RPC

Under paragraph 32

Of "Save that it is admitted that the Second Defendant gave off the record briefings to a small number of journalists about the pre-election memoranda in late summer/autumn 2016, sub-paragraph 8.2.6 is denied".

REQUEST

18. Please identify the journalists briefed by the Second Defendant and state when and how the briefing was done in each case and the gist of what was conveyed.

RESPONSE

The journalists initially briefed at the end of September 2016 by the Second Defendant and Fusion at Fusion's instruction were from the New York Times, the Washington Post, Yahoo News, the New Yorker and CNN. The Second Defendant subsequently participated in further meetings at Fusion's instruction with Fusion and the New York Times, the Washington Post and Yahoo News, which took place in mid-October 2016. In each of those cases the briefing was conducted verbally in person. In addition, and again at Fusion's instruction, in late October 2016 the Second Defendant briefed a journalist from Mother Jones by Skype. No copies of the pre-election memoranda were ever shown or provided to any journalists by, or with the authorisation of, the Defendants. The briefings involved the disclosure of limited intelligence regarding indications of Russian interference in the US election process and the possible co-ordination of members of Trump's campaign team and Russian government officials.

REQUEST

19. Please state what is meant by 'off the record' and, in particular whether it means:

(a) The information provided was not to be published (but might be used);

(b) The information might be published but not attributed to the Defendants in any way;

(c) As (b), but the Defendants could be generically described, but not by name.

RESPONSE

The Second Defendant understood that the information provided might be used for the purpose of further research, but would not be published or attributed. The Defendants repeat that no off the record briefing ever took place concerning the December memorandum, and no copies of any of the pre-election memoranda or the December memorandum were ever provided to journalists by, or with the authorisation of, the Defendants.

REQUEST

20. Please state whether these terms were agreed to by the journalists concerned.

• 8 - RPC

RESPONSE

The Second Defendant was told by Fusion that the terms had been explained to the relevant journalists in advance by them and the Second Defendant reinforced the basis on which he was speaking to each of the journalists he met in person. None of the journalists raised any objection.

Under paragraphs 36 to 39

REQUEST

21. Please state whether the defence of qualified privilege is relied on by the Defendants if they are held to be liable for publication to the world at large as distinct from the admitted publication to the individuals identified by the Defendants in the Defence.

RESPONSE

Yes.

STATEMENT OF TRUTH

The Defendants believe that the facts stated in this Response are true.

Signed:

Position:

Date:

Nicola Cain

Legal Director, RPC; Defendants' legal representative

18 May 2017

-9- RPC

TBH23772701 v1

Claim No. HQ17D00413

IN THE HIGH COURT OF JUSTICE QUEEN'S BENCH DIVISION

BETWEEN

(1) ALEKSEJ GUBAREV

(2) WEBZILLA B.V.

(3) WEBZILLA LIMITED

(4) XBT HOLDINGS.A.

Claimants

and

(1) ORBIS BUSINESS INTELLIGENCE LIMITED

(2) CHRISTOPHER STEELE

Defendants

DEFENDANTS'RESPONSETO PART 18 REQUEST

RPC Tower Bridge House St Katharine's Way London E1W 1AA T: 020 3060 6000

Reference: ORB4.1

Solicitors for the Defendants

Bill browder

Offshore - Cyprus

133m shares

Companies

Not invest - loan

Value in Cyprus as inter

Illici

Active sponsors ofRNC

Browder hired Joanna Glover

Tied into Cheney

Russian adoption by American families

CONFIDENTIAL TREATMENT REQUESTED ~lOT FOR CIRCULATION.' COMMITTEE MEMQERS AMO STA ff ONLY


EXHIBIT

~

PJM-SJC-00000002

llrn rrrt 5urcs - just security · 8/22/2017 · cunningham levy muse llp 1250 connecticut ave,...

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