Simpson Exhibits Redacted

EXHIBIT
l lrn rrrt 5urcs 5 rnatt

' :S,, ;°if· .· .. 1 ·! • • •-:·
August 3, 2017
VlA ELECTRONIC TRANSMISSION

Joshua Levy
Cunningham Levy Muse LLP
1250 Connecticut Ave, N.W .
Washington, D.C. 20036
Dear Mr. Levy:
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.
Sincerely,
Charles E. Grassley Dianne Feinstein

Chairman Ranking Member
EXHIBIT
?:
08.17.2017 Privilege Log in Response to ReQuest for Internal Communications Related to Fusion GPS Communications with Conj?ressional Memoc1:.
8 - ~jo:;>, I . .)
o, v•- · · - -
r 0:.
-- --.
,
Date Sent Email From Email To Email CC Subject/Description Privilege Asserted Basis for Claim
Confidential communication
Ed Licbennan; Glenn Re: Appointment with Cong. performed at the direction of
5/13/16 Rinat Akhmctshin Mark Cymrot Attorney Work Product
Simpson Hill counsel in anticipation of
litigation
Glenn Simpson; Ed Re: Appointment with Cong. performed at the direction of
5/13/16 Rinat Ak.hmetshin MarkCymrot Attorney Work Product
Liebennan Hill counsel in anticipation of
liti11ation
Glenn Simpson; Ed FW: Appointment with Cong. perfonned at the direction of
5/13/16 Mark Cymrot Rinat Akhmetshin Attorney Work Product
Liebennan Hill counsel in anticipation of
liti2ation
Mark Cymrot; Glenn Re: Collectio n of Press performed at the direction of
5/ 16/16 Loura Alaverdi Attorney Work Product
Simpson Stories counsel in anticipation of
litigation
Rinat Akhmetshin; Ed Confidential communication
Lieberman; Loura Alaverdi; performed at the direction of
5/16/16 Mark Cymrot Glenn Simpson Collection of Press Stories Attorney Work Product
Paul Levine; Molly Levinson; counsel in anticipat ion of
Ryan Toohey litil!ation
Rinat A.khmetshin; Ed Confidential communication
Lieberman; Loura Alaverdi; Re: Collection of Press perfonned at the direction of
5/ 16/16 Glenn Simpson Mark Cymrot; Attorney Work Product
Paul Levine; Molly Levinson; Stories counsel in anticipation of
Ryan Toohey litigation
Mark Cymrot; Rinat Confidential communication
Ak.hmetshin; Ed Lieberman; performed at the direction of
5/16/16 Paul Levine Re: National Review Attorney Work Product
Glenn Simpson; Loura counsel in anticipation of
Alaverdi litisrntion
Rinat Akhmetshin; Ed
performed at the direction of
5/16/16 MarkCymrot Paul Levine Liebennan; Glenn Simpson; Re: National Review Attorney Work Product
counsel in anticipation of
Loura Alaverdi;
liti2ation
Ak.hmetshin; Ed Lieberman; performed at the direction of
5/16/16 Paul Levine RE: National Review Attorney Work Product
Alaverdi· litigation
RELEASED BY AUTHORITY OF THE CHAIRMAN OF THE SENATE JUDICIARY COMMITTEE

Eoflfidefltial fer Proauetiofl to SeAate Judiciarv CoFAFAittee Only 1
Date Sent Email From Email To Email CC Subject/Description Privilege Asserted Basis for Claim

Akhmetshin; Ed Lieberman; performed at the direction of
5/16/16 Paul Levine RE: National Review Attorney Work Product
Alaverdi; litigation
Glenn Simpson;
Re: Collection of Press performed at the direction of
5/16/16 MarkCymrot Loura Alaverdi R.inat Ak.hmetshin; Ed Attorney Work Product
Stories counsel in anticipation of
Lieberman
litigation
Mark Cymrot; Glenn RE: Collection of Press performed at the direction of
5/16/ ]6 Loura Alaverdi Attorney Work Product
Simpson Stories counsel in anticipation of
litigation
Rinat Akhmetshin; Ed FW: United States v. performed at the direction of
5/17/16 Mark Cymrot Loura Alaverdi; Paul Levine Attorney Work Product
Liebennan; Glenn Simpson Prevezon counsel in anticipation of
litigation
Paul Levine; Rinat Fwd: Important message from Confidential communication
Akhmetshin; Glenn Simpson; Bill Browder about Sergei performed at the direction of
5/ 18/ 16 MarkCymrot Attorney Work Product
Loura Alaverdi; Ed Magnitsky before HFAC counsel in anticipation of
Lieberman mark-un litigation
Re: Important message from Confidential communication
Bill Browder about Sergei performed at the direction of
5/ 18/J 6 Mark Cymrot Attorney Work Product
Magnitsky before HFAC counsel in anticipation of
mark-uo litigation
Fwd: Important message from Confidential communication
5/J 8/ 16 Mark Cymrot Attorney Work Product
Magnit.sky before HF AC counsel in anticipation of
mark-uo litigation
5/18/ 16 Mark Cymrot Attorney Work Product
mark-uo litigation
5/18/ 16 Mark Cymrot Attorney Work Product
Magnitsky before HF AC counsel in anticipation of
mark-uo litil!.ation
Fwd: Important message from Confidential communication
5/ 18/16 MarkCymrot Attorney Work Product
mark-uo litieation

CoAfiaeAtial for Proa1,1EtioA to Senate J1,1aiEiarv (91'.J'lrAitt@@ Onlv 2
Date Sent Email From Email To Email CC SubjecUDescrrption Privilege Asserted Basis for Claim
Paul Levine; Ed Lieberman; Fwd: Important message from Confidential communication

Rina! Akhmetshin; Loura Bill Browder about Sergei performed at the direction of
5/18/16 Mark Cymrot Attorney Work Product
Alaverdi; ; Glenn Magnitsky before HFAC counsel in anticipation of
Simoson mark-un litigation
FW: Statement in Response
to Representative Dana Confidential communication
Paul Levine; Loura Alaverdi; Rinat Akhmetshin; Ed Rohrabacher's Remarks at the performed at the direction of
5/20/16 MarkCymrot Attorney Work Product
Glenn Simpson Lieberman House Foreign Affairs counsel in anticipation of
Committee Mark-up on litigation
Global Ma,mitskv
Fwd: Collection of Press performed al the direction of
Peter Fritsch MarkCymrot Glenn Simpson Attorney Work Product
10/27/16 litiization
Fwd: Collection of Press performed at the direction of
Peter Fritsch Mark Cymrot Glenn Simpson Attorney Work Product
10127/16 liti2atioo

ConfiaeRt ial for Proa1:Jction t o Senate h,1Eliciarv Committee Onlv 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·u pportlng 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 fromthe 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
. . ··~ . . . .
. .~ ·. :
' .-.:' .: :_.:.·..-...·.:·~.· \· . '· . ....
Detail . . <: . · : ...:.:. _- :_./_/\>.:·.\ \.)

..... ·. . .. ·.... ·:, .· : : ... ··.· .::\~{.::·.'.·>_:.. -"'·.
1. Speaking·\~ a :trus.ted cQ_mpatr.iot.hfJuhe ·2016. ·soµr,ces·Aal;ld:B],a·senfo{-. ·. · .. '
Rus~ian·. f oreign_} f1.~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.t j~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
... -·· ------ - - - - - - - - -- - -
i
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
or
should Ill· seen in terms PUTIN's desire t , return ro Ninl'Lct:nth
Century ·r.rc:n Pc,wcr' politics anchored up.,u c.m111t11es· imcrcsls rr1tltt'r
1h..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) cond uct in
Mosco\,\ tncluded hit mg t hl, prc3idetllia'. -.uite o l 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! rwerl' 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 th ere 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 Kreml in's reported in.Llligcnce feed to TRUMP over
recent years and rumours about a Rus --.1.1n dossier of 'kornpromal' 011
CONFIDENTIAL/SENSITIVE SOURCE
CONFIDENTIAi - EQR SENLITE

· JUDICl"Rv
M lCOHH
v v . PRODUCTIO <;J Ol'JLY
CLMSJC00041392
~· ..
Hillary CLINTON (bei ng 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 hu gged
commen ts CLINTON had made on her v,1rious trips to Russia and focused
on things she had said which rn11 1radic: t,•d her curren t positi on 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/han d ling It on the ex-plicit in,;: ruction:; of PUTIN himself. T h e
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
CLMSJC00041393
COJIJFIDEf~TIAL- FOR SENATE JUDICIARY COMM PRQQl JCTION ONLY
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·e r visi.~ rs ·t o 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.e m 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,a.n 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'ed'. 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
;: ·...• ·· ..
. :·
~~.~~';i~~Fii~f~~t~~i;t)}JBR
~~~-~~~dit':_·,_·~~M
~J~i~a.';L·•.· .·.
,• ..
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·a d been · :
unwittingly compromised; were recruited. Many were people who _h ad · ·
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 o16 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 tcfpro~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 ofthe .·;
~om_pany: Al~9~~bJ~~ .1.~~er w~~ ap~~entlf~ij)~fl,:equen~ v.isitQr-t o ·'.· . ..
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 . ·
.• •.: .
.. •. •, . ( . --; · .... . :.·. . _::,..·..: ··.~-: ;~ :~ .:,:···: ..: . •. . .
•' . .. . .• ...
. :~.
' : .
. ..' '·;.// '5

cmJFI tiE)fFIAL .·r:oR 'SEWATE'"3DDJtlARY-tdM IOi'~PRO'DU-CTiOt>f O~SLY .,. . ""CLMSJCOOb41395
.
' ..
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 frcquc utly 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 gener ally,
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 a nd FSB contr ol. These it,( uded the so-called 'Anunak',
·nuktrap' and 'Metel' organisations.
Z6 July 2015
CONFIDENTIAL/SENSIT IVE SOURCE

l
CONFIDENTIAL FOR SENATE JOOICIARY COMM. PRODI ICTION ONI Y CLMSJC00041396
..
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 ·. ·
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
Detail
• : • • :.
..·. -:
•• : • • • • ;., , : ; .... ' • • • \ • • . :· • •• : ~' • • > • • • • .'. . : • ,.; • '·., • •
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~...theR~sian-:r.e.aij~~ip..Thls was .,- ....
managed on the TRVMP side b~thc -~P.~b-litaJi'aiiicU4ate's·:campaign
mariaget, Paul:MANA~dRT;:wn~fYvas'~$fng-'for~.tgfp'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'tial.~ndteul.te]U\l.acy...CL1NTON, whom
.Presiderit.PUTIN.apparentlybQJh hatj!~·ana,(ea~¢;:,:::: . ·, :.. . -.
• ; : .~ : . . .... .. . •: •. . •• ·.:· · . •. · .:::.·· ; •'\:;~ .... ....... : . ,; . :·:· : ·~·.··:: .• , .j .. ~:: .
2:~.- _1ni~;;~~;,;.,~P~,~~e·.E,'~·~kno~l~~i~ t~i~'th~::R~~t;~\~

~gi~e·had be~n ,
. :·.;,·b~~~~(,t}(e;~~~~n,~ le~l< of~m,lia.tf~ ssiqg:e-:µi~~:~.e~sages,::einahattng'Ir:om
..-.:·.th.f~_em:ocratfc Na~9nal ·comm'fj~ce.(J)'NC); t.d.:th"e -Wi~i~aks-platform;: .
-s:~~ ~ ~--
cci~~r1t:>6iriAt:· ~eR·~s~~Xfe.,~ief1~RY.:too~lrRetlQ'cr10.l{6~~tY,:j .~-:. :~ ·;;·<. ·:-:CLMSJCO.C)"04J397
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.e r 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 ·s upport 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.MP's b~ne5$.dealings.in China·and .
other emerglng·markets. Unlike.tn·Russia, $UbSbµ1ti11l:ah~.· .· t,h~e,were
Involved the payment of.large:~.r,~bes and kickpac~\vhich, we·r e 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.'a s 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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1
C
CONFIDENTIAL FOR SO~ATE JUDICIARY COMM. PRODUCTION mJLY CLMSJC00041398
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
of
details 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~.o pe_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 .i n 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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. .. •.,i\ f,;:);(I '. :.:lfti~t{~~t tiiP)\(l.ft;::~{:ji'.:,,> ; i. •:·.

GONFiDEr>JTI/\L FOR.8E~,A'ft'""JCfD+GIAR~~c:m.fit511bffO)c.]lY." . ....,. . CLMSJCOOb4·1399
.
1 1) July 2016
{C
COl>JFIDHHIAL FOR SEl>JATE JUDICIARY GOMM . PRODUCTION ONLY CLMSJC00041400
•
RUSSIA-US PRESIDENTIAL ELECTION: KREMLIN CONCERN THAT POLITICAL FALLOUT FRO~

DNC E-MAIL HACKJNG AFFAIR SPIRALLING OUT OF CONTROL
Summary
KremHn concerned that political fallout from DNC e-mail hacking operation Is spiralling
out of control. Extreme nervousness among TRU MP'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 fut ure
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
Detail
1. Speaking In confidence to a trusted assoclat~ In l.:ite 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.i th le~.e l :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{ otryef s ·.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.u ld 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 ·
~))p hls_:,.~sg~~~.~10,1,1ly h~~fob~\.ned and· ...
Russian ollg~.r.(hs·.~?.:~:~~-l~~f'l.1.1.J~s. J'ij.~.~p1
supplied the.,Kr.,mlln -Mth.~hts·ftiformattorr,,,/·... . :. ·;,>:·/·:/>'':. ·.'.. ,·...· .·...,> ''··.·, ·
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co~WIOE~JTIAl "'FOR'SENltrE-JtJUICfXRY C'Orvfl'vf."i=>Rb DUGTION b t>""JLY .• . . . GLMSJC00041401

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 , ri derst ood the Kreml in had given its
word that it would not be deployed against thr:: Republican presidential candidate
given how hel pful 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 CLMSJC00041402

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$.l .
Administration, Sergei IVANOV, ·was.angry at the recertt turn of-events,
He believed the Kremlin #tec1m" lnvolyed, Jcu by pr~idential ~9kesman
Dmitriy PESKOV, had gone too far in fnt~rferlng lJ1:forelgn affaii:s-~ith
their "elephant In a china shop blackPR'\IVAN:OV:dalmea always to'. have
opposed the handling and exploitation Qf Intelligence by this Pll'.~te~m".
Followiog the backJash against such for~lgntnier.fetencein .Us'°politics,
lVANOV was advocating that the only sensible course
of action now for
the Russian le~dersbip ~s to "slt.tight·and detjf~v~iWting'.'.. ~ : .
2. Continuing
•
on·thfstheme the SQur.ce;~~~e
' ,. .
iv~~QV~~p~~d th~t.: .:: . . ·.
lo •' • •• :. ,. .. . l .. .. .. •• . . ' •
sf,'~ ' .. • ' • • • • ••
PESJ<OV now was_.: se;tred shitle~(-_ th~t~e w~.~~~:li~,J~~~6,9.~~c;for .,.: ....: _·..' ,.'. .. .
PUTIN an~ ~e-~em_ ltn:.~ d ~eld,-~~~~,ijhleJor.JP.~-.~~~~-~ b~~gai9st: . ·.:~::_\<.'·· ·. ·
Russia~ ·pohti~l ~te.rference tn .$.(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 fut ure, C: Lt i 1er 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 bee n talk in the
Kremlin of TIUJM P being forced lo withd1 . '/\/ from th!! presidential race
altogethe r 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 b ut in the v iew of the source. il
ruma in ed largely wishful lhinking 011 lhc p.m oflhose in Lhc regime
oµposed LO PES KOV and his "bolchcd" opt·1a tions. at lease for the time
being.
5 August 2016
GOt>lFIDENTIAL FOR SEt>V\TE JUDICIARY GOMM. PRODUCTION Ot>JLY 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
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
Detalls
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
to
presidential election 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 the-
educated 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.'. ·. 0 0
0
3. IVANOV reported that.although the

~remHnhad "n;e'resti; ~ th~ ~~~~-~{G~~la
a~d -ll~i''
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
us had tried to divide the Russlanelltewi~s~nctlo.~ butfa)le(J,\~h!lstthey,by contrast, had
view, the
succeeded In spll ttl ng the US hawks I nlmical .to Russia _a_nd ~ :W~s.hlniio.~,11te}nore generally,·ha lf.of-
whom 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 In.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--': . .
: :'· • • • • • ' -: : • : J ~ •
; . ..
~
. '.t5
GONFIDHlTIAL ' FOR ~i;°EN!i.rE·J~RY~ROOUCflO~J'O~llY .- .·~·-'"'"""cLMsjcoo6,i1'405
RELEASED BY AUTHORITY OF THE CHAIRMAN OF THE SENATE JUDICIARY COMM ITTEE
Caner PAGE; and former O!A l)irC(tOr Michael Flynn I this reg31d .)nd as succ<:Ssfu! In terms of
pcrcelvcd OU ICOrTI<'S
JO Augu st 2016
I It
COl!>JFIDENTI/\L FOR SHJ/\TE: JUDICIARY GOMM. PRODUCTION ONLY CLMSJC00041406
I I
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
'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
Detail
'(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!)ctf y,.v11 ., tne ethnic Russ i aHocl.ite
2 rgon :.1·1s lh.,,mo, tht- tthn,c Russ,an associutec• ltUMP ass~se<! that tht:. problem was that
(ur 1 ,,,..
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 th e 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
l1
=-co~r IDEN I !AL FOR SENATE JUDICIARY GOMM. PROOUCTIOJ'.11 ONLY CLMSJC00041407
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
CO IJc.,,"s SECRf:T LIAISON WITH THl: Kl{L::-.tuN
Su mni~t)"
ls..r, mlin 111-,i..lt•, rq 1(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.11 1i,.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"
,in.I 11\cl) h.n ,.. partirip.llt!d in till' ,\11 gu,;t meet i n;:/:,. with CO! JE N
l,lt il1t,1tor
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:-.t uw 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'$L'l .t 1lt\'t'::. in ,\ugu•,I 2016. ,\! though !ht'
i:ommurnrnthm bdwc,•n them had to be Cf) plic !or sccun •y rc.ii;ons; thc Krt>mlin in~idm
cl1·,1rly i11d 1c,11t.-J w hi.;/ he r fric.>nd Lhilt !ht: n• porh:d cont.a\ t /s tool.. plac,• in Prague, Czed,
Rt'public.
2 Continuing on thi:s tlwm1:, tlw Krt'mlin im,,dl'r hit,hl ishh ·LI the im portanc-.:? n( th<.' Rw,.,ian
pnr:i,;t.11:il organi-..:itfon, Ros:-.otrucinid ws l\'o, in this cont.1, t bcnvecn TRUMP rnmp,1ign
ll'JHc'"c·nt<1tn L' 1 .., and Krc•mlm official, Ro,,<1trudnichcst ,·,, w.:1s being used .1s cover for thii;
rt'lt1ti,)nship and it,; ol fit"l' in Prague m,1y \\ ell have been u.,ed to host the COl lEN / Rusi;ian
1'1 t'~H:.knt iJI 1\Jmini~tr.1 tto11 (PA) meeling h,. It was considered a "plausibly deninblc" vdttcle
Im this, whibL rem,1ining entirely under Kremlin control.
3 Thl' Kr~mlin in~idcr went on to identify leading pro-PUTI 'l Oumn figure, l(onstant1n
KOS. \Cl II.: \I (1 lead oi tlw Fcm·ign Rek1tio11s Committee') .is an importnnt figure in the TRUMP
c,11np,1:gn-hn:mli11 li,1be>n opl.'r,1lion KUS.\CI IEV, ,,lso · ! tausibl) deninbk-" being part of Lht>
Ru,-.,ian ll·ghl.ituri: r.i!ht'r than executive, h,,J facilita t('d 1. 1«.• contact in Prague and by
impl:c,itam, mav h.1w .1ttc11dcd the mc•eti11M/ s wilh COi lt~N there in August.
Company Comment
\ \"<:> H'pt,IIL'Jprcviou~ly, in our Compnny lnh·lhgcnce Rl•po11 :0 16/ 135 of 19 Och.>bcr 2016 from the
-.,mh'· tl1tJl COHEN met offici.ib f1on1 the PA Legal Dv ,.11tment dandesti.nely in an EU
't 1111H1,
count I y in Augu:-.t 2016. Thi-. W,b in 01 dt•r to\. hm up the rn, ··.s left behind by west<:rn media
r11, d.itio:,., of rnUMP ex-(,,mpaign manager i\ !ANA FOR f ' .. , orrupt rcldtionship with the former
pn)· l~u,~i.111 YA1'UKOVYCI I regime in Ukrnin1..' and TRUMI ' forcil)n policy advi~or, Carter
P1\CE's M'cr~t meeting::. in Moscow with :,enior wgimc figurv-. in July 2016. Accordi,1& to the
Kremlin ,1dvi:;cH, thc.'$t' mucting/ s W<?r(' originally scheduled !t)J' COHEN in Moscow but shifted to
1
•
1
-COM'lffl:~ffrf!.t F€lR ODJP.TE Jl::t016 1ARY·GOMM. PRODUCTION GNI::¥ CLMSJC00041408
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
OMFtb'ENT!ft.t!°'.FO~ ~l'U tTI! ::IUDlet=ARY GOMM . PRODUCTIO~I ONLY CLMSJC00041409

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

MANAFORT
Sum111<1.ry
f:,-lJl:r.uni..111 Pr L'.;tdt:lll Y/\NllKO\'YCI I con·! les directly to l'lJT IN th at 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 t hat
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
Detail
1. Spe..iking i11 latc August 2010.1n the imnu. t11ale aftermath of Paul
~li\NAFORT's resignati on 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 1 velations about MANAFORT
and Ukraine had featured prorninently on t he agenda. YANUKOVYCH had
wnf1dl'cl in PUTIN thaLhE:' 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 th em 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
c ampaign manager, Cor\?y LEWJ\NOOWSK I 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
"2. I
Ki foi "''1 'ii'~t=:IO~l<l I Ot.C FU~ SENATE JUDICIARY COMM. PRODUCTION ONLY CLMSJC00041411
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
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:o ns 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\' ,o nlinues 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
Derail
1. Sµt,1k1ng i11 tunf1<Jencc: to <1 trustcd compat1t• >L in mlcJ-Scptcmbcr l016. a

sc11io1 membc1 of the Russian Presidential .\•lm inblration (P,\)
rnmmcmed on tht political fallou t 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 forme r 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 presiden t 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 mid -
Septemhcr. There was however a growing tr.1111 of thought and associated
lobby, ,ffgL:i11g that the Rus5ians could still 111.ike candidate CLINTON look
"we.ik :ind stupid" by provoking her in to rai l rng against PUT! N and
Russin vvithout the n eed 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 r egard.
COt'>IFIDENTIAl FOR SEt>JATE JUDICIARY COMM. PRODUCTION ONLY CLMSJC00041413

Company Commen t
The substance of wh.n was reponed by the senio ,· .{uss inn PA official i11 par<1s l
and 2 nbovc:, incl uding 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
CmfflDENTIAL FOR SENATE JUDICIARY GOMM . PRODUCTIO~J ONLY CLMSJC00041414

COMPANY lNTEl.LIGENCE REPORT 2 016/1 12
1WSS1i\/1JS PHESIDENTlA L ELECTION: l<REMLIN ·All'HA GROUP CO·

0 PER,\ TIO N
Sununary
'l'op it!vl'I R11s~Llll o ll ici.1: (\m1inns cu rren t clos, 1 cs~ of /\lpha Croup·
PUTIN relat io n8h1 p. Signific:an l f.tvo urs co nli11uL· •"u be done in bo th
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 -Alph a relatio nship il'('ntif1 ed as Oleg

GOVORUN, cu1Ten1ly Head ofa Prl.!s idenlial Ad1 11 11istration clepartment
but throughout the J990s. the Alpll,1 executive\\ i10 delivered ill icit cash
dirt'nlv to PUTIN
PlJTIN pl'rso11ally unbothcrcrl obou t Alpbc1's cu rre nl la<:k nf investmen t in

Russia but un der pressure from co l leagu es o ve1 this and obit: Lo <~xploit it
<1:. IL',cr uv1:1 Alpht1 interlocutors
Detail
1. -.;peaking w nu ust<.:cl com p~ll n o l 111 mid-Septen1ncr 2016, a top level

the· :1is Lory anti current s La l~
Hu.,..;i rn governmen t official rn111111e1Hed on
ol relations between Presiden t PUTIN a nd the ,\!pha Group of businesses
led by oligarchs Mikhail FRIDMA N, Petr AVEN ~rn d German KHAN. The
Hus::,ian government figure r eporl~d lhat although lhey had had their ups
Jnd downs, the leading fi gu 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 bu sin ess/legal ones for
/dpha. Also, FTU DMAN an d AVEN continued to g!ve informr1I advi ce l o
PUTIN on foreign policy, and cspc:c!a lly about the US where he distrusted
:1dvice being given to him by o fficials.
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\d mintslnition uffidaL Oleg GOVORUN, who curre ntly
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 th e 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 carri er"
CO~JFIDENTI/\L FOR SENATE JUDICIARY COMM. PRODUCTION GNbY CLMSJC00041415

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 1ti•.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
CONFIDENTIAL F'OR SENATE JUDICIARY GOMM. PRODUCTION ONLY

CLMSJC00041416
'
,,
COMPANY INTELLIGENCE REPORT 20 16/113
RUSSIA/US !'RESIDENT I AL ELECTION- REPUBLI CAN CANDIDATE TRUMP'S

PRIOR ACTIVITIES I N ST PETtRSOURG
Summary
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
Detail
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 preside nt 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 r eported that TRUMP had
paid bribes there to further his interests b ut 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 partic ipated in sex
parties in the city too, but that :tll direct w1l11esses to this recently had
been "silenced" i.e. brihed or coerce d 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
CONFIDENTIAL FOR SENATE JUDICIARY COMM. PRODUCTlmJ ONLY CLMSJC00041417

,,
COMPANY INTELLIG ENCE REPO RT 20161, 30
RUSSIA. KREMLIN ASSE SSMENT OF T RU M P ANO RU~i ~-'IAN INTE;AF ERENCE IN US

PRE:SIOENTlAL ELEC TlON
Swmnar)'
Buyl!r 's romorse s!.!\$ In w1rt1 Krmnlm ovor TRUMP sur, ,ort operation m U S presidentlrJI
eldCh:J n Rus::.,nn l0<.1drm;.h1p Ot::.dp pe,lnteo 111<.11 leaked EH 1~ils on CLINTON h.avo not h ad
gr oacor impact u1 camp algt)
Ru~s1ans have lnJac1Gd lurtt1er Mlt•CLINTON materla1 1:110 tne ·p taussbly denlable' l.aaks
plpalinfJ which w ill contH1u~ 10 surface, but best rna torlal ,Jready In public domain
PUTIN ar)yry wrm sa n,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 c urrant 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 lru stGd compa•r ot tn ear~y October 2016. a se ruor
Ru ~ s1an lo<1oe rsh1p lrgurC> and a Foreign M1n1i.lry oftlcul 1eported on recant cte-velopments
cur.cern,ng tl-ia Kremlin 's o ~ ratio r'I to suppoft R(3publl<-111 ca11dldate Oonatd TRUMP .n lt)ll
US pressd8nltal elG<:ltt>n. T he s ~rHO ! l!:)aderstup hgu re s utd that a dogma of buy~r·s remorse
wa::; setung ,n wnong Ru s.slun leaoe, s concerning TRUMP. PUTII.J ano his colleag ues were
::;urpnsed ano dlsappo1nted shat leaks of D i:tmocrotlc CJ,ldtdato, Hillary CLINTON'S haclc~a
&·mall~ had not had groa1er ,mp a.cl on the carnp,:l1gr\.
2. Cor\l1nu1ng on ths~ !hr?rne. the senior leadsrshlp rtgure '~) rnm ant8d that a stream or
rurth&r
h<Jckeu CLJNTON mn19r,al alre ady 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 l hart:) W&riiJ no real garna-changers
to con,o
3 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 T RUMP
suHxirt o~ra tlon 11"1 thB t,rst pl~ea . th~ M FA offlcta.l so1u that Russi~ r\a.ed&d to ul)set the
iiboral lnt&r national s tatus quo, Including on U kralna-r..:ilaled sanc11ons, which was ser1ously
- COf.aFIOtNTIAL FOR SE~~ATE JUDICIARY GOMM. PRODUCTIO~J Ql)JbY

CLMSJC00041418
( I
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 11he lost IM pros1ci1:tncy and may run lor and be
elocteci lo tlnolher public o1hce.
12 Oclabt:Jr 20 16
~IDEM I IA.l FOR SENATE JUDICIARY COMM . PRODUCTION ONLY CLMSJC00041419

~ I
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
,·,111firm, 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 1 1c)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 , cill-.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 O ti11t ,~~r, wh1:n lw ilb~'>St'<l lhis was no
lnn8t'r po,-,1bk· <;t,e. I !IN w,,.,
h•,m to rn·,hlc1pt ;iccordi n1~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
to 1h1.: 11.'ad~r,hip confirmed U1a t o kc) role m the .,, (rct TRU~.{P campaign/ Kremlin
J1 t•.•:.:,
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 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
l
dv,ll !\ ti11p,11·J th.it In h•rms 111 hi, l',)!1111H'nl fll1 ·rl{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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•• • r• • '
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..
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'
'
. . - -- .
.
- - - - -- -
LS Cklub l.'r 20 I 1,
CONFIDENTIAL FOR SENATE JUDICIARY GOMM . PRODUCTION ONLY CLMSJC00041421

>I
•
RUSSIA/US PRESIDENTIAL ELECfl ON: THE I MPOlff/\NT ROLE OF TRUMP

1.!\\VYER, COHEN I N CAMPAIGN'S SECRET LIAISO\ W ITH T HE KREMLIN
Summa1-y
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 u p 1(1emlin's TRUMP support
opcr,llion
Detail
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
CONFIOEPfflAL- FOR SD~ATE JUDICIARY GOMM. PRODUCTION ONLY CLMSJC00041422

t ' •
• •
..
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 lVAN OV .is Head of PA
in August 2016. his replaceme nt 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 unsur e 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 s ecuriry 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
cmfftDENTIAL FOR SENATE JUDICIARY GOMM . PRODUCTION ONLY CLMSJC00041423

.. ••'
COMPANY INTELLIGENCE REPORT 201 6/166
US/RUSSlA: FURTHER DETAILS OF SECRET OJALOt;lJE BETWEEN TRUMP

CAMPAIGN TEAM, !<REMLIN ANO ASSOCIATED H1\CKERS IN PRAGUE
Summary
rnUMI'':; rq>rt'!,.('lll.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 ras 11 ;,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
1r1Pr ,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 ,m ti·
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 opc1at1 1 : umh~r
RPs,11t111d111chestvo cov:ir. Acc·,1ding 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.
CONFIDENTIAL- FOR SENATE JUDICIARY COMM. PRODUCTION ONLY CLMSJC00041424

RELEASED BY AUTHORITY OF THE CHAIRMAN OF THE SENATE JUDICIARY COMMITTEE - - - - - - - - -- - - - - " "
..,
3. reportt?d tha! over lhc pi r .ud M.irch-Septcmber 2016

a company called and its aifili.,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 rJiat 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.lP-
Krl'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 prJ ct 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 othe r
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
COMFIDENTIAL- FOR SE~~ATE JUDICIARY COMM. PROD! ICTION ONI Y CLMSJC00041425 :, S

EXHIBIT
t..,I
~· ,9;) . I ' l -r~
IN THE HIGH COURT OF JUSTICE / ·.-t: cffa'1fii.No. Q11Doo413
!
QUEEN'S BENCH DIVISION
-, APR 2017
BETWEEN:- ' , - -- - · "?
(1) ALEKSEJ GUBAf\~~ ..... ,JUD ,q_"-·

(2) WEBZILLA B.V. ''<lC•N f)X'"'
(3) WEBZILLA LIMITED -'·'-"--~
(4) XBT HOLDINGS S.A.
Claimants
-and-
(1) ORBIS BUSINESS INTELLIGENCE LIMITED

(2) CHRISTOPHER STEELE
Defendants
DEFENCE
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 pre-
election 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 Pre-
Action 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 Pre-
action 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:
Christopher Steele
Position: Director, Orbis Business Intelligence Ltd
Date: 03 April 2017
TBH23475964 v1
EXHIBIT
._s,-
.
.-·d i:) · I ·- )
~-
IN THE HIGH COURT OF JUSTICE Claim no. n"" •. - _
BETWEEN
(1) ALEKSEJ GUBAREV
{2) WEBZILLA B.V.
(3) WEBZILLA LIMITED
(4) XBT HOLDING S.A
Claimants
and
(1) ORBIS BUSINESS INTELLIGENCE LIMITED

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:
Nicola Cain
Position: Legal Director, RPC; Defendants' legal representative
Date: 18 May 2017
-9- RPC
Claim No. HQ17D00413
IN THE HIGH COURT OF JUSTICE

BETWEEN
(1) ALEKSEJ GUBAREV
(2) WEBZILLA B.V.
(3) WEBZILLA LIMITED
(4) XBT HOLDINGS.A.
Claimants
and
(1) ORBIS BUSINESS INTELLIGENCE

LIMITED
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
TBH23772701 v1
EXHIBIT
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 PJM-SJC-00000002

Simpson Exhibits Redacted

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EXHIBIT

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VlA ELECTRONIC TRANSMISSION

Dear Mr. Levy:

Charles E. Grassley Dianne Feinstein

RELEASED BY AUTHORITY OF THE CHAIRMAN OF THE SENATE JUDICIARY COMMITTEE

Mark Cymrot; Rinat Confidential communication

RELEASED BY AUTHORITY OF THE CHAIRMAN OF THE SENATE JUDICIARY COMMITTEE

Paul Levine; Ed Lieberman; Fwd: Important message from Confidential communication

RELEASED BY AUTHORITY OF THE CHAIRMAN OF THE SENATE JUDICIARY COMMITTEE

COMPANY JNTELIJGENCE REPORT 2016/080

US PRESIDENTIAL EtECTION: REPUBLICAN CANDIDATE DONALD TRUMP'S

Russian regt~e,has.been .cultivating. s·u pportlng and a'sslsting·TRU~PJor

Former top·Rl,lsslan 'intelligence officer cl~lm~ FSB. has .c9~prom.ls~d

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CONFIDENTIAi - EQR SENLITE

Hillary CLINTON (bei ng rirl'ul:lwd), Sow·ce r3 confirmed the nte's

6. Continuing on this theme. Source G, a sen ior Kremlin official. confided

COMPANY INTEUIGENCE REPORT 2016/086

RUSSIA/CVBER CRIME: A SYNOPSIS OF RUSSIAN STATE SPONSORED AND

- Russia has extensive programme of shltt'·sponsored offensive cyber

· Example .cited of successful Russian.cyhe~.operatlo~·~rg~ti~g senior

Example given of us citizen ofRussian origin.appr:oach~d.b~ PSB and

Problems however for Russia~ aut~orities them~el_ves.lil co.un~e~lng local .

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western governments; penetrating leading foreign business corporations,

2. In term~ of the success of Russian offensive cyber op~rations to date, a

4. Jn a more advanced an_d successful FSB _oper,at_lo;11, an.IT _operator ti1sJde a .

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5. In terms of oLher technical IT platform~ an FSB cyber operative f1agg1:d

CONFIDENTIAL/SENSIT IVE SOURCE

COMPANY INTELLIGENCE REPO~T 2016/095

RUSSIA/US PRESIDBNTIAL ELECTION: FURTHER INDICATIONS OF

Further evidence of extensive conspiracy between TRUMP's campaign

• TRUMP associate admits Kremlin behind recent appearance of DNC e·

• Agreed exchange of information established in both directions. TRUMP's

• Mechanism for transmitting this.Intelligence involves "pension"

Suggestion from source close io:TRUMP and MA1'1AF9RT that Republican

1. ·Speaking in confld~nce to ~ C?.~P~t1i9,t,J.tl :!~~e. l~W~;?P.W?•:.SQ~~~e·-&~ aA:·'_.-- · ·

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3. ln the wider context of TRUMP campaign/Kremlin co-operation, Source E

4. In terms of the intelllgence flow from·thc TRUMP team to Russia, Source

5. Commenting on.the negative medla publicity:surroundlng alleged

6. Finally, regarding TRUMP's claimed mi'nima·l i~ves'tment profile in Russia,

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RUSSIA: SECRET KREMLIN MEETINGS ATTENDED BY TRUMP ADVISOR,

- TRUMP advisor Carter PAGE holds secret nwetings In Moscow with

- SECHJN raises Issues of future bilateral US- Russia energy co-operation

• DIVEYKIN ~iscusses release of Russian dossier of 'kompromat' on

1. Speaking in July 2016, a Russian s.ource close to Rosneft President, PUTIN.

2. According to SECHIN's associate, the Rosneft President (Ceo) had raised

3. Speaking separately, also .i n July 2016, an.offici;ll,ctose-.to Presicfo~tial

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